Legality: from EUTR to EUDR, certification and the UK

Legality rules ask one question: can you show that the wood was legally harvested and, under the EUDR, that it is deforestation-free? This lesson teaches the concepts and the dates confirmed in the portal's articles. Several legal points are unverified, so the lesson tells you where to check official sources.

From EUTR to EUDR

Regulation (EU) No 995/2010 (the EUTR) required operators placing timber on the EU market to carry out legality due diligence. Regulation (EU) 2023/1115 (the EUDR) repeals it and covers wood and derived products such as furniture (European Commission).

The application dates moved several times:

A law-firm summary says a Commission review of 4 May 2026 left the timelines unchanged. A final news check for the weeks before 26 October 2026 could not be run, so re-check the Commission page and the Official Journal before you plan.

Who has which duties?

According to a law-firm summary, the 2025 amendment created downstream operators, who place on the market products made from inputs already covered by a due diligence declaration. They do not file their own declarations, but they keep supplier and customer details (and declaration reference numbers where the supplier is a primary operator) for five years. Non-SME ones must register in the Commission's information system. Medium and large primary operators still complete full due diligence (information, risk assessment, mitigation). Micro and small primary operators may use a simplified declaration.

Where does a sawmill sit? Worked example with three mills (our interpretation, to be confirmed with your competent authority):

• Mill A first places timber on the EU market from its own log purchases: likely a primary operator with full duties.
• Mill B buys from an operator that has already filed a statement: possibly a downstream operator or trader with record-keeping duties.
• Mill C exports to a non-EU buyer: export is within the regulation's wording (Commission page), so ask the authority how it applies.

Whether timber placed on the market before the EUDR applies has a transitional rule is unverified; do not rely on any date for old stock.

Country risk

A law-firm report says the Commission classified countries in May 2025 as high, standard or low risk (low risk: 140 countries including all EU Member States), and low risk allows simplified due diligence. The implementing act was not confirmed.

What data to keep ready

For wood, a third-party copy of the original Article 9 lists the species' common and scientific name, country of production, geolocation of the plots, quantity and supplier details. That copy pre-dates the 2025 simplifications, so check the current text. Species must be identified correctly: spruce and fir, ash and oak, or beech and maple can be confused. Record who identified the species, how and when, and send doubtful lots to a laboratory.

Certification: FSC and PEFC

Chain of custody (CoC) certification covers everyone who handles the wood after the forest. Our interpretation: to sell with a certification claim you need your own CoC certificate, issued by an accredited certification body. PEFC says a certificate is valid for at most five years with annual surveillance audits. Industry sources say FSC and PEFC certificates are indicators of legal and deforestation-free products but do not replace the EUDR due diligence statement. FSC claim types and validity were not verified.

The UK

GOV.UK describes UKTR duties for the first person placing timber on the GB market: gather species, quantity, supplier, country of harvest and legality information, assess the risk and mitigate it to negligible. Traders keep supplier and customer records. Keep a standard data sheet ready for UK buyers.

Russia and Belarus

A consultancy summary (not the Official Journal) reports EU bans on wood from Belarus and Russia covering HS chapter 44, and FSC withdrew certificates in both countries. Check current sanctions text before handling any such origin.

Key points

• EUDR replaces the EUTR; as read on 26 October 2026, large and medium operators apply from 30 December 2026 and other micro and small operators from 30 June 2027.
• Micro and small operators already covered by the EUTR apply from 30 December 2026.
• Downstream operators and traders keep records for five years; role classification of a sawmill must be confirmed with the authority.
• FSC and PEFC claims support but do not replace due diligence.
• Record the species and how it was identified.