Under the EU Deforestation Regulation (EUDR), forestry service providers are usually not operators, because you fell the timber on behalf of others and do not place it on the market yourself. But without your data the due diligence of the forest owner or sawmill does not work: you record the geolocation data of the felling site and the matching permit.
Your role in the supply chain
You stand right at the start of the chain – at the physical place where the timber originates. Even though you do not have to submit a due diligence statement yourself, you are the only party that can document the exact GPS position of the felling and the associated permit. Anyone who works cleanly here makes the statement much easier for the forest owner and the sawmill – and becomes the preferred partner.
Your obligations
- Correct felling and permit documentation – the permit must match the felling.
- Record the GPS position of the felling site, as a point or polygon.
- Hand the data over to the client (forest owner or sawmill).
- Provide information at the authority's request and grant access to the felling site.
- Archive records and recorded data reliably.
Typical process in the forest
- Order from the forest owner – the felling permit is in place.
- On site with the mobile app: record the GPS position, take a photo of the felling.
- Upload the forestry permit as a photo, enter species and quantity.
- Completion: the data is automatically sent to the client.
- If the authority queries it: all data is retrievable from the archive.
Practical tip: Record the GPS position directly at the felling, not later from memory. An offline-capable app stores the data even without reception and transmits it as soon as there is signal again. Whether a point or polygon is needed is explained in Geolocation data: point or polygon?
What the software must do
- Mobile app with GPS tracking
- Offline function for forest areas without reception
- Photo upload with automatic geo tag
- Hand the data over to the sawmill or forest owner with one click
- Integration with the forestry cadastre (BayernAtlas and the like)
Deadlines for forestry service providers
| 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 if you do not submit a statement yourself: your clients are bound by these deadlines and will expect the geolocation data from you. Anyone who introduces clean field data collection early becomes a sought-after partner. How the statement comes together at the client is shown in EUDR for forest owners.
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 forestry service provider an operator?
Usually not. Forestry service providers fell timber on behalf of the forest owner and do not place the timber on the market themselves. However, they are the most important data source: anyone who records the geolocation data and permits cleanly makes the statement much easier for the forest owner and the sawmill.
What data must a forestry service provider record?
The GPS position of the felling site as a point or polygon, the matching felling permit, plus species and quantity. This data is handed over to the client – the forest owner or sawmill.
Is a GPS point enough or do I need a polygon?
For areas over four hectares a polygon is required; below that a GPS point with at least six decimal places is sufficient. A mobile app with GPS tracking records both directly in the forest.