From 30 December 2026 timber cannot be placed on the EU market for the first time without an entry in the EU Information System. For a forest owner everything turns on one question: who is the operator in the deal — you or the buyer. We walk through the regulation and the Commission's guidance.
EUDR: less than three months to 30 December 2026
From 30 December 2026, timber can be placed on the EU market for the first time only with an entry in the EU Information System: either a full due diligence statement (DDS) or a one-time simplified declaration. That is the requirement of Regulation (EU) 2023/1115 (EUDR) as amended in December 2025. For timber there is no deferral to mid-2027 — not for private individuals, not for small firms.
The real question for an owner is not "does EUDR apply to me" but "who is the operator in my deal". If you sell standing timber and the logs become the buyer's property the moment they are cut, the obligations sit with the buyer. If you harvest yourself, or hire a contractor, and sell the assortments, you are the operator and you need a simplified declaration. Below: how to tell which case is yours and what to prepare.
Key takeaways
- There is one date for timber: 30.12.2026. The deferral to 30.06.2027 for natural persons, micro and small undertakings does not cover timber (Article 38(3) of the regulation).
- A natural person can be an operator. In a standing-timber sale the operator is whoever owns the logs at the moment of harvesting.
- A private owner or small firm selling its own harvest files one simplified declaration, not a DDS per consignment.
- In a simplified declaration, geolocation may be replaced by the postal address or cadastral details of the plot.
- Deforestation under EUDR means converting forest to agricultural use after 31.12.2020. Felling followed by regeneration is not deforestation.
Correction 04.10.2026. The previous version of this article (May 2026) said that a private individual cannot be an operator, that small forestry firms are deferred to 30.06.2027, that company size is assessed under Recommendation 2003/361/EC, and that every member of the supply chain references the DDS. None of that matches the regulation as amended in 2025 or the Commission's guidance. The text has been rewritten from primary sources, which are linked at the end.
What the regulation actually requires
A product on the EUDR list may be placed on the EU market or exported only if three conditions hold: it is deforestation-free, it was produced legally under the rules of the country of production, and it is covered by a due diligence statement or a simplified declaration. Wood is one of the regulation's seven commodities; roundwood and fuel wood are both on its product list.
The cut-off date is 31 December 2020. As Latvia's Ministry of Agriculture (Zemkopības ministrija) explains, deforestation in the regulation's sense is the conversion of forest to agricultural land; conversion for a road or a building falls outside the definition. Forest means land of more than 0.5 ha with trees higher than 5 m and canopy cover above 10 %. Ordinary felling after which the forest regenerates is not deforestation. For wood there is a second condition: harvesting must not induce forest degradation — the conversion of naturally regenerating forest into plantation forest or other wooded land (Article 2(7) of the regulation).
Latvia, like every EU member state, is classified as a low-risk country (Regulation (EU) 2025/1093). That simplifies due diligence: information on origin still has to be collected, but risk assessment and risk mitigation are not required — unless information pointing to a risk of non-compliance comes to light (Article 13).
Who is the operator: you or the buyer
The operator is whoever first places the product on the EU market in the course of a commercial activity. The European Commission's guidance (FAQ, version 5, point 3.1) says it in so many words: an operator may be a natural or a legal person. "A private owner is not an operator" is wrong.
Standing trees as such are outside the regulation (point 3.12). The product comes into existence at harvest, and the operator is whoever owns the logs at that moment. If the contract makes the buyer of the felling area (cirsma) the owner of the harvested wood automatically, the buyer is the operator. If the contract or national law transfers ownership to the buyer only after harvesting, the forest owner remains the operator.
Hence the practical rule: the answer lies in the wording of the contract, not the size of the plot. Reread the clause on transfer of ownership of the timber before you sign.
- You sell standing timber (cirsma), the buyer fells and owns the logs at once — the buyer is the operator and files the declaration or DDS.
- You harvest yourself or through a contractor and sell assortments at the roadside — you are the operator.
- You sell the land with the forest on it — land is not on the regulation's product list and standing trees are outside its scope, so the sale itself creates no EUDR obligation.
If you are the operator: the simplified declaration
The 2025 amendment created the category of "micro or small primary operator": a natural person, or a micro or small undertaking, established in a low-risk country and selling products it has grown or harvested itself. Size is assessed under Directive 2013/34/EU. According to the Ministry of Agriculture, the small-undertaking ceiling means exceeding no more than one of three limits: balance sheet total EUR 5 million, net turnover EUR 10 million, 50 employees. A private owner acting in good faith does not have to prove their size separately (FAQ, point 3.26).
Such an operator does not file a DDS for each consignment. It files a simplified declaration in the EU Information System once, before the first sale, and receives a declaration identifier (Article 4a of the regulation). That identifier must be passed to the buyer. The declaration need not be updated when quantities change. If new plots are added, it is worth updating them, and the actual places of harvest must be documented (FAQ, point 3.27).
The regulation also allows the state to make the information available on the producer's behalf where everything required already sits in national registers (Article 4a(4)). Whether Latvia will do this for forest owners is not stated on the ministry's page as of 24.09.2026. Check it before your first sale after 30 December.
- Who is filing: name and address; an EORI number if the goods are imported or exported.
- What you sell: the product code, a description, and a one-off estimate of annual quantity.
- Where it was harvested: the country and the geolocation of all plots — or their postal address or cadastral details.
- A statement that you exercise due diligence and sell only where no risk, or only a negligible risk, of non-compliance is found.
One date: 30 December 2026
The general scheme is that the regulation applies from 30.12.2026, and from 30.06.2027 for natural persons and micro and small undertakings. But the provision carries an exception: the deferral does not apply to products listed in the annex to the old Timber Regulation (EU) No 995/2010 (Article 38(3)). Roundwood (code 4403) and fuel wood (4401) are in that annex.
So for timber there is one date for everyone: 30 December 2026. The Commission confirmed it on 13 July 2026: the regulation applies from 30.12.2026 to large and medium operators and to micro and small operators already covered by the Timber Regulation. Do not rely on the general line that "small operators start in mid-2027" — it holds for beef or soy, not for wood.
Coordinates: when you need them and which kind
A full statement (DDS) is filed by an operator outside the simplified regime — for example a medium or large harvesting company that bought your standing timber. It needs the geolocation of every plot the wood came from. In a simplified declaration, geolocation may be replaced by a postal address or cadastral details, provided they identify the plot unambiguously (FAQ, point 3.28).
The operator is responsible for the accuracy of the coordinates even when the owner supplied them (points 1.11 and 1.12). You help the buyer by assembling in advance what describes the felling site: the cadastre number, the block and compartment (nogabals) numbers, the felling-area sketch, and the felling confirmation (ciršanas apliecinājums) issued by the State Forest Service (Valsts meža dienests, VMD). Your forest inventory data with the stand plan can be downloaded free of charge from the VMD e-services portal (sign in via Latvija.lv); the service has no fixed processing term.
The MezaData EUDR passport helps prepare the plot data. It is free, with no sign-up and no email. Enter the felling confirmation number and the passport takes the exact felling-area boundaries from VMD's public permit service; or enter the cadastre number and tick the compartments. You get a page with the register details, the share of forest cover on 31.12.2020 from the EU reference map JRC GFC2020, and one GeoJSON file in the EU format to hand to the buyer: each separate part of a plot is its own polygon. The page can be printed or saved as PDF, and its link stays valid for 5 years — save it, because we do not send it by email. Timber buyers with an account can, on request, paste a list of permit and cadastre numbers and get all the passports in one ZIP archive.
The limits matter. In permit mode the boundary is the felling area, but species and register signals describe the whole compartment; in cadastre mode the file describes whole compartments, and a felling-area boundary may not coincide with them. The register data is VMD open data, refreshed quarterly; the GFC2020 map is EU reference data and not legally binding. The passport shows register facts but does not certify compliance and does not replace the declaration — the operator files that and answers for it.
- A plot of more than 4 ha needs a polygon: perimeter points to six decimal places.
- A plot of less than 4 ha may be given as a single point; a polygon is optional.
- The plot must describe the actual place of harvest, not the whole cadastre.
What the buyer will ask you for
A sawmill or trader buying wood that an operator has already placed on the market is a downstream operator or trader. It files no statements; large ones (those that are not SMEs) must additionally register in the Information System. Its duty is to keep details of the supplier and the number under which the product was declared: the DDS reference number or the simplified-declaration identifier (FAQ, point 3.4).
Passing that number on is the operator's obligation. If you are the operator, the buyer will expect the identifier with the first delivery after 30 December; knowing its supplier is an operator, it may not place the wood on the market without it. If the buyer of the felling area is the operator, all it needs from you is the documentation for the plot.
Enforcement and fines
Penalties are set by each member state. The regulation fixes a floor for the ceiling: the maximum fine for a legal person may not be lower than 4 % of its annual EU-wide turnover (FAQ, point 10.2). We do not quote Latvian amounts here — check them against the legislation in force.
According to the Ministry of Agriculture, the State Forest Service (VMD) will continue as the competent authority for timber in Latvia, as it was under the old Timber Regulation. Checks focus on operators; downstream links are checked only on the supplier details and numbers they have kept.
What to do before 30 December
Timber sold before 30 December 2026 follows the old rules. Anything harvested and sold after that date falls under EUDR. If felling is planned for the winter, prepare now.
- Establish who the operator is: find the contract clause on transfer of ownership of the harvested timber.
- If it is you — register in the EU Information System and file the simplified declaration before the first sale; first check the ministry's page in case the state files it for you. Registration in the system (TRACES) has been open since 6 November 2024; test submissions go to a separate ACCEPTANCE environment that needs its own registration.
- If it is the buyer — ask which regime it applies and what plot data it needs.
- Assemble the plot file: cadastre number, compartment numbers, felling-area sketch, felling confirmation.
- If part of the forest was converted to agricultural land after 31.12.2020, timber from that area cannot be sold — clarify the position with VMD before felling.
FAQ
I am a private individual and sell timber once every twenty years. Does this apply to me?
Yes, if you are the one selling the wood rather than the buyer of the felling area. The regulation covers natural persons acting in the course of a commercial activity. But the simplified regime applies to you: one declaration, no risk assessment. The quantity in it is estimated for the years in which a sale actually takes place (FAQ, point 3.30).
I am selling a felling area to a company. What is required of me?
If the contract makes the company the owner of the logs at the moment of harvesting, the company is the operator. What it needs from you is accurate plot data and the documents showing the felling is legal. The company's size determines its regime: a small one files a simplified declaration, a medium or large one files full DDS.
Do I have to measure the coordinates myself?
Not for a simplified declaration: the regulation lets you give the postal address or cadastral details of the plot. Polygons are needed for a full DDS, and the operator answers for them. Coordinates can be taken with an ordinary phone or handheld receiver — the Commission expressly names that as an acceptable method (FAQ, point 1.1).
I felled after 2020. Is that a breach?
No, provided the land is still forest. The breach is selling timber from an area converted to agricultural use after 31.12.2020. Felling followed by regeneration, carried out under Latvian rules, does not conflict with EUDR: Article 21 of the Forest Law (Meža likums) requires the owner to regenerate the stand, and Cabinet Regulation No. 308, point 4, sets the deadline at five calendar years after the year of felling, or ten on wet site types.
Sources
- Regulation (EU) 2023/1115 — the EUDR base text (eur-lex.europa.eu) — definitions, operator obligations, penalties.
- Regulation (EU) 2025/2650 — the December 2025 amendment (eur-lex.europa.eu) — Articles 2(15a), 4a, 38 and Annex III: the simplified regime and the dates of application.
- Regulation (EU) No 995/2010 — the former Timber Regulation (eur-lex.europa.eu) — the annex listing codes 4401 and 4403.
- European Commission — "Frequently Asked Questions: Implementation of the EU Deforestation Regulation", version 5 — points 1.1, 1.11, 1.12, 3.1, 3.4, 3.12, 3.26, 3.28, 3.30, 10.2.
- European Commission — news of 13.07.2026 on the product scope and the Information System — confirmation of the dates of application.
- Ministry of Agriculture of Latvia — "ES Atmežošanas regula (EUDR)" — overview of the amendment, small-undertaking thresholds, access to the Information System.
- Meža likums — the Forest Law (likumi.lv) — Article 21: the duty to regenerate the forest.
- Cabinet Regulation No. 308 "Meža atjaunošanas, meža ieaudzēšanas un plantāciju meža noteikumi" (likumi.lv) — point 4: the regeneration deadline.
- Ministry of Agriculture of Latvia — answers to questions from industry — the definition of deforestation, low-risk status, VMD as the competent authority for timber.
Disclaimer
This text is not legal advice. It describes the regulation and the Commission's guidance as they stood on 4 October 2026; the national rules for applying them in Latvia may still be refined. Who the operator is in a particular deal depends on the terms of your contract — if in doubt, consult a lawyer or the State Forest Service.