The EU Deforestation Regulation replaced the EU Timber Regulation (EUTR) effective December 30, 2024. Timber operators who built compliance systems around the EUTR's "negligible risk" standard now face materially different requirements. The EUDR demands both legality and deforestation-free status, adds plot-level geolocation, and requires electronic filing through TRACES NT. Existing EUTR systems do not meet these requirements without significant adaptation.
What is EUDR timber verification?
Under the EUTR, timber operators demonstrated negligible risk of illegal harvesting. The EUDR (Regulation 2023/1115) retains the legality requirement and adds an entirely new dimension: operators must also demonstrate that timber was produced on land not subject to deforestation or forest degradation after December 31, 2020. This dual requirement applies to all timber products placed on or exported from the EU market, classified under the HS codes in Annex I. FLEGT licenses satisfy the legality leg under Article 3 but do not address deforestation-free status. An operator relying on FLEGT alone is not EUDR-compliant.
What this template covers
This checklist walks timber operators through the full verification process, structured to surface the specific gaps between EUTR-era systems and EUDR requirements.
EUTR-to-EUDR gap assessment
- Inventory existing EUTR due diligence documentation; identify which elements carry over and which do not
- Confirm whether current systems capture deforestation-free evidence — if they address legality only, document this gap
- Determine whether supplier records include plot-level geolocation (EUTR did not require this; EUDR does)
- Verify your organization has registered for TRACES NT for electronic DDS filing
- Assess whether FLEGT-licensed shipments are treated as fully compliant — flag as a gap (FLEGT satisfies legality only)
- Review whether your system accounts for the December 31, 2020 deforestation cutoff date
Legality documentation
- For each supplier, obtain the legal basis for harvesting: concession agreement, forest management license, harvest permit, or equivalent authorization
- Confirm harvest volume falls within the annual allowable cut or quota in the concession or management plan
- Obtain the harvest plan or compartment-level documentation showing the specific area was authorized for the period
- For plantation timber, obtain planting records or land title documentation demonstrating establishment before December 31, 2020
- Verify that applicable taxes, royalties, and fees for timber harvesting and trade have been paid in the producing country
- Confirm CITES compliance where applicable — check whether the species is listed and whether export/import permits are in order
- For FLEGT-licensed timber, retain the license and reference number — but document that deforestation-free verification is still required
Deforestation-free evidence
- Obtain satellite imagery covering each harvest area with a baseline anchored to December 31, 2020
- For concession timber, verify the compartment or coupe was forested as of the cutoff and that harvesting occurred under an approved management plan (selective logging under a plan is not deforestation per Article 2)
- For plantation timber, demonstrate the plantation was established before the cutoff — timber from land deforested after 2020 is non-compliant regardless of legality
- Cross-reference harvest coordinates against deforestation alert systems (Global Forest Watch, JRC Tropical Moist Forest) to flag post-cutoff vegetation loss
- For high-risk producing countries under the EUDR benchmarking system, apply enhanced scrutiny including independent deforestation-free verification
Geolocation requirements
- Collect coordinates for each plot where timber was harvested — individual plots, not aggregated concession-level centroids
- For plots exceeding four hectares, provide polygon boundaries rather than a single centroid point
- For concession operations, map specific compartments or coupes harvested, not the entire concession boundary
- Verify coordinates match the actual harvest location using satellite imagery or field verification
- Retain geolocation data in a format compatible with TRACES NT requirements
Species and product identification
- Record the scientific species name as required by Article 9(1)(a) — trade names or common names alone are insufficient
- Classify the product under the correct HS code in EUDR Annex I (e.g., 4403 wood in the rough, 4407 sawn wood, 4410-4411 panels)
- Where products contain multiple species, identify and document each species present
- For processed products, maintain chain-of-custody linking the finished product to source species and harvest location
DDS preparation
- Compile all evidence into a structured due diligence file for each product or consignment
- Complete the risk assessment covering all Article 10(2) factors — use the EUDR Risk Assessment Template for the full evaluation
- Where risk is non-negligible, document mitigation measures taken under Article 11 and evidence that risk was reduced
- Prepare the DDS for electronic submission through TRACES NT with all required fields populated
- Assign a reference number and link the DDS to its underlying evidence package for five-year retention
How to use this template
Step 1: Run the gap assessment first. Determine which EUTR system elements carry forward and where the gaps are. This prevents duplication and focuses effort on new EUDR requirements.
Step 2: Work legality and deforestation-free in parallel. Assign legality to procurement or legal teams and deforestation-free evidence to sustainability or GIS teams. Both must be complete before filing.
Step 3: Validate geolocation independently. Do not accept supplier-provided coordinates at face value. Cross-check against satellite imagery. Inaccurate geolocation invalidates the entire DDS.
Step 4: Assemble and file the DDS. Compile the evidence package, conduct the Article 10 risk assessment, and submit through TRACES NT. Retain the full package for five years.
How to implement this in your organisation
Assign ownership. Your compliance officer or sustainability manager owns this template and is accountable for the EUTR-to-EUDR transition assessment. Procurement and legal teams contribute legality documentation; GIS or sustainability staff handle deforestation-free evidence collection. Refer to the relevant commodity-specific checklist for operational details on species verification and harvest-level traceability.
Set the review cadence. Reassess the gap analysis and verification evidence quarterly and immediately when triggered by a new supplier, a new harvest area, a concession renewal, or a country risk reclassification by the European Commission. Review FLEGT licence status at each consignment to confirm legality coverage remains current.
Define your escalation path. Any gap between existing EUTR-era systems and EUDR requirements halts DDS preparation for the affected consignment until the gap is closed. The responsible team member escalates unresolved gaps to the export manager within 48 hours, documenting the specific EUDR requirement not met and a proposed remediation timeline.
Connect to existing workflows. Integrate deforestation-free verification and geolocation requirements into your existing EUTR due diligence system rather than building a parallel process. Link species verification and compartment-level geolocation to your existing procurement and QC procedures, and store completed verification packages alongside TRACES NT submissions for the mandatory five-year retention period.
Who needs this template
- EU timber importers transitioning from EUTR systems to EUDR requirements
- Tropical timber exporters who must provide plot-level geolocation and deforestation-free evidence to EU buyers
- Compliance officers at wood product manufacturers, paper mills, or furniture companies under EUDR Annex I HS codes
- Forest concession operators who must demonstrate selective harvesting meets the EUDR deforestation-free threshold
Does a FLEGT license mean my timber is EUDR-compliant?
No. Under Article 3, a FLEGT license satisfies the legality requirement. However, the EUDR adds a separate deforestation-free requirement that FLEGT does not address. Operators must still verify timber was produced on land free from deforestation after December 31, 2020, and file a DDS through TRACES NT.
Is selective logging under a forest management plan considered deforestation?
Article 2 defines deforestation as conversion of forest to agricultural use or plantation. Selective harvesting under an approved management plan, where the forest remains forest, is not deforestation. However, operators must demonstrate that no degradation occurred and that the management plan was legally authorized.
What changed for geolocation between EUTR and EUDR?
The EUTR did not require geolocation. The EUDR requires coordinates for every plot where the commodity was produced. For plots over four hectares, polygon boundaries are required rather than single points. This is one of the most significant operational changes, particularly for operators sourcing from concessions with multiple harvest compartments.
Do I need to verify species with scientific names?
Yes. Article 9(1)(a) requires the trade description including scientific species name. Trade names vary by region and can be ambiguous. Scientific nomenclature is the only identification competent authorities can verify unambiguously, especially for tropical hardwoods where one trade name may cover species with different CITES statuses.
The transition from EUTR to EUDR demands that timber operators rebuild their verification systems around a dual standard: legal and deforestation-free, with plot-level geolocation evidence for every consignment. ResourceLedger provides the evidence infrastructure to collect, verify, and retain the documentation this process requires. Book a demo to see how it supports timber supply chain due diligence.