EUDR questions and answers for businesses
Company roles, due diligence statements and practical supply chain records
Your EU Deforestation Regulation (EUDR) obligations depend on the product you handle, your activity and your position in the supply chain. A company importing a relevant product for the first time has different responsibilities from a sawmill processing timber that has already undergone upstream due diligence. Start by checking the product’s customs classification, then identify your role for each transaction.
This Q&A brings together recurring questions from timber processors, traders, packaging businesses and food manufacturers.
To read the answer, click on the question
1
Application dates and company size
When do EUDR obligations apply?
The main application date is 30 December 2026 for large and medium-sized operators and for micro and small operators dealing with products already covered by the EU Timber Regulation. Other micro and small operators generally have until 30 June 2027. In particular, micro and small suppliers of roundwood under CN 4403 do not automatically benefit from the later date. Newly added products under Delegated Regulation (EU) 2026/2102 have a separate application date of 30 December 2027. Confirm the date for your product and activity rather than using company size alone. [1]
How do we determine whether our company is an SME?
EUDR uses the Accounting Directive’s undertaking categories. An SME includes micro, small and medium-sized undertakings; non-SME means a large undertaking. The small-undertaking thresholds discussed in the webinar are €5 million balance sheet total, €10 million net turnover and 50 employees. The upper medium-sized thresholds are €25 million, €50 million and 250 employees. Classification uses at least two of the three criteria, with rules for changes over two consecutive financial years. Check the applicable national implementation and your accounting classification before relying on a category. [4]
Does exceeding 50 employees automatically make us medium-sized?
No. For example, a company with 60 employees, €8 million turnover and a €2.1 million balance sheet total meets two small-undertaking thresholds, despite exceeding the employee threshold. Likewise, €8.4 million turnover and 77 employees do not settle the classification without the balance sheet figure. Being small also does not automatically establish a June 2027 application date: the product and the EUTR exception still matter.
2
Identifying your role
Can one company have several EUDR roles?
Yes. Assess each product flow separately. A business may be an upstream operator when importing plywood from outside the EU, a trader when reselling timber already placed on the EU market without changing its relevant customs classification, and a downstream operator when making another relevant product from inputs already subject to upstream due diligence. Processing alone does not settle the role: check the activity, the Annex I classification and the status of every relevant input. [2]
Is a sawmill a downstream operator?
Normally, yes, where it buys roundwood already covered by an upstream DDS or SD and manufactures another Annex I product, such as sawn timber. If it buys directly from the upstream operator, it is the first downstream operator. This conclusion depends on all relevant inputs having the required upstream status; it does not apply automatically to timber with unknown origin or missing required coverage.
What is the difference between a trader and a downstream operator?
A reseller of relevant products already placed on the EU market will generally be a trader where the relevant Annex I CN/HS classification remains unchanged. A processor manufacturing another relevant product from covered inputs will generally be a downstream operator. Both have supply chain information obligations. A reseller purchasing directly from an upstream operator is the first trader and must retain the upstream reference or identifier.
How do we know whether we are the first downstream buyer?
Look at the role of your direct supplier for the specific delivery. If it is an upstream operator or MSPO, you are the first downstream buyer for that flow. If it is already a trader or downstream operator, you are further downstream. A supplier may have different roles across deliveries, so obtain clear transaction-specific information and record how you reached your conclusion. A general statement about the supplier’s business is insufficient if the transaction facts point to a different role.
Do delivery terms such as CIF determine the operator?
Delivery terms alone do not determine EUDR responsibility. For an ordinary first import, identify who releases the relevant product for free circulation, who is identified in the customs arrangements and who subsequently makes it available in the EU. Review contracts and customs documents together. EORI registration alone also does not transfer responsibility from one party to another.
Who is responsible in a packaging or assembled kit supply chain?
First establish whether the packaging, individual components and finished kit fall within Annex I under their correct CN codes. Then identify the party first placing relevant materials on the EU market, including imports. Ordering a custom design or assigning a new article number does not by itself determine the EUDR role. Where a manufacturer makes a relevant product solely from already covered relevant inputs, the downstream rules may apply. In the webinar, a medium-sized business buying finished corrugated packaging from an EU manufacturer and reselling it was identified as a trader further downstream, assuming the manufacturer’s relevant inputs had already undergone upstream due diligence. It keeps supplier and customer records but does not submit a DDS or register solely for this downstream activity. A business itself importing relevant kit components from outside the EU normally has upstream obligations for those imports. A new product name or kit number does not automatically require another DDS after all relevant inputs have been covered upstream.
3
DDS references and downstream obligations
Must a sawmill submit a new DDS for its finished products?
A sawmill acting as a downstream operator does not submit a new DDS simply because it turns already covered roundwood into another relevant product. This applies to SME and non-SME downstream operators. Retaining upstream references is an information obligation; it is not a requirement to create a replacement statement for every finished batch.
Which information must downstream businesses keep?
Keep the required identification and contact information for suppliers and business customers for at least five years and make it available to competent authorities on request. Where the direct supplier is an upstream operator or MSPO, also collect and retain its DDS reference number or SD identifier. Maintain records that allow the business to connect that information to the relevant incoming deliveries. [3]
Must DDS numbers be passed to every customer?
No. The first downstream operator or trader must collect and retain the reference or identifier received from its upstream supplier, but does not have to pass it indefinitely along the supply chain. References may be shared voluntarily or by commercial agreement. Later buyers still need to record their direct supplier and business customers.
Must an EUDR statement appear on invoices or delivery notes?
For ordinary transactions within the EU, EUDR does not require a DDS number, geolocation information or a prescribed EUDR statement on invoices, packing lists, delivery notes or CMR documents. Businesses may add information voluntarily. This does not remove recordkeeping obligations or any separate customs requirements.
What additional obligations apply to non-SME downstream businesses?
Non-SME downstream businesses must register in the EUDR Information System and perform additional verification where a substantiated concern arises. In that situation, a non-SME downstream business must verify that upstream due diligence was exercised and that no or only negligible risk was identified before continuing with the affected product. It does not normally repeat every supplier’s due diligence systematically. Both SME and non-SME businesses must notify the competent authority and affected downstream businesses when relevant new information indicates possible non-compliance.
What if a supplier cannot provide a required reference?
First establish whether a reference is legally required for that delivery. A further-downstream supplier may have no obligation to pass one on; qualifying transitional material needs different evidence. However, where your direct supplier is an upstream operator subject to the requirements, missing required DDS or SD information cannot be solved by treating the supplier as downstream or mixing its material with covered inputs. Investigate the status and resolve the gap before proceeding.
4
Traceability and timber production
Must every finished board be traced to one forest plot?
A first downstream sawmill does not normally need a one-to-one physical link between each board and its original forest plot. It should retain supplier information and the required upstream references, connect them to incoming deliveries, and account for the material through normal stock and production records. This downstream position does not remove an upstream operator’s obligations concerning production origin.
Can roundwood from several suppliers be mixed?
Mixing already covered material is not automatically prohibited. Retain the upstream references and records of the incoming deliveries used in the relevant stock or production flow. Unknown or non-compliant material cannot be legitimised by mixing it with DDS-covered wood. Where different regulatory categories coexist, your records should distinguish them reliably; separate batches may help where accounting alone cannot establish their status.
What records might an inspector request from a sawmill?
Useful inspection records include supplier details; purchase and transport documents; DDS references or SD identifiers; records connecting those references to incoming timber; stock and production accounting; and customer and sales information. A non-SME sawmill should also be able to demonstrate Information System registration. Where inconsistencies or substantiated concerns arise, an authority may request further evidence or inspect the site.
Are chips, sawdust and other residues outside EUDR?
Not automatically. Assess each output under its own CN classification and Annex I entry. Chips, particles, sawdust and certain wood waste or scrap may be included under ex 4401. Where a relevant output is made from already covered roundwood, the sawmill generally has downstream obligations rather than a new DDS obligation. A commercial description such as residue or by-product is not proof of a waste exemption. Check the legal waste criteria and any specific Annex I exclusion.
Is a clear-cut area automatically non-compliant?
No. A temporarily unstocked area expected to regenerate through normal forest management can remain forest. Assess deforestation and forest degradation after 31 December 2020, alongside legality. EUDR forest degradation includes conversion of primary or naturally regenerating forests into plantation forests or other wooded land, and conversion of primary forests into planted forests. Evidence may include forest management plans, harvesting permits, forest records, regeneration obligations and imagery. Geolocation alone does not prove compliance. [4]
5
Transitional stock and cross border trade
Does buying a forest before the deadline exempt later harvests?
No. The date on which the forest was purchased does not create a transitional exemption for future timber. For wood, the harvest date is the production date. A business harvesting and first placing timber on the EU market or exporting it after the applicable date must meet the upstream requirements, unless an applicable simplification changes the reporting route. Timber transition arrangements need assessment of production and first-placing dates and the specific legal provisions; do not rely on the forest purchase contract alone.
What evidence supports transitional stock status?
Keep evidence of the relevant dates and the link to the material used in the finished product. Depending on the flow, this may include supplier confirmations, invoices, lot numbers, transport records, customs declarations and production traceability. No single prescribed document was identified in the webinar or written follow-up. A supplier statement unsupported by identifiable deliveries or batches may be inadequate. Material sourced after the applicable date must meet its applicable EUDR obligations even if it is mixed with older stock.
Must transitional and DDS covered timber be physically separated?
EUDR does not generally require physical separation solely because timber has these different statuses. Records must distinguish the quantities and substantiate the claimed status. Where that cannot be demonstrated reliably, separate batches or physical segregation provide a clearer evidential basis. This should not be read as permission to include unknown or non-compliant timber.
Is delivery from Latvia to Finland an export?
No. For these purposes, export means leaving the EU customs territory. Supplying pallets from Latvia to Finland is an intra-EU transaction. If the pallets are relevant products made from already covered inputs, apply the appropriate downstream obligations, including retaining references where you buy directly from upstream operators.
Must a downstream exporter create another DDS?
The downstream rules mean a downstream operator exporting a relevant product made from inputs already covered upstream does not submit a new DDS or a DDS referring to the received numbers. The downstream export exemption from providing a DDS reference to customs does not remove other customs formalities or traceability obligations. The speaker explicitly left the selection of customs codes such as C718 and Y196 to customs specialists. Confirm current declaration codes with your customs representative for the particular procedure.
What happens when EU cocoa is processed abroad and chocolate is reimported?
The EU re-importer may qualify as a downstream operator where it can demonstrate that all relevant cocoa inputs were previously placed on the EU market. Keep the chain of evidence from cocoa lots through export, manufacture and chocolate re-import. For covered inputs, current Commission guidance provides for supplier reference numbers in the customs declaration, or the conventional re-import number 22EU2222222222 where no references were provided. Transitional inputs require a separate assessment and proof of their earlier status; do not interchange transitional and ordinary re-import references. [2]
6
Forest owners and simplified procedures
Does buying standing timber give us the same role as buying logs?
No. The webinar distinguished a purchase of standing trees or harvesting rights from a purchase of already harvested logs. Where your company buys harvesting rights, harvests the timber and first places the relevant wood product on the market, it will normally have upstream operator obligations. Where you buy logs already placed on the market by the forest owner, you normally act as a first downstream operator or trader. Review the actual contract, harvesting and first-placing arrangements before allocating responsibility; owning a harvesting permit alone does not settle the role.
What if our timber supplier is a private individual?
A natural person can have EUDR obligations. Where a forest owner produces and first supplies their own logs, assess whether they qualify as an MSPO: this involves primary production in the low-risk country where they are established, not merely being a private individual. Qualifying MSPOs use a one-off SD, updated when important information changes, rather than a DDS for each supply. They provide the SD identifier to their first downstream buyer. An SD is not automatically an annual declaration, and small size alone does not remove obligations. [2]
Can we submit a declaration for a forest owner?
An upstream operator can appoint an EU-established authorised representative to submit a DDS or SD on their behalf. This requires a formal mandate and the appropriate registration in the Information System; the operator retains responsibility. Helping a supplier gather documents does not itself make you their authorised representative or remove their declaration obligation. Do not treat your own due diligence exercise as an automatic replacement for a supplier’s required SD or DDS. This clarifies the practical options discussed during the webinar. [2]
Is simplified due diligence the same as a simplified declaration?
No. Simplified due diligence under Article 13 is a procedure available where its low-risk sourcing conditions are met. It retains the information-gathering obligation and requires assessment of relevant supply chain complexity and risks of circumvention or mixing; it is not a blanket exemption based on a supplier’s address. An SD is a separate reporting route for qualifying MSPOs. An operator using simplified due diligence still submits a DDS unless a separate reporting simplification applies. Assess the production origins and the full supply chain rather than classifying a whole shipment only by the country from which it was dispatched. [4]
7
Imports and practical preparation
Can a non EU supplier submit a DDS instead of the EU importer?
Where the EU company releases the product for free circulation, it normally acts as the upstream operator and must fulfil its own DDS obligation. The non-EU supplier can provide supporting origin and legality data. Where the non-EU company itself releases the product for free circulation, Article 7 can result in that non-EU operator and the first EU-established business making the product available both being operators. Each operator submits its own DDS; using the same underlying data does not merge their responsibilities.
Does a tax or customs representative become the operator?
Not automatically. A representative is not automatically an EU subsidiary either. An EU-established person may separately be appointed as an EUDR authorised representative with a written mandate to submit a statement on the operator’s behalf. Responsibility remains with the operator. The precise importer arrangement should be reviewed against the customs and commercial facts.
Do goods merely transiting the EU need an import DDS?
Distinguish release for free circulation from customs warehousing, inward processing, temporary admission and transit. If goods remain under such procedures and are subsequently re-exported without release for free circulation in the EU, no EU import DDS is required for that flow. Confirm the actual procedure and any later change in customs status.
How should aggregated or salvage cocoa be assessed?
The spreadsheet asks how to trace cocoa collected from many sources, but its written answer addresses service support rather than the tracing method. It does not establish an exemption for salvage beans. Before import, establish whether the goods are relevant products and whether the operator can obtain the required origin, legality and due diligence evidence for the constituent material. Do not assume that aggregation or a salvage description removes those obligations. This scenario requires a specific technical assessment.
How BM Certification can support you?
Contact BM Certification about EUDR training, supplier audits and independent assessments of due diligence documentation or systems within our service scope. Relevant Chain of Custody certification may provide complementary evidence for risk assessment. BM Certification does not provide EUDR implementation consultancy or design clients’ due diligence systems. Certification or independent verification does not replace the business’s legal responsibility for compliance.
For enquiries, contact [email protected] or your local BM Certification office.
What your business can do now
- Check each product’s CN classification and Annex I scope, including recent scope changes.
- Map each material flow and identify your role, direct supplier’s role and application date.
- Confirm the required DDS or SD information and organise supplier, customer and delivery records.
- Check whether transitional stock claims are supported by dates and batch evidence.
- Set a process for missing information and possible non-compliance, and resolve customs questions with your representative.
———
Note:
- DDS means due diligence statement
- SD means simplified declaration
- MSPO means micro or small primary operator.
- Source numbers refer to the links at the end.
These answers provide general information based on the limited details shared by webinar participants. They are conditional on the circumstances described and may differ depending on your products, supply chain and business activities. They do not constitute legal advice or a company-specific compliance assessment. Please check the current EUDR requirements and official guidance before applying an answer to your business.
Official sources
[1] European Commission — Regulation on Deforestation-free products. Application dates and recent product scope changes. https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en
[2] European Commission — Understand roles and responsibilities under the EUDR. Used for role definitions and the current re-import reference. https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/roles-and-responsibilities_en
[3] European Commission — EUDR Information System API FAQ. Supplier and buyer information and five-year retention. https://acceptance.eudr.webcloud.ec.europa.eu/tracesnt/help/eudr-documentation/operator/faq.html
[4] Regulation (EU) 2023/1115, consolidated 18 September 2026. Read with Directive 2013/34/EU for company-size classification. https://eur-lex.europa.eu/eli/reg/2023/1115/2026-09-18/eng/pdf
Further reference — European Commission FAQ on EUDR Implementation. https://environment.ec.europa.eu/publications/faq-eudr-implementation_en
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