EUDR vs EUTR: what actually changed for timber
The EUDR replaces the EU Timber Regulation, and if you built a due-diligence system for the EUTR you are further ahead than most. But the two regimes differ in five ways that matter, and the biggest one, geolocation, is not something an EUTR system was ever designed to hold.
Updated 31 July 2026, 3 min read
The short version
The EUTR asked: is this timber legal? The EUDR asks: is this timber legal, and can you point to the specific piece of land it came from, and was that land forest on 31 December 2020? The legality question you have already answered. The other two are new work.
| EUTR (995/2010) | EUDR (2023/1115) | |
|---|---|---|
| Core test | Legality only, harvested in accordance with the law of the country of harvest. | Legality plus deforestation-free plus a filed statement. |
| Traceability | Country, and sub-national region or concession where applicable. | Plot-level geolocation: coordinates to six decimals, polygons above four hectares. |
| Cutoff date | None. | 31 December 2020. Land converted after it is permanently disqualified. |
| Scope | Timber and certain timber products. | Wood plus six other commodities, and a wider derived-product list, pulp, paper, printed matter, furniture, prefabricated buildings. |
| Exports | Not covered. | Covered. Placing on the market and exporting are both triggering events. |
| Declaration | No filing. Due diligence held internally, produced on request. | A statement filed in the information system before the goods move, returning a reference number that customs check. |
| Country risk | No formal benchmarking. | Low / standard / high classification, driving simplified due diligence and check rates of 1% / 3% / 9%. |
| Penalties | Set nationally, widely variable, often modest. | Floors set at EU level, fines to at least 4% of EU turnover, confiscation of goods and revenues. |
What carries over
More than you might expect. If you ran a real EUTR system rather than a paper one, these transfer directly:
- The three-step structure. Information, risk assessment, risk mitigation is the same architecture. Article 10's fourteen factors are broader than the EUTR criteria but recognisably the same exercise.
- Legality evidence. Harvest permits, concession documents, tax and export records, species and volume documentation, all still needed, and now feeding Article 3(b).
- Supplier relationships and audit routines. The chains you already know how to interrogate are the chains you now need plot data from.
- Species identification. Common and scientific names remain a requirement, and remain a frequent omission on composite products.
What does not, and where the work is
- Geolocation. No EUTR system holds plot geometry, because nothing required it. This is a new dataset, a new collection process and a new maintenance burden, not a field to add to an existing record.
- The 2020 baseline. Legality is a documentary question; deforestation is a remote-sensing question. Different evidence, different tooling, different expertise. See the cutoff.
- Filing discipline. The EUTR let you assemble the file and hold it. The EUDR requires a statement before the goods move, with customs enforcing it. Compliance moves from an audit rhythm to a transaction rhythm.
- Product scope. Publishers, printers, packaging converters and furniture makers who were outside the EUTR are inside the EUDR. If your Annex I assessment predates May 2026, re-check it.
- Export flows. Every EU-origin consignment leaving the union now needs its own statement, an entirely new obligation for domestic processors who only ever sold outward.
EU-grown timber is in scope too. A common misreading of the EUTR carried into the EUDR: that domestic harvest is somebody else's problem. It is not. EU member states are classified low risk, which usually means simplified due diligence, but simplified due diligence still requires the full Article 9 information set, including plot geolocation. Swedish, Finnish, Polish and Romanian forestry all sit inside the regulation.
The FLEGT question
FLEGT-licensed timber enjoyed a presumption of legality under the EUTR. Under the EUDR a licence can support the legality limb, but it says nothing about the deforestation limb and nothing about plot geolocation. Treat FLEGT documentation as evidence feeding your risk assessment, not as a route around it. The same applies to certification schemes generally.
Related
Sources
Every claim on this page is drawn from Regulation (EU) 2023/1115 as amended, the Commission’s guidance and FAQ, and the implementing and delegated acts. Read the consolidated text on EUR-Lex.
Konstata is compliance software, not legal advice. Verify obligations against the consolidated EUDR text on EUR-Lex.
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