As a timber trader who only buys and resells goods without altering them, under the EU Deforestation Regulation (EUDR) you are a trader – and since the December 2025 amendment you file no due diligence statement of your own, regardless of your size. The difference lies in the depth: large traders (non-SMEs) register in TRACES, collect reference numbers, retain them for five years and check them where there is concern; SME traders mainly record the reference numbers and keep them. You only become an operator with a statement of your own when you import yourself.
Your role in the supply chain
The EUDR distinguishes between operators and traders – according to whether you place a product on the market for the first time (operator) or merely pass on goods that are already covered (trader). A timber trader does not alter the goods, so it is a trader. Unlike before the 2025 amendment, even a large trader no longer files a due diligence statement of its own; the difference between large and small now lies only in the depth of the obligations.
A large trading business (non-SME) registers in the EU system TRACES NT, collects its suppliers' reference numbers, passes them on and checks, where there is substantiated concern, whether due diligence was carried out. An SME trader has the fewest obligations: record and keep reference numbers, keep records, without TRACES registration. A statement of your own is only required if you import yourself – then you are an importer and thus an operator with full due diligence.
Your obligations
- Document all supplier and customer data in full – name, address and the statement reference (DDS).
- For every incoming delivery, obtain the reference number of the due diligence statement from the supplier.
- On sale, pass the statement number on to the customer – on the shipping document or the invoice.
- If there is any indication of a risk (for example illegal clearing), immediately inform the competent authority and your customers.
- As a large trader (non-SME), in addition: register in TRACES NT and check, where there is substantiated concern, whether due diligence was carried out.
- Only if you import yourself: full due diligence with geolocation data, risk assessment and your own due diligence statement – then the obligations for importers apply.
- Keep all documents digitally for five years.
Typical process in the trade
- Order with the supplier – the statement reference is automatically requested at the same time.
- Check the intake: enter the statement number in the system, store certificates (FSC, PEFC).
- The risk indicator assesses the delivery based on country and supplier.
- Sale to the customer: the statement number is automatically printed on the delivery note and invoice.
- The customer database records to whom each statement was passed on.
Practical tip: The biggest stumbling block in the trade is a missing statement reference from the supplier. Request the DDS number already when placing the order – not only on goods intake. What to do when a supplier does not deliver is explained under What to do when your supplier does not cooperate?
What the software must do
- Supplier and customer database with statement management
- Automatic risk alert for high-risk countries
- Online portal for suppliers to maintain their own data
- Automatic printing of the statement number on delivery note and invoice
- Integration with ERP and accounting (for example DATEV, Sage)
- Reporting by country, supplier and volume
- Five-year archive with an authority file at the push of a button
Deadlines for timber traders
| 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, as an SME, your turn comes later: some of your suppliers are subject earlier. So start collecting statement references in good time, to keep the chain intact. How to fill in a statement in detail is explained in the article Completing a due diligence statement – step by step.
Important: The roles are not mutually exclusive. For goods you buy within the EU single market you remain a trader; for goods you import yourself from a third country you are simultaneously an operator. The role attaches to the flow of goods, not to the company – your software should be able to handle both in parallel.
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
Must a timber trader file its own due diligence statement?
As long as you only trade goods without altering them, you are a trader and – regardless of size – file no due diligence statement of your own. Large traders (non-SMEs) must, since the 2025 amendment, register in TRACES NT, collect the reference numbers, retain them and check them where there is substantiated concern; SME traders mainly record and keep them. A statement of your own is only required if you import yourself.
Does a small timber trader have to submit its own due diligence statement?
As a rule, no. As an SME trader you do not submit a new due diligence statement; instead you record your supplier's reference number and keep all records for five years.
What happens if a supplier does not provide a statement number?
Then you are missing a mandatory record, and you may not resell the goods. Speak to the supplier early or switch sources – read more under What to do when your supplier does not cooperate?