This checklist helps EU importers verify whether evidence provided by their timber suppliers is sufficient to support a defensible Due Diligence Statement before filing. Unlike exporter-oriented checklists that guide evidence collection, this template focuses on the importer's verification obligation: assessing the completeness, consistency, and credibility of evidence you receive.
Under Article 4, the EU importer bears primary legal liability. If a competent authority challenges your DDS and the underlying supplier evidence is weak, the penalty exposure falls on you — up to 4% of EU-wide annual turnover. Timber importers face unique challenges: species identification (Article 9(1)(a)), the selective-logging-versus-deforestation distinction, the EUTR-to-EUDR transition, and the limited scope of FLEGT licences.
What is the EU importer's verification obligation?
Regulation 2023/1115 requires the operator placing timber on the EU market to exercise due diligence encompassing information gathering, risk assessment, and risk mitigation (Article 8). The importer cannot delegate this obligation to suppliers, sawmills, or traders. Even where upstream actors have identified species and documented legality, the importer must independently assess whether that evidence is sufficient and credible.
Timber supply chains span 3-4 tiers: concession or plantation to sawmill, sawmill to secondary processing, processor to exporter, exporter to EU importer. Importers who operated under the EUTR must not assume prior compliance satisfies the EUDR — the requirements are materially different.
What this template covers
Supplier documentation review
- Confirm supplier has provided a complete evidence package — not just a FLEGT licence, FSC/PEFC certificate, or self-certification
- Verify evidence covers the specific harvest compartment(s), not just the broader concession
- Check that evidence is dated and version-controlled — reject undated documents
- Confirm all intermediaries (sawmills, secondary processors, traders) are identified by name
- Verify the supplier has not conflated EUTR compliance with EUDR compliance — the EUDR adds deforestation-free verification and geolocation requirements the EUTR did not require
- Confirm attestations are signed by an authorised representative
Red flags: FLEGT licence or FSC certificate as sole evidence. "We were EUTR compliant, so we are EUDR compliant." Evidence refers to the concession without identifying harvest compartments.
Geolocation data verification
- Verify coordinates are at harvest-compartment level — not concession boundary — in WGS84/EPSG:4326 at 6-decimal precision
- Confirm polygon boundaries define the specific area harvested, with collection timestamps and device metadata
- Cross-check a sample of coordinates against satellite imagery to confirm forest at the indicated locations
- Verify collection timestamps correspond to the harvest period, not a historical survey
- Confirm each harvest area links to a concession holder, plantation owner, or community forest manager with current tenure
- For plantation timber: verify geolocation distinguishes the plantation from adjacent natural forest
Red flags: Round-number coordinates — likely estimated. Concession-level polygons only, no harvest compartment detail. Polygon area far exceeds what the documented volume would require. Multiple consignments from different periods share identical geolocation.
Deforestation-free evidence assessment
- Verify deforestation screening against the December 31, 2020 cutoff using satellite imagery at sufficient resolution
- Confirm screening distinguishes selective logging (harvesting within a standing forest) from deforestation (conversion to non-forest per the FAO definition)
- Check that independent alert systems (e.g., Global Forest Watch, JRC Tropical Moist Forest monitoring) were cross-referenced
- Verify pre- and post-harvest canopy cover analysis demonstrates the area remains forested
- For plantation timber: verify the plantation was not established on land converted from forest after December 31, 2020
- Confirm screening methodology is documented: data sources, resolution, and decision thresholds
Red flags: FSC/PEFC cited as sole deforestation-free evidence — certifications do not use the December 31, 2020 cutoff. FLEGT licence cited for deforestation-free status — FLEGT covers legality only. No selective-logging-versus-clear-cutting distinction.
Legality evidence assessment
- Verify supplier identified relevant legislation of the country of production — not just "all laws complied with"
- Confirm concession licence or plantation permit is current and harvest volumes fall within licensed limits
- Verify scientific species name recorded for each product (Article 9(1)(a)) — trade names insufficient; confirm identification methodology (visual, laboratory, or DNA)
- For CITES species: verify export and import permits are valid, match the species and volumes, and are consistent with harvest documentation
- Where a FLEGT licence exists: confirm it is on file, and separately verify deforestation-free status
- Check legality evidence covers all categories under Article 9(1)(e): forestry, land use, environmental protection, labour, tax, and indigenous and community rights including FPIC
Red flags: Trade names only, no scientific species identification. CITES permits expired or volumes mismatched. Concession licence lapsed or harvest exceeds licensed limits. "Industry standard practice" cited as legality evidence.
Processing and traceability verification
- Verify volume conversion documented at each stage (log to sawn, sawn to panel or finished) with yield factors and methodology
- Confirm sawmill intake links each log or batch to the specific harvest compartment and concession
- Check species verification performed at processing — identification confirming species matches harvest documentation
- Verify batch identifiers maintained from harvest through processing and export with traceability links at each transfer
- Confirm no mass balance applied — EUDR requires physical segregation or identity preservation (Article 9)
- For mixed-species consignments: verify each species is individually traceable with separate documentation
Red flags: Reconciliation gaps exceeding 5% without explanation. Species at harvest differs from species at sawmill without explanation (possible substitution). Traceability cannot link processed timber to specific harvest compartments.
Risk assessment and DDS readiness
- Perform your own risk assessment — do not rely solely on the supplier's assessment or a FLEGT licence (Article 10)
- Document your methodology: how you evaluated evidence, thresholds applied, and decision criteria
- Assess origin-specific risks: conflict timber, illegal logging prevalence, governance capacity for each source country
- Where your assessment identifies concerns the supplier did not flag, require additional evidence before filing
- Confirm all DDS fields under Article 4(2) can be populated from the evidence package
- Verify evidence archived for the 5-year retention period (Article 12)
- Confirm end-to-end auditability: competent authority can trace from DDS to individual harvest compartments through each processing stage
Red flags: "Negligible risk" for a high-risk origin without justification. No version control or audit trail. Evidence unavailable in a format you can archive independently.
How to use this template
Step 1 — Request the full evidence package. Specify that evidence must include species identification, harvest-compartment geolocation, and processing traceability — not just a FLEGT licence or certification. Embed requirements in purchase contracts. For timber, verify the supplier has not conflated EUTR compliance with EUDR compliance — the requirements are materially different.
Step 2 — Verify each section. Mark items complete only when independently verified — not when the supplier has confirmed verbally.
Step 3 — Document your verification. Record the date, evidence examined, and your conclusion for each item. This documentation is part of your due diligence and must be retained five years.
Step 4 — Decide before filing. If red flags remain unresolved, do not file the DDS. Filing on weak evidence creates greater legal exposure than delaying.
How to implement this in your organisation
Assign ownership. Your EU compliance officer owns the checklist end-to-end, from receiving the supplier evidence package through to the filing decision. Procurement acts as the first filter, performing a completeness check on each incoming package before forwarding it for substantive review. An internal auditor should review the compliance officer's verification work at least annually to confirm procedures are followed consistently.
Set the review cadence. Run this checklist for every consignment before filing the DDS — per-consignment review is non-negotiable. Conduct a full supplier re-assessment annually, and trigger immediate re-verification whenever a supplier reports changes to their harvest compartments, concession boundaries, or processing chain. Flag any supplier who conflates EUTR compliance with EUDR compliance for immediate re-verification — the requirements are materially different, and prior EUTR processes almost certainly have gaps.
Define your escalation path. Any red flag identified during verification pauses the DDS filing immediately. Procurement holds the next payment milestone until the issue is resolved. If a red flag remains unresolved within 30 days, escalate to the head of compliance or legal counsel. Document every escalation, including the date raised, parties involved, and resolution or outcome.
Connect to existing workflows. Embed the evidence specification directly in purchase contracts so suppliers know what to provide before shipment — including species identification methodology, harvest-compartment geolocation, and processing traceability. Gate customs release on checklist sign-off — no signed-off checklist, no release authorisation. Integrate QC inspection at port with the verification process so that physical species checks and documentation review happen as a coordinated step rather than separate procedures.
Who needs this template
- EU importers placing timber or wood products on the EU market who must verify supplier evidence before filing their DDS
- Compliance officers assessing whether upstream evidence — particularly species identification and harvest-compartment traceability — meets the standard for a defensible filing
- Procurement managers evaluating whether current suppliers provide EUDR-grade evidence (beyond previous EUTR requirements), and whether contracts need amendment
- Internal auditors reviewing verification procedures and the EUTR-to-EUDR transition before competent authority inspections
FAQ
Does a FLEGT licence satisfy my verification obligation?
No. FLEGT covers legality only. You must separately verify deforestation-free status against the December 31, 2020 cutoff. A FLEGT licence supports the legality component but cannot replace geolocation verification, deforestation screening, or DDS filing.
My company was EUTR-compliant — does that satisfy the EUDR?
No. The EUDR adds mandatory geolocation at harvest-compartment level, verification against the December 31, 2020 cutoff, and DDS filing in the EU Information System. EUTR-era evidence almost certainly has gaps that must be closed.
How do I verify the scientific species name my supplier provided?
Request the identification methodology: visual, laboratory (wood anatomy, spectroscopy), or DNA. For high-value and CITES species, visual identification alone carries risk — species substitution is a known fraud vector. Where doubt exists, require independent laboratory verification.
What if the supplier evidence has gaps but the consignment has already shipped?
Do not file the DDS until gaps are resolved. If they cannot be closed, you face a choice: reject the consignment, apply enhanced mitigation with documentation, or accept the exposure of filing on incomplete evidence.
Timber supply chains involve species identification, the selective-logging-versus-deforestation distinction, and the EUTR-to-EUDR transition — each a unique verification challenge for EU importers. A checklist identifies what to check — a platform makes verification systematic. Book a demo to see how ResourceLedger helps EU importers assess supplier evidence against EUDR requirements before every DDS filing.