EUDR for timber: the special case of a long traceability chain

Timber is one of the seven commodities covered by the EUDR, but its value chain stands apart from the other six because of its length: between the felled tree and the piece of furniture sold in a shop, a wood product often goes through four to six processing stages (log, sawing, drying, panel or machined part, assembly), each potentially carried out by a different company. This guide covers what that length changes in practice for compliance.

The declaration is not redone at each link, but it is passed on

The principle remains the one already covered in our guide on the due diligence statement, and Regulation (EU) 2025/2650 of 19 December 2025 made it clearer still: since that date, a downstream operator no longer files a statement at all — it collects and keeps the reference number of the primary operator's statement, and reports it in its customs declaration. For timber, this means in practice:

• The sawmill that buys logs from a forest operator is, in most set-ups, the primary operator: it files the first statement, referencing the felling plots.
• The manufacturer of panels or machined parts that buys sawn timber references the sawmill's statement, as long as its supply does not mix several origins within the same production batch.
• The furniture manufacturer, the last link before final placing on the market, must be able to trace the complete chain back to the forest origin — which assumes that each intermediate link has correctly kept and passed on its reference.

A date not to have applied to you by mistake. The additional period until 30 June 2027 granted to micro and small enterprises applies outside the timber sector. A small sawmill, a forest operator or a timber trader therefore falls under the general deadline of 30 December 2026, whatever its size. It is one of the few exclusions written into the text by name, and it targets exactly the readership of this guide.

The most frequent breaking point: mixing at the sawmill

A sawmill that processes logs from several forest operators on the same production day often produces sawn timber that mixes several origins without physically distinguishing them. This is the most frequent moment at which EUDR traceability is lost in a timber chain: once the logs have been sawn together, it becomes impossible to separate afterwards which plank came from which plot. Two workable responses:

• Separate sawing batches by origin, even at the cost of a more constraining production organisation — the only method that preserves individual traceability by plot.
• Document the mix as such, with the complete list of plots of origin that contributed to the mixed batch — the statement then covers all the plots, not just one, which remains compliant as long as each one is individually documented.

Composite products: furniture, plywood panels, paper

A piece of furniture assembling several species, or a plywood panel combining several plies of different origins, cannot be covered by a single aggregated statement that would hide the components. The final manufacturer must keep, for each finished-product reference, the list of statements for each of its wood components — a document-aggregation task that comes on top of the manufacturing itself.

Recycled wood and products already in circulation

Recycled or reused wood — reconditioned pallets, reintegrated production offcuts — receives distinct treatment: once it has already been placed on the European market a first time in compliance, its reintegration into a new product does not generally require a new due diligence statement linked to the forest plot of origin. The documentation of its first placing on the market nonetheless remains the document to keep.

Common mistakes

• Not requiring the statement reference from your upstream supplier — a furniture manufacturer who has never asked its sawmill for this reference discovers the traceability gap at the time of an inspection, not before.
• Mixing sawing batches without documenting the combined origins, thereby losing individual traceability without even realising it at the time of production.
• Treating a composite product as a single origin when it combines several species or batches from distinct plots.

Checklist

1. Require the statement reference from each timber supplier, at every stage of the chain.
2. Explicitly document any mixing of batches in production, with the complete list of origins.
3. For a composite product, aggregate the statements for each component, never a single overall statement.
4. Keep the first-placing-on-the-market documentation for reintegrated recycled wood.