As an importer, under the EU Deforestation Regulation (EUDR) you are a full operator: you place the timber on the EU market for the first time and therefore carry the highest density of obligations. You must collect geolocation data, assess the risk and submit a due diligence statement via TRACES NT before every customs declaration.
Your role in the supply chain
Importers stand at the entrance to the EU supply chain. Unlike a downstream trader, you cannot rely on a statement that already exists – you are the one who fulfils due diligence for the first time. This covers data collection, risk assessment and – if necessary – risk mitigation, until a negligible risk is reached. Especially for high-risk countries, documentation alone is not enough; active measures are required here.
Your obligations
- Obtain detailed supplier data from the country of production.
- Record the geolocation coordinates of the harvest area – ideally as a polygon (mandatory from four hectares).
- Collect legality evidence: forestry permits under local law, FSC/PEFC as well as FLEGT licences.
- Risk assessment and, where applicable, risk mitigation (additional audits, alternative suppliers).
- Due diligence statement before every customs declaration via TRACES NT.
- Keep all documents digitally for five years, retrievable for the authority at any time.
Typical process for imports
- The supplier in the third country is contacted via the multilingual online portal.
- The supplier uploads geolocation coordinates, permits and certificates.
- A satellite analysis automatically checks the stated areas for deforestation.
- On a red risk signal: take an additional measure or switch supplier.
- The due diligence statement is submitted before the customs declaration.
- Customs clearance with the statement reference – the goods can be released.
Practical tip: The most common bottleneck on import is missing or imprecise geolocation data from the country of production. Clarify early whether a point is sufficient or a polygon is needed – the details are explained under Geolocation data: point or polygon? Certificates do not replace the obligation, but they help with the risk assessment: Certificates: FSC, PEFC and FLEGT.
What the software must do
- Multilingual supplier portal (DE / EN / FR / ES and more)
- Satellite analysis for harvest areas
- Geo-polygon validation
- Multiple tenants for several sites and entities
- Integration with customs software
- Optional: handling the supplier outreach for you
Deadlines for importers
| 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.
For imports in particular it pays to start early: suppliers in third countries need time to provide geolocation data and permits. Connect your most important sources well before the deadline. The latest simplifications the EU has adopted are explained under EU simplifications to the EUDR.
How deep the checks go depends on the country of production
Since the amendment, the effort required follows the risk classification of the country of production (the EU country benchmarking):
- Low risk – 141 countries, including most trading partners: simplified due diligence under Art. 13. You collect the information and submit the statement – risk assessment and risk mitigation fall away.
- Standard risk: full due diligence with risk assessment and, where necessary, mitigation until negligible risk is reached.
- High risk – currently only Belarus, Myanmar, North Korea and Russia: full due diligence plus enhanced scrutiny (9 % control rate instead of 1 % for low risk).
You will find the classification in the country benchmarking. Check it per country of production – not per supplier.
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
What obligations does an importer have under the EUDR?
Anyone who imports timber from countries outside the EU carries full due diligence: data collection with geolocation coordinates, legality evidence, risk assessment, where applicable risk mitigation, and a due diligence statement before every customs declaration.
Do I need a polygon rather than a GPS point for imports?
For harvest areas over four hectares a polygon is required; below that a GPS point with at least six decimal places is sufficient. For imports from high-risk countries a polygon is often advisable anyway, so the area can be checked by satellite.
What to do when a supplier in a third country does not provide data?
Without complete data you may not place the goods on the market. Support the supplier via the portal or switch to an alternative – read more under What to do when your supplier does not cooperate?