The EUDR – Regulation (EU) 2023/1115 of 31 May 2023 – moves into practice in 2026. For sawmills that means little time is left until geolocation data, risk assessment and submission via TRACES NT have to run smoothly. This article focuses on what's current – the deadline, the typical mistakes and a fast way in.
Full sector guide for sawmills: A continuously maintained, step-by-step account of all obligations – from onboarding suppliers to archiving – is on the sector page EUDR for Sawmills. This blog post complements it with the current 2026 view.
What changes in 2026
The EUDR applies in stages by company size. Two dates matter – plus a cut-off date that applies regardless of size:
| Large companies | from 30 December 2026 |
|---|---|
| Small & medium-sized enterprises (SMEs) | from 30 December 2026 (timber) |
| Deforestation-free cut-off date | not cleared after 31 December 2020 |
For large sawmills it gets serious at the end of 2026: from 30 December 2026 they must submit a due diligence statement via TRACES NT before placing timber on the market. The extended deadline of 30 June 2027 – only for natural persons, micro and small undertakings established as such on 31 December 2024 – does not help sawmills: under Art. 38(3) it only applies to products not already covered by the old Timber Regulation (EUTR), and roundwood and sawn timber were covered. The deforestation-free cut-off stays fixed: the timber must not come from land cleared after 31 December 2020. Anyone who only starts building clean supplier data in 2026 runs into time pressure – the real work sits exactly here and takes months.
The most common mistakes sawmills make
In practice the same stumbling blocks recur. These seven points most often lead to incomplete or invalid statements:
- Batch without a plot reference: Timber from several sources mixed together without documenting each plot of production individually. A blanket entry for the whole batch is not enough.
- Geolocation data too imprecise: Fewer than six decimal places, or a GPS point instead of a polygon for plots over four hectares.
- Underestimating domestic timber: The EUDR also covers exclusively German timber. The country of origin lowers the risk but does not exempt you from the obligation to submit a statement.
- Mistaking a certificate for a substitute: FSC/PEFC only lower the risk; they do not replace the due diligence obligation or the statement.
- Not passing on reference numbers: The reference and verification number received in TRACES NT must be passed on to customers – ideally on the delivery note and invoice.
- Not keeping records: Geolocation data, risk assessment and correspondence must be archived digitally for five years and produced on request to the BLE.
- Starting too late: Building up supplier data takes months – don't wait until just before the cut-off.
Quick-start checklist
If you're starting now, get these points in order first:
- Own role clarified (usually an operator) and the relevant deadline determined (2026 or 2027)
- All suppliers recorded and informed of the data needed
- Geolocation data requested per plot of production (point or polygon, six decimal places)
- Risk assessed per consignment, goal: negligible risk
- Trial statement prepared in TRACES NT, reference-number hand-off clarified
- Storage set up for the five-year archiving requirement
The complete workflow with all obligations is described on the sector page EUDR for Sawmills; the overall overview is in the EUDR guide. The article Completing the due diligence statement correctly shows exactly how the form is filled in.