How Woodwise built audit-ready supplier traceability

Initial challenges

When EUDR obligations first became clear, Woodwise faced several significant hurdles:

• Unclear company role per product: Determining when the company was an operator (first placer on the market) vs. a trader (reseller) was not always obvious - especially across different sourcing and manufacturing pathways.
  
  
• SME status ambiguity: EUDR obligations vary based on company size, and Woodwise needed to confirm whether it would qualify as an SME with potentially lighter duties. Based on headcount and turnover, it did not qualify, meaning it must meet full due diligence obligations.

• Mixing timbers: Woodwise import timber from multiple sources, and use mixes of the timber to make furniture items. Warnings of mixing in EUDR meant that Woodwise are unsure if they are allowed to use timber from different sources, in one product.
  
  
• Wood-specific risk assessment: Under the EU, timber is subject to additional risk assessments. Woodwise are uncertain about the exact parameters of the risk assessments they must conduct.

• Collecting supplier data: As Woodwise do not purchase data directly from timber harvesters, but from middle-ground suppliers, they were uncertain on how to collect information on the ‘plot’ level - such as geolocation, legal employment information and deforestation information.

This case study will take you through each challenge, step-by-step, to show how Woodwise came to understand better their requirements under EUDR.

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Key EUDR challenges and how Woodwise addressed them

1. Unclear DDS responsibilities for furniture products

One of Woodwise’s first hurdles was determining whether and when it needed to produce a new Due Diligence Statement (DDS). For example, when importing timber from Brazil, Woodwise clearly acts as the operator and must create a DDS, as it is the first company importing the product into the EU. But for timber purchased from another EU company - say a Dutch distributor - a DDS already exists. A couple of things stand out here:

1. Woodwise is a non-SME. With >250 employees, it is not allowed to simply pass on DDS, it must submit a new DDS. Either as a trader or operator.
2. When importing goods, Woodwise must make a DDS for any EUDR relevant product that does not already have a DDS. In this example, for the timber imported from Brazil.
3. As Woodwise is manufacturing materials, and making a ‘new’ (in terms of HS code) product available on the market, they are considered an ‘operator’ and must create a new DDS. 

The answer lies in the Regulation (EU) 2023/1115, which states that operators responsible for the first making available of a relevant commodity or product on the Union market, must exercise due diligence and submit a DDS. As wooden furniture is listed in Annex I as a relevant product, with a different HS code from timber, it therefore requires a new DDS. 

However, the input DDS (from imported or intra-EU timber) can be referenced within the new one. As noted in the FAQs, DDSs can integrate information from earlier DDSs - such as legality, geolocation, and supply chain - provided these are traceable and valid. For Woodwise, this means that their outgoing DDS for the finished furniture can reuse verified data from the input timber DDSs, but must still be product-specific and shipment-specific.

2. Mixing timbers in single furniture items

Woodwise often mixes timbers in one product - such as making a chair where the seat panel is Swedish pine and the backrest is Indonesian teak. Given EUDR’s warnings against mixing known-origin and unknown-origin materials, the company questioned whether such a product would be compliant. The EU FAQ highlights that mixing products from different sources is allowed, provided the origin of each component is known and verifiable, and the final DDS accounts for each unique plot of origin. 

In the chair example, Woodwise must create a DDS that includes geolocation and legality data for both timber sources. Swedish pine may qualify as low-risk under Article 29 (see more about changes to the risk benchmarks here), while Indonesian teak will require full due diligence under Article 10. Because each component has a known origin, complete traceability, and its own DDS (or source data), Woodwise is allowed to combine them in the final product. 

The regulation prohibits mixing only in cases where traceability is lost or risk is obfuscated - not in cases where mixed sourcing is clearly documented and risk-assessed.

3. Wood-specific risk assessment requirements

Timber - unlike coffee or cocoa - is subject to a dual compliance threshold: it must be both deforestation-free and degradation-free. Degradation, under EUDR, focuses on a structural change from one forest type to another. This distinction caused early confusion for Woodwise, particularly in assessing how to structure risk assessments and what evidence would be sufficient. 

As the FAQ singles out wood and requires that it (a) be harvested from land not subject to deforestation after 30 December 2020, and (b) be harvested without inducing forest degradation after that date. This means that even legal timber harvests may still be non-compliant if they cause degradation - for example, if selective logging reduces forest canopy below minimum thresholds or disrupts ecological functions.

To operationalise this, Woodwise used Coolset, which automatically provides a wood-specific risk assessment workflow. For every shipment of timber - particularly from countries like Brazil and Indonesia - geolocation data was examined, as well as satellite maps and land-use classification layers to verify that the land had not been cleared post-2020. The post-harvest management practices were also assessed, to understand if they had “induced degradation”, including: 

• Whether local forest management laws are followed,
• Whether post-harvest regeneration plans exist,
• And whether the ecological state of the forest will recover.

This required sourcing forest management plans, harvest permits, and - when needed - consulting local forestry data or reforestation plans to assess future regeneration prospects. Timber from a plot that is degraded (and not recovering) due to harvest activity cannot be placed on the market, even if deforestation did not occur.

Other wood-specific risk assessments were also completed by Woodwise, including species declaration and further scrutiny on the supply chain trading patterns. Alongside the wood-specific risk assessment, Woodwise used Coolset to assess all other risks under Article 10, including legality, social impact and presence of Indigenous peoples.

4. Plot-level supplier data collection

One of the most practical challenges Woodwise faced was collecting granular, plot-level data - such as geolocation coordinates, harvest legality, and social safeguards - from intermediary suppliers who purchase from primary producers. 

Operators are required to know the exact origin of the product, down to the harvest plot. Simply knowing the first-tier supplier (e.g. a Dutch wholesaler or Indonesian mill) is not enough. To bridge this gap, Woodwise used Coolset’s traceability management tool, that allows unlimited suppliers to make an account, and do a 1-1 matching of their incoming and outgoing materials until the origin.

Suppliers are asked to identify the precise plots of harvest for each timber type, and upload relevant documentation. Where middle suppliers were unsure, the Coolset platform allows them to pass on the survey to others further up the supply chain. Through this structured, persistent outreach, the company was able to build a reliable dataset that met the traceability, legality, and no-deforestation requirements of Article 9; using their sales orders, purchase orders and internal batches as the guide to real origin order traceability.

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How Coolset helped Woodwise achieve EUDR compliance

To support its EUDR readiness, Woodwise adopted the Coolset EUDR compliance platform to manage supplier engagement, documentation, and due diligence workflows. Coolset provided dedicated supplier workspaces, enabling Woodwise to send structured questionnaires to each supplier - ensuring geolocation, legality, and forest degradation data were collected in a compliant format. 

The platform's automated risk logic helped distinguish between low-risk and standard-risk timber, and provide custom mitigation plans for high-risk timber products. Geospatial tools helped verify deforestation-free status via satellite-linked mapping. 

Crucially, Coolset’s system allowed Woodwise to integrate upstream DDS data into its own outgoing DDS records, ensuring audit-proof traceability without duplicating effort. With DDS sent automatically to TRACES (the European Commission's digital certification and management platform), Woodwise were able to complete all due diligence within the Coolset platform. This modular, regulation-aligned tool helped the company go from confusion to clarity in just a few quarters.

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Conclusion

With the EUDR compliance deadline fast approaching, Woodwise has built a structured, scalable, and auditable approach to due diligence - grounded in a clear understanding of the regulation and practical execution. From clarifying its operator role and DDS obligations to navigating complex wood-specific risk requirements, the company is now well-positioned to meet its obligations with confidence.

By proactively coordinating with suppliers, investing in systems, and leveraging expert platforms like Coolset, Woodwise has transformed a complex regulatory mandate into a strategic advantage - reinforcing trust, reducing risk, and ensuring long-term access to the EU market for its timber-based products.

*Woodwise BV is a hypothetical company. See more on Coolset’s EUDR compliance platform.

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