About seven months are left before December 30, 2026. By that date every Latvian timber seller into the EU supply chain will need GPS coordinates of the felling site and a completed due diligence statement. What that means for a private owner.
EUDR: 7 months to the deadline
The EU Deforestation Regulation (EUDR, Regulation 2023/1115) takes effect for large and medium operators on December 30, 2026. For micro and small operators, the date is June 30, 2027. A private forest owner is not formally an "operator" and faces no direct EUDR sanctions. However, every legal entity buying cirsma in Latvia is an operator — and after that date cannot purchase timber without GPS coordinates of the felling site and confirmation that the forest was not cleared after December 31, 2020. In practice, this is a prerequisite for the sale itself. Fines for operators run up to 4% of annual EU turnover (Regulation 2023/1115, Article 25).
Key takeaways
- EUDR deadline for large and medium operators: 30.12.2026; for small and micro: 30.06.2027.
- Private owners are not operators, but without a GPS polygon the cirsma buyer cannot file a DDS.
- Request the VMD stand polygon now — processing takes 2-4 weeks.
- Cut-off date: 31.12.2020 — the forest must not have been cleared after this date without legal replanting.
- Fine ceiling for operators: up to 4% of annual EU turnover (Regulation 2023/1115, Article 25).
What is EUDR in plain language?
In May 2023 the EU adopted Regulation 2023/1115, a mandatory due diligence law to prevent deforestation and forest degradation in supply chains. It bars EU companies from placing on the market any goods linked to deforestation after December 31, 2020 (the cut-off date). Latvia, as a net timber exporter, sits directly in the regulation's scope.
The regulation covers seven product groups: timber and timber products (lumber, furniture, paper), beef and leather, coffee, cocoa, rubber, soy, and palm oil. Timber is the only group that directly affects Latvian forest owners.
For each product, the operator — the entity that first places goods on the EU market or produces them — must collect the geographic coordinates of the source plot, confirm no deforestation after the cut-off date, confirm legal compliance in the country of harvest, and submit a Due Diligence Statement (DDS) in EU TRACES. Every subsequent participant in the chain references the operator's DDS and maintains traceability.
Regulation 2023/1115 requires a mandatory Due Diligence Statement in EU TRACES before each timber consignment placed on the EU market. The fine ceiling for violations is at least 4% of the operator's annual EU turnover (Article 25, Regulation 2023/1115, eur-lex.europa.eu, 2023).
Who is affected in Latvia?
Latvia is a net timber exporter, both to the EU and beyond. That means the regulation reaches nearly every commercial market participant, and private forest owners can't stay on the sidelines even though they're not formally operators (European Commission EUDR implementation guidance, DG ENV, 2024).
The clear categories by operator size:
The simple rule for a private owner: if you sell cirsma to a legal entity, your buyer is an operator. To resell the timber legally, that buyer needs your GPS coordinates and a cut-off confirmation from you. That's not your obligation under EU law — but without those inputs, the buyer simply can't purchase your cirsma after December 30, 2026.
- Large and medium SIA operators (LVM, Latvijas Finieris, Stora Enso Latvia, Metsä Latvia, Södra and larger local players) — obligation from December 30, 2026.
- Micro and small operators (most local sawmills, private resellers) — from June 30, 2027.
- Operators already registered under EUTR (995/2010) — the date is December 30, 2026 regardless of size. EUTR registration carries over to EUDR. This applies to virtually all SIA structures with forestry activity that existed before 2020.
- Private individual owners — not formally operators. But their timber won't reach the EU market unless the buyer has completed the DDS.
DDS and the data it requires?
The Due Diligence Statement is a formal document the operator submits in EU TRACES before each consignment. It's not a free-form letter: its structure is governed by the annex to Regulation 2023/1115, with the form being refined by the European Commission. In its current form, the DDS contains several mandatory sections.
Consignment identification: HS code, quantity, weight or volume. Origin identification: country of harvest and geographic coordinates of the plots — polygons or points depending on the product type. Chain-of-custody documents: for forestry, a VMD certificate and cirsma contract. Legal compliance confirmation: in Latvia this means Meža likums, Cabinet Regulations on felling, and VMD permits. No-deforestation declaration: verification that the plot was not cleared after December 31, 2020 — checked against satellite imagery, automated in EU infrastructure. Risk assessment: documentation of mitigation measures.
For timber, the central component is the geographic coordinates of the source plot. These are either polygon geometry (preferred for larger plots) or a point with a buffer (for smaller ones).
GPS coordinates — the main technical hurdle?
GPS coordinates are where most private owners run into trouble. A cadastre centroid won't do: you need the actual polygon of the cirsma site. For larger plots of around 4 ha or more, the EU typically requires a polygon (a sequence of points), not a single coordinate.
Four practical issues to understand:
- Format. WGS84 lat/lon (standard GPS coordinates) or LKS-92 (Latvia's national system)? The regulation accepts both, but EU TRACES typically requires WGS84.
- Precision. Coordinates must be tied to the actual cirsma site, not the wider cadastre. If the cadastre is 50 ha but the cirsma is on 5 ha, coordinates cover those 5 ha, not the whole cadastre.
- Polygon geometry. For sites of around 4 ha or more, the EU typically requires a polygon, not a single coordinate. This is a real problem if you don't have geospatial data.
- Data source. The optimum is VMD stand polygons, which already exist in the state register. A private owner can request them through the VMD personal cabinet or via a commercial request.
There are three realistic paths to getting coordinates. Through VMD: stand polygon request via the vmd.gov.lv personal cabinet or directly at the regional branch — free, but with a 2-4 week wait. Through a professional forest surveyor: GPS perimeter survey tied to cadastre boundaries — 30-80 EUR per site, 1-3 days. Through MezaData: stand polygon export by cadastre_id from VMD open data in DDS-ready format.
What doesn't work: a cadastre centroid with no link to the stand (unsuitable for cirsma covering part of a cadastre), a phone GPS reading (5-15 m precision, insufficient for larger sites), or a verbal description ("the forest near village X") — the regulation requires machine-readable coordinates.
Who falls under 30.12.2026, who under 30.06.2027?
This is the detail many SIA operators get wrong. The application date depends on operator size under EU criteria, not on EUTR registration history. Active forestry SIAs in Latvia often have turnover of 5-50 million EUR and land in the medium band, which means December 30, 2026 is their date (Recommendation 2003/361/EC).
EU SME criteria under Recommendation 2003/361/EC fall into four bands:
- Microenterprise — up to 10 employees, turnover or balance sheet total no more than 2 million EUR.
- Small enterprise — up to 50 employees, turnover or balance sheet total no more than 10 million EUR.
- Medium enterprise — up to 250 employees, turnover no more than 50 million EUR or balance sheet total no more than 43 million EUR.
- Large enterprise — anything above the medium threshold.
Under EUDR, large and medium operators begin applying the regulation on December 30, 2026; micro and small on June 30, 2027. Smaller sawmills with turnover up to 10 million EUR and fewer than 50 employees may fall into the small band and gain a window until June 30, 2027.
A prior EUTR registration (995/2010) does not automatically determine EUDR sizing — sizing is always assessed against current financial figures. If your cirsma buyer is a large or medium SIA, they must comply with EUDR from December 30, 2026, and without a complete DDS package they cannot legally buy your cirsma.
Under Recommendation 2003/361/EC, a medium enterprise in Latvia has up to 250 employees and turnover up to 50 million EUR. Active forestry SIAs frequently fall in this band, meaning their EUDR deadline is 30.12.2026, not 30.06.2027 (Recommendation 2003/361/EC, eur-lex.europa.eu, 2003, applied in the EUDR context 2026).
Sanctions and the fine ceiling
Under Article 25 of Regulation 2023/1115, member states must set effective, proportionate, and dissuasive sanctions. These include a fine with a ceiling of at least 4% of the operator's annual EU turnover — that ceiling applies to the aggregate of violations at EU level, while the specific amount per violation is set by Latvian national law within that ceiling.
Other sanctions include confiscation of the consignment, a ban on placing the affected products on the EU market until the violation is remedied, and public disclosure of the violation and the offending company. The exact penalty in Latvia and the procedure for applying it are defined in national rules — check the current text on likumi.lv and LVPR or VMD bulletins.
For a private forest owner, no direct EU sanction applies, because an individual is not an "operator" under the regulation. The indirect effect, being unable to sell cirsma, is functionally equivalent to a ban on commercial activity.
MezaData in the EUDR context
MezaData aggregates VMD data on all roughly 3 million stands in Latvia, including the polygon geometry of each stand. That creates a direct product connection to EUDR requirements.
Planned features in seller mode:
We're rolling this out incrementally in seller mode; the final readiness target is Q4 2026, ahead of the main EUDR deadline.
- Stand GPS polygon export: by cadastre_id you receive a GeoJSON or Shapefile polygon, ready to upload as a DDS attachment in EU TRACES.
- Cut-off compliance check: verification that the stand was not cleared after 31.12.2020, via VMD release-to-release comparison.
- Inventory documentation: dates of the most recent VMD walkthroughs, supporting the legality confirmation.
- Cadastre-level summary: a single document for the whole cadastre with a per-stand breakdown for the operator buyer.
What to do now?
In May 2026, about seven months remain to the main EUDR deadline. For a private owner planning a cirsma transaction in 2026-2027, there are five concrete steps.
Check your buyer's readiness. Ask whether they have an EUTR registration and whether their DDS filing process is in place. If the buyer isn't ready by December 30, 2026, the problem starts on their side and indirectly affects yours.
Pull together the cadastre paperwork. You'll need a current Zemesgrāmata extract, a current VMD certificate with inventory data, and a cirsma contract in standard form.
Request the stand GPS polygon through VMD, or wait for the MezaData feature release in the second half of 2026. Without a polygon, the DDS cannot be filed.
Verify the cut-off status. If felling occurred on your site after 31.12.2020, check whether it was permitted sanitary or planned felling with replanting. If yes — that's legal harvest and falls outside the cut-off scope. If no — there's a problem.
A critical timing nuance: "placing on the market" is not the date the cirsma contract is signed, it's the delivery date to the final operator. If your cirsma is felled in December 2026 but reaches the EU market in February 2027, the DDS is already mandatory. Transactions where timber reaches the EU market before December 30, 2026 are not subject to EUDR.
FAQ
I'm a private individual. Does EUDR apply to me directly?
No. EUDR applies to "operators" — legal entities that first place a product on the EU market or export it. Individuals are not operators. But your cirsma buyer is an operator, and without meeting the requirements they cannot buy your timber after the deadline.
What if I sell cirsma to another individual instead of an SIA?
Technically both of you stay outside EUDR obligations. But if the other individual has no processing channel, they're unlikely to buy cirsma at commercial volume. The real market for private cirsma is sale to SIA operators, and they all fall under EUDR.
What counts as "deforestation" under EUDR?
Conversion of forest to non-forest use: agriculture, construction, infrastructure. Regular harvest with replanting is not deforestation, because the site remains forest. Main felling with mandatory replanting under Meža likums § 11 is fully compatible with EUDR. The problem arises if you cleared a site after 31.12.2020 and didn't replant (turning it into pasture, for example), and you're now selling what remains.
Can a DDS be filed before December 30, 2026?
Test registration in EU TRACES has been available since the end of 2024. Real DDS submissions only start from the application date. Until December 30, 2026, the simplified EUTR rules remain in force.
What happens if satellite imagery shows freshly cleared forest on my site?
The EU uses Global Forest Watch and similar open data for verification. If the satellite record shows forest cover loss on your coordinates after 31.12.2020, that's an automatic red flag. The operator buyer cannot legally complete the DDS and won't buy the cirsma. If the loss occurred within legal harvest with replanting, it gets documented via the Meža likums permit and the DDS will pass. If the clearance was unlawful — you already have a problem under Latvian law, and EUDR will compound it.
Sources
- Regulation (EU) 2023/1115 — EUDR primary text (eur-lex.europa.eu).
- Regulation (EU) 995/2010 — EUTR, the prior regulation (eur-lex.europa.eu).
- EU TRACES — DDS submission system (traces.ec.europa.eu).
- European Commission DG ENV implementation guidance, 2024-2026 updates.
- Meža likums (likumi.lv) — Latvian legislation referenced by the legality requirement.
- VMD — stand geographic data and inventory (vmd.gov.lv).
- Global Forest Watch — open deforestation data (globalforestwatch.org).
- LVPR (Latvijas Valsts mežu padome) — industry guidance on EUDR readiness.
Disclaimer
This article is not legal or regulatory advice. EUDR is a complex regulation whose requirements are being refined by European Commission and Latvian national rules. Before making business decisions, consult a licensed EU law adviser or your industry association. All dates, fines, and procedures cited here reflect the state of knowledge at the time of writing (May 2026) and may change.