Regulation and reporting as data problems · 28 Sep 2026

What data does EUDR actually require from wood exporters?

← Regulation and reporting as data problems

Exporters outside the EU have no direct obligation. The EU Deforestation Regulation places its duties on the companies that place wood products on the EU market, and on those exporting from it. Those companies can only file due diligence with data the exporter holds. For each product, that means the geolocation of every plot the wood came from, including every wood component of a composite product. It means the full scientific name of each species, and when the wood was harvested. It means evidence it was harvested legally in the country of production. And the wood must be kept apart from wood of unknown origin at every step. The regulator's May 2026 review applies it from 30 December 2026 to all companies except most micro and small operators.

An exporter based inside the EU is in a different position. The regulator's FAQ says operators must trace each commodity to its plot "before making a relevant product available or placing it on the EU market, or before exporting it". An EU-based exporter files its own due diligence.

What the usual answer says

The top answers list geolocation, species, harvest dates, supplier details and legality evidence. That list is broadly right. It was written against the 2024 or 2025 timeline, and it treats the data as documents to collect. For a sawmill or panel maker, the harder question is how the data travels with the wood.

Segregated supply base: the whole plot list travels with every product Plot Harvest unit Load ticket Mill batch Product lot Shipment Batch-level links: each step joined to the next Segregated supply base ships with the full list of plots and species that could be in it Linked batch by batch ships with only the plots in that lot
Both designs keep known-origin wood apart from wood of unknown origin. The linked design needs the records between each step joined, which is the link most mills rarely hold. Diagram: Quarri.

Where the rules now stand

The regulator's simplification review of 4 May 2026 confirms that the regulation "will enter into application on 30 December 2026" for all companies except most micro and small operators, who follow on 30 June 2027. Micro and small operators "already covered by the EU Timber Regulation" also start on 30 December 2026. Amendments in 2024 and 2025 "shifted due diligence responsibilities to first placers on the EU market". The review estimates the combined changes cut annual compliance costs "by approximately 75%". A law firm's summary of the December 2025 amendment adds that printed products "have been removed from the scope".

The review keeps geolocation. The postal-address alternative, including "cadastral information or an equivalent", is for micro or small primary operators filing a simplified declaration. The FAQ, version 5 of April 2026, puts it the same way. A medium or large sawmill or its forest suppliers still need plot geolocation.

The wood-specific detail

The FAQ is precise on three points. For composite products such as furniture, it says "the operator needs to geolocate all the plots of land where the relevant commodity (wood, for example) used for the manufacturing process has been produced." The scientific name "is mandatory for all relevant products listed in Annex I to EUDR under the commodity Wood", including pulp and paper. A state forest association's summary of the May guidance adds that the information system "requires species-level identification; genus alone is not sufficient". Where the species can't be pinned down, "the operator must list every species that may have been used". Timber harvested before 29 June 2023 stays under the old timber regulation if placed on the market by 31 December 2029. Packaging "used exclusively to support, protect or carry another product is out of scope".

Downstream, the law firm's summary notes that operators and traders must keep supplier details "for five years", with the reference numbers of the due diligence statements behind them.

Segregation, not identity preservation

This is where the data model is decided. The FAQ rules out mass balance chains of custody. Wood of known origin can't be mixed with wood of unknown origin "at any step of the supply chain". But it adds: "As mass balance is therefore to be ruled out, full identity preservation is not needed."

So a mill has two lawful designs. It can keep a segregated supply base, where every log comes from plots it has geolocated and checked. Each product then ships with the full list of plots and species that could be in it. Or it can link each shipment to the batches, load tickets and harvest units that fed it, and ship with only those plots.

The first is simpler, and for a mill with a stable, compact supply base it may be enough. The second is worth building when the full list would run to hundreds of plots a buyer won't review, or when one plot in the supply base is one a buyer won't accept. Most mills already hold scaling, production and shipping records. What they rarely hold is the link between them.

Where AI helps

AI can read permits, cutting licences and certificates into structured records. It can map common species names to full scientific names, match load tickets to harvest units, and flag shipments whose plot list is incomplete. What it can't do is recreate a link between a batch and its logs that was never recorded.

When it doesn't apply

Exporters whose buyers are all outside the EU have no reason to build this. Products outside the regulation's annex are out of scope, and so, since December 2025, are printed products.

Quarri for sawmills is built around how a sawmill runs, from log intake to shipped order.

Sources

  1. European Commission, "Report from the Commission to the Council and the European Parliament" on the EUDR simplification review, COM(2026) 191 final, 4 May 2026: environment.ec.europa.eu
  2. European Commission, "Frequently Asked Questions: Implementation of the EU Deforestation Regulation", version 5, April 2026: webgate.ec.europa.eu
  3. European State Forest Association, "EUDR: What the Commission's 4 May 2026 simplification package means for wood, state forests and non-EU operators": eustafor.eu
  4. Stibbe, "The amended EUDR: what has changed and what has remained", 30 December 2025: stibbe.com

Quarri is an AI-native data platform for the timber supply chain. It connects buying, production, sales and inventory for forest management, sawmill, wood products and pulp, paper and packaging operators.

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