If, as a forest owner, you sell timber directly, then under the EU Deforestation Regulation (EUDR) you are an operator. That means due diligence applies. The effort stays manageable, though: you record your land parcels once with geolocation coordinates and then submit a single simplified declaration (Art. 4a).
Your role in the supply chain
You stand at the start of the chain and place the timber on the market for the first time – that makes you an operator. Importantly: you only become obligated on sale. If you have your forest managed by a forestry service provider who records the timber for you, you benefit from their geolocation data. But the statement itself is submitted by you, the selling forest owner.
Your obligations
- Record your land parcels once in the software – with geolocation coordinates.
- Archive forestry permits.
- Submit a due diligence statement per sale or per year via TRACES NT.
- Pass the statement number on to the buyer (sawmill, timber trade).
- Keep all records digitally for five years.
Typical process
- One-off: import land parcels from the forestry cadastre.
- After each felling: record species, quantity and harvest date.
- Once: submit the simplified declaration under Art. 4a and receive an identification number.
- The statement is sent to the authority automatically.
- The statement number automatically lands on the delivery note for the buyer.
Practical tip: The one-off simplified declaration is your biggest lever. Instead of reporting every delivery or every year, you submit it once and update it only on material changes. Have your land parcels imported cleanly from the cadastre once – after that the effort is minimal. How to fill in the statement is shown in Completing a due diligence statement – step by step.
What the software must do
- GIS map with land parcel integration
- Templates for German forestry law documents
- Simplified declaration (Art. 4a) with TRACES NT integration
- Simple operation – also for family businesses
- Five-year archive with an authority file as a PDF
Deadlines for forest owners
| Business size | Obligation from |
|---|---|
| Larger businesses | 30 December 2026 |
| Small and medium-sized enterprises (SMEs) | 30 December 2026* |
* Important for the timber sector: Under Art. 38(3) the extended deadline of 30 June 2027 – only for natural persons, micro and small undertakings established as such on 31 December 2024 – only applies to products that were not already covered by the old Timber Regulation (EUTR). Roundwood, sawn timber, panels and furniture were covered by the EUTR – for these the 30 December 2026 applies regardless of company size.
Even though most private and smaller forest owners are SMEs: for timber the 30 December 2026 applies, because timber was already covered by the old Timber Regulation (EUTR). Set up your land parcels in good time so that the single simplified declaration (Art. 4a) runs without time pressure. The simplifications the EU recently adopted are explained under EU simplifications to the EUDR.
Submission via an authorised representative
You do not have to submit the statement yourself. Under Art. 6, natural persons and micro-enterprises may appoint an authorised representative to submit on their behalf – typically the next buyer, such as the sawmill or trader you already work with.
For the representative the effort stays manageable: they can submit for many principals from a single account. Responsibility for the accuracy of the information remains with you; only the technical handling is delegated.
Frequently asked questions
Is a forest owner an operator?
A forest owner who sells timber themselves is an operator and must submit a due diligence statement. Anyone who has the forest managed only through a service provider and does not place timber on the market themselves usually is not.
Do I as a forest owner have to submit a statement every year?
No. Micro and small primary producers – small operators established in a low-risk country, EU member states included (Art. 2(15a)) – have since the 2025 amendment submitted only one simplified declaration (Art. 4a) and receive an identification number for it. It is updated only on material changes – not per sale and not annually.
What data do I need as a forest owner?
Your land parcels with geolocation coordinates, the forestry permits, and per felling the species, quantity and harvest date. You record the land parcels once, after that you only maintain the individual fellings.