Why This Is Your Problem, Not Just Your Buyer's
EUDR technically applies to the EU-based "operator" who places goods on the EU market โ not to you as a US exporter. But that operator legally cannot file a compliant Due Diligence Statement without plot-level geolocation and legality data that only exists at your end of the chain: the harvest site. If you can't produce it, EU buyers won't take the risk โ they'll source from an exporter who can.
What's Actually Covered
EUDR regulates raw and many processed wood products, not just logs. That includes logs, sawnwood, veneer, plywood, particleboard and OSB, wood pulp and paper, and certain furniture and printed products that contain wood. If it's made from timber and headed to the EU, assume it's in scope until you confirm otherwise.
What Your EU Buyer Will Ask You For
GPS coordinates for the harvest plot
Not the county or state โ the actual plot the timber was cut from, precise enough to identify the specific production area.
Harvest date and species confirmation
Tied to the specific load or batch, not a general seasonal estimate.
Proof the land wasn't deforested or degraded after December 31, 2020
Usually established through a satellite imagery cross-check against that cutoff date.
Legal harvest documentation
State harvest permits, Best Management Practice (BMP) compliance records, and landowner agreements that establish the harvest was legally authorized.
A documented chain of custody
From landowner, to logger, to mill, to hauler, to exporter โ with each handoff recorded, not just the origin and destination.
How US Compliance Frameworks Overlap (and Don't) With EUDR
The US Lacey Act already requires species declaration and proof that timber was harvested legally โ and that documentation genuinely helps. But the Lacey Act doesn't require plot-level geolocation or a deforestation-free proof point tied to December 31, 2020. Lacey Act compliance and EUDR compliance are not the same thing, and having one doesn't mean you automatically have the other.
The same goes for forest certification schemes like FSC or SFI. Certification is useful supporting evidence, but it isn't automatically accepted as EUDR proof on its own โ you still need the underlying geolocation and post-2020 deforestation check.
Steps to Get Ready Before Your Buyer Asks
- Start capturing GPS coordinates at the point of harvest, not after the fact โ retroactive geolocation is far harder to establish credibly.
- Cross-check harvest sites against forest-cover status as of December 31, 2020, using satellite imagery.
- Digitize your chain of custody. Paper tickets and disconnected spreadsheets are still how most US exporters track this today, and it doesn't hold up well under EU due diligence review.
- Decide who in your chain will actually file the DDS โ usually your EU importer, if you're upstream โ but be ready to hand them everything they need in a form they can attach a reference number to.
- Track the deadline that actually applies to your buyer: large and medium EU operators must be compliant by December 30, 2026; if you sell to a smaller EU importer, theirs is June 30, 2027.
FAQ
Does EUDR apply to me if I never touch the EU myself?
Yes, indirectly. Your buyer needs your data to file a valid DDS, so in practice you carry the documentation burden even though you're not the one submitting it.
Is FSC or SFI certification enough on its own?
No. It can support your file, but it doesn't substitute for plot-level geolocation and a post-2020 deforestation check.
What if I sell through a broker or trader instead of direct to an EU buyer?
The obligation still traces back to the point of origin. A broker will ask you for the same underlying geolocation and legality data to pass along the chain.