The question is not whether you declare deforestation-free: it is which plot your batch came from
7 min read
A typical scenario, not our own case. A wood-furniture company buys sawn timber from several sawmills through an intermediary, seasons it, cuts it and turns it into furniture components sold across the Union. A customer asks for the due diligence statement required under the deforestation regulation. The sales office opens the supplier file: name, address, framework contract. One thing is missing, and it is the one that matters: which forest the trunk came from that produced the plank now sitting in the batch being shipped. The regulation does not ask whether the timber is legal in the abstract. It asks for the plot of land, one by one, where it grew.
The prohibition sits in Article 3; the proof sits in Article 9
Regulation (EU) 2023/1115 — the EUDR — covers seven commodities, listed verbatim in Article 1: “cattle, cocoa, coffee, oil palm, rubber, soya and wood”, plus the products that contain them. Article 3 sets the prohibition: relevant commodities and products “shall not be placed or made available on the market or exported” unless they are, together, “deforestation-free”, produced “in accordance with the relevant legislation of the country of production” and “covered by a due diligence statement or a simplified declaration”. “Deforestation-free” carries a cut-off date, fixed by Article 2: the commodities must come from “land that has not been subject to deforestation” after 31 December 2020 and, for wood, must be harvested “without inducing forest degradation” after the same date.
Article 4 turns the prohibition into an operational duty: before placing the product on the market, the operator exercises due diligence and makes available to the competent authorities a statement declaring “no or only a negligible risk”. By submitting it, the operator “shall assume responsibility for the compliance of the relevant product with Article 3”, and keeps a record of it for five years. The documentary core is Article 9: for five years, backed by evidence, the operator collects “the geolocation of all plots of land where the relevant commodities … were produced”, “as well as the date or time range of production”. A dot on a map is not enough: Article 2 defines geolocation as coordinates “using at least six decimal digits”, and for plots “of more than four hectares” — other than cattle holdings — “polygons with sufficient latitude and longitude points to describe the perimeter” are required. For cattle, geolocation instead covers “all the establishments where the cattle were kept”.
Where the plot-level data actually sits
In a company that buys through intermediaries, that data does not live in one place. Coordinates come from suppliers — when they come at all — in spreadsheets or PDFs sent by email, each in its own format: no common schema, no automatic check that the point given is really where it claims to be. The supplier register sits in the ERP, and records who sold what, not which forest or field it came from. Batch traceability sits in the production system or the MES, and breaks at the first blend: three different consignments of sawn timber become one batch of semi-finished stock, and the upstream link is lost right there. Invoices and transport documents sit in accounts and in logistics; customs declarations are held by the customs representative, not by the office that bought the goods — the same distance between whoever holds the data and whoever answers for it applies to customs origin. The country-risk assessment required under Article 10 — which weighs the “prevalence of deforestation or forest degradation in the country of production” and the “complexity of the relevant supply chain” — and the evidence gathered for it sit in a file kept by whoever handles sustainability, rarely linked to the ERP that generates the delivery notes.
The link between the batch sold and the plot of land where the raw material was grown is the one piece of data, in the whole statement, that no company system holds in full: it originates outside the company and must cross every step of the supply chain without breaking. The ERP knows who supplied the timber; the MES knows which batch it entered; neither, on its own, knows whether it came from the plot declared three shipments ago or from a neighbouring one, possibly deforested after 2020. Without that link rebuilt and dated, the due diligence statement is a completed form, not proof — much as a signed policy is not enough without the data proving it was implemented.
Penalties, and the dates verified today
Article 25 leaves penalties to the Member States within one shared constraint — effective, proportionate, dissuasive — but sets a common floor: for legal persons, the maximum fine “shall be at least 4 % of the operator’s … total annual Union-wide turnover”, on top of confiscation of products and revenues and exclusion for up to 12 months from public procurement in the event of a serious or repeated infringement. We report no Italian amounts: we have not verified the national transposing rule against a primary source.
Full application has been postponed twice: by Regulation (EU) 2024/3234 of 19 December 2024 and by Regulation (EU) 2025/2650 of 19 December 2025. In the EUR-Lex consolidated version updated to 26 December 2025, Articles 3 to 13 — among others listed in Article 38 — “shall apply from 30 December 2026” for large and medium-sized undertakings. For natural persons and micro and small undertakings established as such by 31 December 2024, this slips to 30 June 2027 — except for products already covered by the old timber regulation (Regulation (EU) No 995/2010), which stay on the general date of 30 December 2026, with its own transitional regime running to 31 December 2029 for wood harvested before 29 June 2023. The same Regulation 2025/2650 introduced a simplified regime for micro and small primary operators: a one-time simplified declaration, with geolocation replaceable by a postal address. That simplification is theirs, not the processing company’s, which still faces the full duty on 30 December 2026.
If a customer asked you today, for the batch shipped this week, for the geolocation of the plot of origin, how many systems would you need to open — supplier emails, ERP, MES, accounts, freight forwarder, the sustainability file — before answering with data that would hold up to a check?
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Where we stop
We do not provide legal advice and we do not qualify any company’s supply chain: whether a plot of land has been subject to deforestation after 31 December 2020 is an assessment for the operator, using the tools the regulation itself provides. We report no Italian penalties, because the transposing rule is not one we have verified here against a primary source. We do not cite the information platform under Article 33 or the Commission’s guidance on applying the regulation: we have not opened them for this piece, and whoever consults them directly will find guidance more current than any article can stay.
The two axes, applied
Complying. In our system, the information duty under Article 9 becomes a control running on the client’s documents and systems: for every batch placed on the market, which plots of land support it, from which supplier, with what evidence and in which system it sits — ERP, MES, accounts, logistics, the sustainability file — with an alert when a batch enters production without the link to its plot of origin. The file comes out exportable and dated, ready for inspection, instead of rebuilt by hand once the request arrives.
Deciding. The same system unifies ERP, MES, accounts, logistics and document archives into a single operating model on which AI agents execute decisions with a human operator in command — for large enterprises, defence, public administration and healthcare. Always in two delivery modes: on-premises, on autonomous machines needing no deep integration into the client’s network, or dedicated cloud, with a dedicated VPN and a data centre in Italy. Always with shared management.
From the first session, at no cost, comes the dated list of the products in scope, with, for each one, which data supports the statement, which system holds it and who updates it — blank boxes included. It stays yours even if we do not go on together. Talk to one of our engineers.