Under the EU Deforestation Regulation (EUDR) you are usually a downstream user or trader: you buy timber and install it in the garden or the landscape. But as soon as you manufacture timber elements yourself and resell them – such as pergolas of your own production or wood chips – you become an operator with your own due diligence statement.
Your role in the supply chain
The EUDR distinguishes between operators and traders or downstream users. Anyone who only buys and installs timber essentially passes on the existing supply chain and documents it. Anyone who manufactures timber elements themselves and sells them places a new product on the market and thereby takes on the obligations of an operator – similar to a joiner. So first clarify which activity applies to your business.
Your obligations
- Collect supplier data and the statement reference (DDS) for every timber delivery.
- When passing on to the end customer (for example a pergola in a private garden): disclose the supply chain.
- When processing timber yourself: a simple due diligence statement, like a joiner, via TRACES NT.
- For each site, document which timbers with which reference were installed.
- Keep all delivery documents for five years.
Typical process on a project
- Timber order for site X via the mobile app.
- Material delivery on site – the delivery note is captured by photo.
- Position and date are automatically stored with the photo (geo tag).
- The project file contains all installed timbers with supplier and statement number.
- On completion, the customer receives a short confirmation of the timber origin.
Practical tip: On site, every minute counts. A mobile app with photo upload saves you the later rework in the office. Make sure suppliers hand you the statement reference directly – if it is missing, read What to do when your supplier does not cooperate?
What the software must do
- Mobile app with photo upload and geo tagging
- Project material list per site
- Supplier management with statement reference
- Offline function for sites without reception
- Simple PDF export for customer handover and the authority
- Five-year archive of all projects
Deadlines for landscaping & gardening
| 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 landscaping businesses are SMEs: for timber products the 30 December 2026 applies, because they were already covered by the old Timber Regulation (EUTR). Anyone who processes timber themselves should follow the process of a joiner. The simplifications the EU has 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 landscaping business affected by the EUDR?
Yes, as soon as timber is involved. Anyone who only buys and installs timber is a downstream user and must document supplier data and statement references. Anyone who manufactures timber elements themselves and resells them is an operator with their own simplified due diligence statement.
Do I have to record the timber origin for every site?
You should document for each project which timbers with which statement reference were installed. That way you can prove the origin if the authority asks and to the customer, and keep records for five years.
Do I need geolocation data for the installed timbers?
The geolocation data of the harvest area is usually recorded by the upstream supplier. You pass on their statement reference. You record your own GPS data mainly when you process timber yourself or want to document the site logistics.