Companies that import timber in the EU are now navigating two overlapping regulations: the EU Timber Regulation (EUTR) and the EU Deforestation Regulation (EUDR).

The EU Timber Regulation focuses on legality, making sure timber placed on the EU market is not illegally harvested. The EU Deforestation Regulation keeps the same due diligence logic but raises the bar: timber must be deforestation-free and companies need to show compliance with a wider set of “legal production” requirements, which can include third-party and human rights-related laws in the country of production.  

The EUTR has been the rulebook since March 2013, which means it has shaped timber due diligence for almost 13 years. On the other hand, the EUDR was adopted much later and its enforcement has been pushed back again. The latest EU decision postpones application to 30 December 2026 (with later dates for smaller companies under the regulation).

That combination, a long-running timber law plus a delayed replacement with a different evidence bar, is exactly where timeline confusion starts. Many companies are wondering which rules apply during this transitional period and when the switch will actually happen for timber.

What is the timeline for EUTR and EUDR?

The EUTR has been in force since March 2013, making it illegal to place illegally harvested timber on the EU market. For more than a decade, it has been the baseline of timber due diligence in the EU, requiring companies to assess legality risks and keep supporting documentation. Importantly, the EUTR remains fully applicable today. Its obligations do not pause or weaken because of the EUDR. Enforcement continues without interruption until the EUDR formally replaces it after a phase-out period.

Read our detailed breakdown of the EUTR and who must follow it.

The EUDR was adopted in June 2023, as a broader framework covering seven forest-risk commodities, including timber. While it builds on the same due diligence logic as the EUTR, it adds stricter requirements around deforestation-free production, geolocation, and expanded legality checks. The regulation was originally expected to apply from the end of 2024, but its rollout has been postponed twice. Following the latest delay, the EUDR will apply from 30 December 2026 for large and medium companies. 

Although the regulation provides a later application date for small and micro enterprises in general, this additional SME deferral does not apply to timber and timber products already covered by the EUTR. For timber operators, including SMEs, due diligence obligations therefore continue without a sector-specific grace period.

Crucially for timber companies, the EUTR and EUDR are designed to operate alongside each other during a defined transition period. The EUTR does not stop applying when the EUDR enters into force. Instead, the EUDR creates a transitional framework under which timber harvested before a specific cutoff date can continue to follow EUTR requirements. 

Under these rules, timber harvested before 29 June 2023 may be placed on the EU market in line with the EUTR until 31 December 2028. From 1 January 2029 onwards, all timber placed on the EU market must comply with the EUDR and EUTR will completely phase out as a regulation. The key factor determining which regulation applies is the harvest date of the timber. The harvest date refers to when the tree was felled, not when the product is imported, sold, or transformed. 

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Does the EUTR still apply?

The EUTR remains in force and enforceable for timber both before the EUDR starts applying and throughout the EUDR transition period. It does not stop applying when the EUDR enters into force.

For timber companies, this means that an EUTR-compliant due diligence system is still required. Companies must continue to assess legality risks and retain supporting documentation for timber placed on the EU market today, and for timber harvested before 29 June 2023 that can continue to follow EUTR rules until 31 December 2028. There is no enforcement gap during this period, and national authorities continue to carry out EUTR checks. 

At the same time, companies are expected to prepare for, and eventually apply, the EUDR due diligence system for newly harvested timber. Importantly, an EUDR due diligence system does not replace the EUTR one. It must be aligned with EUTR requirements. In practice, this means due diligence systems need to support both regimes at once, with legality checks that satisfy EUTR and additional data layers that meet EUDR requirements.

For timber companies, the transition is therefore not about switching from one system to another, but about building on existing EUTR due diligence so it remains valid while expanding it to meet EUDR obligations. This alignment is essential to avoid compliance gaps during the years when both regulations apply.

How often do companies need to report or do due diligence under EUTR?

Companies do not need to submit periodic reports under the EUTR, but they must apply due diligence continuously for every placement of timber on the EU market and repeat the process at least annually. 

A key point when preparing for EUTR compliance is that due diligence is not a one-off reporting exercise. Unlike regulations that require scheduled submissions to authorities, the EUTR is built around continuous due diligence. Operators are required to have a due diligence system in place and to apply it every time they place timber or timber products on the EU market. There is no obligation to file regular reports with authorities as compliance is assessed through inspections rather than recurring filings. 

At the same time, this does not mean that companies must rebuild their due diligence from scratch for every shipment if the underlying supply conditions have not changed. In practice, many companies organise EUTR compliance around supplier–product combinations. This means conducting a comprehensive risk assessment for a specific product sourced from a specific supplier and origin, and relying on that assessment for subsequent shipments as long as the relevant conditions remain the same. However, this due diligence is not static. It must be updated whenever key elements change, such as the supplier, country or region of harvest, species, product type, or the risk profile of the supply chain. 

In addition, even where no obvious changes occur, good practice, and regulatory expectations,  point towards reviewing EUTR due diligence at least annually to confirm that the information remains accurate and that no new risks have emerged. This ensures that the due diligence system remains effective over time, rather than becoming outdated

It is also important to distinguish between operators and traders under the EUTR, as their obligations differ. Below is a clear breakdown of their responsibilities:

• Operators are companies that place timber or timber products on the EU market for the first time. They are responsible for carrying out full due diligence, including information gathering, risk assessment, and risk mitigation where needed. 

• Traders deal with timber that has already been placed on the EU market. They are not required to perform risk assessments themselves, but must maintain records identifying their suppliers and customers and keep those records for at least five years. 

This traceability requirement of traders allows authorities to follow timber flows through the supply chain if concerns arise. Operators are similarly expected to retain their due diligence documentation for a minimum of five years, in case of audits or inspections.

EUTR vs EUDR: What changes and what stays the same?

The EUTR and the EUDR share the same overarching objective: keeping illegal and unsustainable forest-related products out of the EU market. However, the EUDR significantly expands both the scope and the evidence required to demonstrate compliance. For timber companies, this means moving from a legality-based framework to a broader system that also addresses deforestation risk and traceability.

The main differences and continuities between the two regulations can be summarised as follows.

1. Scope of commodities

The EUTR applies exclusively to timber and timber products. The EUDR, by contrast, covers seven forest-risk commodities: timber, cattle, cocoa, coffee, palm oil, rubber, and soy, along with a wide range of derived products. While timber remains in scope under both regulations, the EUDR extends the same due diligence logic to additional sectors that were not previously regulated under the EUTR.

2. Legality versus deforestation-free production

Under the EUTR, compliance is centred on legality. Operators must ensure that timber has been harvested in accordance with the applicable laws of the country of production. The regulation does not explicitly require companies to assess deforestation or land-use change.

The EUDR retains the legality requirement but adds an additional condition: products must be deforestation-free. Companies must be able to demonstrate that commodities were not produced on land deforested after 31 December 2020 and, for timber, that they are not linked to forest degradation. As a result, EUDR due diligence goes beyond legality alone and introduces an environmental threshold that did not exist under the EUTR. Even the legality requirement is expanded to topics out of the field of legal harvesting to responsible business practices and third party rights.

3. Depth and form of due diligence

Both regulations require companies to carry out due diligence, but the level of detail and formality differs. Under the EUTR, operators are required to collect basic supply chain information (such as species, country of harvest, supplier and quantity), assess the risk of illegal harvesting, and mitigate that risk where necessary. This process is largely internal, with no obligation to submit due diligence information to authorities unless requested during an inspection.

Under the EUDR, due diligence becomes more granular and shipment-specific. For each batch placed on the market, companies must collect detailed data, including the geolocation of the exact plot of land where production took place and the time of production or harvest. Once risk is assessed as negligible, a due diligence statement must be submitted to the EU’s platform TRACES before the product can be placed on the market. In practice, this shifts compliance from holding due diligence to formally declaring it for each shipment.

4. Traceability and documentation requirements

The EUTR requires traceability on supplier and country level down the supply chain: operators must know their suppliers, and traders must keep records of buyers and sellers. It does not require traceability back to the forest plot itself.

The EUDR introduces plot-level traceability. Companies must obtain and retain geolocation coordinates for the land where timber (and other in-scope commodities) was produced, allowing authorities to verify deforestation-free status. While both regulations require records to be kept for at least five years, the volume and specificity of documentation required under the EUDR is substantially higher.

What stays the same

Despite these changes, several core principles remain consistent. Timber is covered under both regulations. In both cases, responsibility lies with the company placing products on the EU market, and placing non-compliant products on the market is prohibited. The logic of risk assessment and mitigation carries over from the EUTR to the EUDR, even though it is more formalised under the newer regulation. Enforcement also remains the responsibility of national authorities, although the EUDR introduces more harmonised penalty requirements across Member States.

Overall, the EUDR does not replace the EUTR approach to timber due diligence so much as build on it. For timber companies, the shift is going to be less about building an entirely new system and more about expanding the existing due diligence system to meet the extended compliance requirements.

Which regulation applies to my shipment? (Practical examples)

During the transition from the EUTR to the EUDR, the regulation that applies to a specific shipment of timber depends on when the timber was harvested and when it is placed on the EU market.

The most important reference point is the harvest date. This determines whether a shipment falls under the EUTR transition regime or the EUDR framework once its obligations become enforceable.

To illustrate how this works in practice, consider the following examples:

Example 1: Timber harvested in 2022, placed on the EU market in 2025

Frameworks to comply with: EUTR 

This shipment falls under the EUTR. The timber was harvested before the EUDR cutoff date and is placed on the market before EUDR obligations apply. The operator must carry out EUTR due diligence focused on legality and retain the required documentation. No EUDR due diligence statement is required.

‍Example 2: Timber harvested in 2024, placed on the EU market in 2026

Frameworks to comply with:

• EUTR until EUDR enforcement
• EUDR after EUDR enforcement

Until the EUDR becomes enforceable, this shipment is still subject to the EUTR. Even though the timber was harvested after the EUDR cutoff date, the EUDR does not yet apply, and there is no compliance gap. The operator must therefore carry out EUTR due diligence when placing the timber on the market.

Once the EUDR becomes enforceable, timber harvested after 29 June 2023 is no longer eligible for the EUTR transition. From that point onward, these products must be handled exclusively under the EUDR for the entire transition period, meaning companies must apply full EUDR due diligence for each shipment.

Example 3: Timber harvested before 29 June 2023, placed on the EU market after EUDR applies (e.g. in 2027)

Frameworks to comply with: EUTR until 2028

This shipment will still follow EUTR requirements as the timber harvested before the EUDR cutoff date may continue to be placed on the EU market under EUTR due diligence until 31 December 2028, even if the EUDR is already in force. Operators must be able to demonstrate the harvest date to rely on this transition.

EUTR and EUDR side-by-side

To summarise the key dates and transition milestones, here’s a timeline comparison of EUTR versus EUDR:

What to do now: dual compliance checklist for 2025–2027

Until the EUDR becomes enforceable, and throughout the transition period that follows, timber companies must continue applying the EUTR while progressively preparing for the EUDR. During this waiting period, the focus should be on keeping EUTR compliance robust while making sure existing systems can evolve into EUDR-ready ones.

1. Continue full EUTR due diligence

EUTR enforcement has not slowed down. Competent authorities have continued to invest in inspections and auditor capacity, and with the EUDR delayed, EUTR remains the primary framework authorities will use to assess timber compliance. Companies should therefore continue applying EUTR due diligence rigorously: assessing legality risks, maintaining documentation, and ensuring non-negligible risks are addressed. Scaling back EUTR efforts in anticipation of the EUDR would increase enforcement exposure during this period.

2. Review whether your EUTR system already meets EUDR legality expectations

Although the EUDR introduces new requirements, part of its due diligence framework, particularly around legality, builds on concepts already familiar under the EUTR. This makes the interim period a good moment to assess whether your existing EUTR processes are sufficiently robust to support the expanded legality checks under the EUDR, including areas such as land tenure, third-party rights, and responsible business practices. Identifying gaps early allows companies to adjust their EUTR systems in a way that remains compliant today while reducing future rework. Many companies follow only informal or ad-hoc processes still on EUTR and when this is the case it needs to be identified and adjusted to the EUDR standards.

3. Introduce a harvest-date tag at order level

Because the applicable regulation during the transition depends on when the timber was harvested, companies should introduce a clear harvest-date identifier in their systems. This tag should be used to determine, for each order, whether EUTR or EUDR requirements apply. Having this logic embedded operationally is critical to managing parallel obligations and avoiding misapplication of due diligence rules as EUDR enforcement approaches.

4. Start EUDR data deep-dives with your most mature suppliers

Rather than attempting to roll out full EUDR data collection across all suppliers at once, companies can use this period to work first with their most mature and transparent suppliers. This typically means going one step beyond existing EUTR traceability by moving from chain-of-custody information to plot-level identification, including geolocation. From there, companies can progressively expand the data requested, aligning supplier by supplier with the full EUDR dataset, while building internal processes and expectations in a controlled way.

Taken together, these steps allow companies to remain fully compliant under the EUTR today while gradually shifting their due diligence systems toward EUDR readiness. The transition is not about replacing one framework with another, but about extending existing EUTR processes so they can support both regimes during the years when they overlap.

How software helps manage the EUTR to EUDR transition

Managing EUTR and EUDR obligations in parallel is difficult to do manually. Spreadsheets, shared folders, and email-based document collection quickly become hard to maintain when different rules apply to different shipments at the same time. This is where dedicated compliance software becomes particularly valuable during the transition period.

Harvest date tracking and automatic classification

Software can collect and store harvest-date information at product or order level and automatically classify shipments as falling under EUTR, EUDR, or the EUTR transition regime. This removes the need for manual checks and helps ensure the correct due diligence requirements are applied consistently as enforcement dates approach.

One system for both regimes

Rather than treating EUTR and EUDR as separate compliance exercises, software allows companies to manage both within a single system. Documents collected for EUTR, such as legality evidence, supplier information, and risk assessments, can be reused and expanded as EUDR requirements come into scope. This avoids duplicating work and ensures that existing due diligence remains valid while additional data is layered in over time.

From supply chain traceability to plot-level geolocation

EUDR requires a shift from supply chain traceability to plot-level traceability. Software supports this transition by allowing companies to start with existing chain-of-custody information and progressively add geolocation data for suppliers that are able to provide it. As this data is added, systems can support deforestation-risk checks by linking geolocation coordinates to relevant risk data, helping companies assess deforestation exposure as part of EUDR due diligence.

How software can support the transition to EUDR reporting

When EUDR obligations become enforceable, companies will need to submit due diligence statements for compliant shipments. Software can support this transition by structuring collected data in line with EUDR reporting requirements and preparing it for submission through EU systems such as TRACES. This reduces the risk of missing or inconsistent data and makes the shift from internal due diligence to formal reporting more manageable.

Coolset’s platform is designed to help timber companies manage both EUTR and EUDR requirements in one place. Instead of duplicating efforts or starting from scratch, teams can extend their existing EUTR due diligence system to meet EUDR expectations.

You can tag harvest dates, track which regime applies to each shipment, reuse existing supplier documentation, and begin layering in EUDR-specific data like geolocation and deforestation status - all within the same workflow. When EUDR becomes enforceable, the platform also supports automated Due Diligence Statement generation and submission via TRACES.

See Coolset for EUTR in action - reach out to our team.

Frequently Asked Questions

What is the timeline for the EUDR?

The EUDR officially entered into force on 29 June 2023, but its obligations apply after a phase-in. As of the latest update, large and medium companies must start complying by 30 December 2026, and small/micro companies by 30 June 2027 for non-timber commodities. Small and micro companies in the timber industry have to comply from 30 December 2026. (These dates reflect a one-year postponement agreed by the EU in late 2025).

Does the EUDR replace the EUTR?

Yes. The EUDR will completely replace the EUTR but not instantly. There is a transitional overlap: timber harvested before the EUDR’s cutoff date (29 June 2023) can still be traded under EUTR rules until the end of 2027/2028 (depending on placement date). During that transition, EUTR and EUDR both operate. After 2028, EUTR will no longer be used at all. 

Is the EUDR delayed?

Yes, the EUDR’s enforcement has been delayed twice from its original schedule. Initially, the regulation’s application was expected in December 2024 (18 months after June 2023 entry into force. That was postponed by one year to 30 December 2025 for large companies. Then, in late 2025, EU institutions agreed on another one-year delay. As a result, the new enforcement dates are December 2026 (large/medium firms) and June 2027 (small firms). Read Coolset's article on whether the EUTR still applies if the EUDR is delayed for more information.

Can EUTR and EUDR apply at the same time?

Yes, but only across different shipments, not for the same product. During the transition period, a company may be subject to both EUTR and EUDR at the same time, depending on the timber it places on the EU market. Until the EUDR becomes enforceable, all timber falls under the EUTR. Once EUDR enforcement starts, timber harvested before 29 June 2023 can continue to follow EUTR requirements until 31 December 2028, while timber harvested on or after 29 June 2023 must comply with the EUDR.

How long do I need to keep EUTR documents?

At least five years. Both the EUTR and EUDR have a five-year record-keeping requirement. Under EUTR, operators and traders must retain the information related to due diligence and supply chain transactions for a minimum of five years. This includes purchase documents, supplier info, risk assessment files, mitigation measures taken, etc. The idea is that authorities can check back on compliance for a reasonable period after the fact.