As a sawmill, under the EU Deforestation Regulation (EUDR) you are usually a downstream operator: your raw timber was already placed on the EU market by the forest owner or importer with a due diligence statement. Since the December 2025 EUDR amendment you then no longer file your own due diligence statement – but you must collect your suppliers' reference numbers, check them, pass them on to your customers and archive them for five years. Only if you import roundwood yourself from a non-EU country does full due diligence with your own statement fall to you as the operator placing it on the market for the first time.
Your role in the supply chain
What matters is who places a product on the EU market for the first time – only that first placer files the due diligence statement. For local roundwood that is the forest owner, and your sawmill sits downstream. The EUDR originally required processing businesses to file their own statements too; the December 2025 amendment removed that (new downstream-operator role, Art. 2(15b) and Art. 5). What still applies: as a non-SME you must satisfy yourself that your suppliers have actually met their due diligence obligations, and the origin must remain traceable across every processing step.
Your obligations
As a rule – timber that has already been placed on the EU market:
- Record the reference numbers of your suppliers' due diligence statements and check them for plausibility.
- Track the batch throughout the mill – even after processing, its link to the incoming reference must remain traceable.
- Pass the reference numbers on to your customers at the point of sale.
- Archive all records digitally for five years.
- Act on substantiated concerns – such as indications of deforestation – and report them to the authority.
Fewer forms does not mean less responsibility: The penalties – up to 4% of EU-wide annual turnover, plus confiscation of the goods – apply to every obligation, not just the statement. If your supplier's reference number is missing or does not match the batch, the goods may not be sold. Your supplier's gap then becomes a standstill at your mill – which is why it matters that references arrive in full, are checked, and stay assignable across every processing step.
When importing directly from non-EU countries, additionally:
- Record supplier data: name, country, species (with scientific name), quantity and the geolocation coordinates of the harvest area.
- Assess every origin for risk (country, region, supplier) – obtain additional evidence for standard or high risk.
- Submit your own due diligence statement per batch or as a combined statement via the EU system TRACES NT.
Typical process at the mill
- The lorry with raw timber arrives at the mill – the delivery documents are scanned.
- In the intake form, the geolocation coordinates, forestry permit, species, quantity and batch are recorded.
- The risk indicator shows green, amber or red. For amber or red, the four-eyes approval applies.
- For EU timber, the supplier's reference is imported and checked; for direct imports, your own due diligence statement is created and submitted automatically.
- The batch is tracked through the mill: oak log 2026-1182 → planks 2026-1182-A.
- On sale, the statement reference is attached to the delivery note.
Practical tip: A combined statement bundles several similar deliveries from the same supplier – often as an annual report. This reduces the effort considerably if you buy regularly from the same sources.
What the software must do
- Record, check and pass on suppliers' reference numbers at the point of sale
- Goods intake form with species, batch, geolocation data and permit
- Automatic risk indicator based on the EU country list
- Automatic due diligence statement with TRACES NT integration
- Batch tracking throughout processing
- Integration with your existing ERP system
- Five-year archive with an authority file at the push of a button
Deadlines for sawmills
| 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.
We recommend starting well before the deadline. That way your suppliers are connected in good time and your first statements run without time pressure. Read more in the article EUDR for sawmills – the complete guide.
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
Must a sawmill file its own due diligence statement?
Usually no longer. If your mill buys timber that has already been placed on the EU market – for example roundwood from a local forest owner – you have, since the December 2025 EUDR amendment, been a downstream operator: you collect, check and retain the reference numbers of your suppliers' statements. Only when importing directly from non-EU countries do you file your own due diligence statement.
What happens if a supplier does not provide geolocation data?
Then the timber may not be placed on the market. Either you help the supplier with the data collection or you switch sources. How to deal with this is explained under What to do when your supplier does not cooperate?