About seven months remain until 30 December 2026. By that date, every supplier of Latvian timber into an EU supply chain must provide GPS coordinates of the harvest site and pass a due diligence procedure. Here is what this means for the private forest owner.
Important before you read
Important before you read. EUDR is an EU regulation, and its implementation details are still being refined by the Latvian Cabinet of Ministers and the European Commission. The dates of 30 December 2026 for large and medium operators and 30 June 2027 for micro and small operators are set in the current text of Regulation (EU) 2023/1115, but the specific procedures, DDS forms, and penalty schedules are being clarified by national rules and may change. All calculations and scenarios below are illustrative. Before signing any deal, verify the current requirements at eur-lex.europa.eu and through LVPR / VMD.
TL;DR
- EUDR (Regulation (EU) 2023/1115) is the European regulation against deforestation. It becomes binding for large and medium operators on 30 December 2026, and for micro and small operators on 30 June 2027. It covers timber, beef, coffee, cocoa, rubber, soy, and palm oil.
- For a private forest owner in Latvia, the practical effect runs through the supply chain: the buyer of your cirsma (a legal-entity operator, for example a sawmill or an exporter) must collect GPS coordinates of the harvest site, verify that the forest was not cleared after 31 December 2020, and submit a Due Diligence Statement (DDS) in EU TRACES.
- Without GPS coordinates and a confirmation that the stand does not breach EUDR criteria, the seller cannot place the timber with a legal-entity operator in the EU supply chain. In practice this is a de facto ban on selling cirsma to a commercial buyer without following the procedures.
- Operator size is determined by EU SME criteria (Commission Recommendation 2003/361/EC): employees, turnover, and balance sheet. The 30 June 2027 application date is a carve-out for microenterprise and small enterprise operators, assessed against those criteria, not against any prior EUTR registration. Most active forestry SIAs in Latvia exceed the SME thresholds and fall under the 30 December 2026 date.
- Penalties: up to 4% of the operator's annual EU turnover as a ceiling for cumulative infringements at EU level, not per consignment. The specific amount for any given infringement is set by Latvian national legislation within that ceiling.
- MezaData in this context can export the GPS extent of a forest compartment (using VMD polygonal geometry) as a ready-made DDS attachment, speeding up preparation for the buyer.
What EUDR is, in plain language
In May 2023 the European Union adopted Regulation (EU) 2023/1115, a law on mandatory due diligence to prevent deforestation and forest degradation in EU supply chains. The idea is straightforward: EU companies cannot import or produce certain commodities if they are linked to deforestation after 31 December 2020 (the cut-off date).
The regulation covers seven commodity groups:
For each product the operator (the entity that first places it on the EU market or produces it) must:
Each subsequent participant in the chain (trader, processor, retailer) must reference the operator's DDS and maintain the traceability chain.
- Timber and processed wood products (timber, furniture, paper).
- Beef and leather.
- Coffee.
- Cocoa.
- Rubber.
- Soy.
- Palm oil.
- Collect the geographic coordinates of the site where the raw material originated.
- Confirm that the site was not deforested after 31 December 2020.
- Confirm the legality of harvesting in the country of origin.
- Submit a Due Diligence Statement (DDS) to EU TRACES, the EU's single electronic customs-readiness system.
Who is affected in Latvia
In Latvia, EUDR applies to all forest-processing output that enters the EU chain. Given that Latvia is a net timber exporter (both inside and outside the EU), the regulation reaches almost every commercial player in the market.
The clear categories:
The simple rule for a private owner: if you sell cirsma to a legal entity, your buyer is an operator. For that buyer to legally resell the timber, you must hand over GPS coordinates of the harvest site and confirmation that the stand does not breach the cut-off (31 December 2020).
This is not your obligation under EU law, but without these inputs your buyer simply will not be able to purchase your cirsma after 30 December 2026.
- Large and medium SIA operators (LVM, Latvijas Finieris, Stora Enso Latvia, Metsä Latvia, Södra, and the larger local players): bound from 30 December 2026.
- Microenterprise and small enterprise operators (most local sawmills, private trading companies): bound from 30 June 2027.
- Private natural persons (forest owners): formally not "operators". But their timber will not reach the EU market unless the buyer has completed a DDS.
What a DDS is and what data it requires
A Due Diligence Statement is a formal document that the operator submits to EU TRACES before each consignment. Under the current form (which may still be refined) it contains:
For forest timber, the central element is the geographic coordinates of the harvest site. These take the form of either polygonal geometry (preferred for larger sites) or a point with a buffer (for small ones).
- Consignment identification: product type (HS code), quantity, weight or volume.
- Supplier and origin identification: country of harvest, geographic coordinates of the sites (polygons or point coordinates depending on commodity type).
- Chain of ownership: documents proving the right to harvest and sell (for forestry: the VMD extract and the cirsma contract).
- Legality confirmation: compliance with the national legislation of the country of harvest. In Latvia: the Forest Law (Meža likums), the Cabinet Regulations on felling, and VMD permits.
- "No deforestation" confirmation: the site was not cleared after 31 December 2020. The check is performed against satellite imagery, and the comparison is automated within the EU infrastructure.
- Risk assessment and mitigation: the operator must document how risks were assessed and which mitigation measures were taken.
GPS coordinates: the main technical hurdle
This is the hardest part for a private owner. A few practical questions:
Realistic ways to obtain coordinates:
What does NOT work:
- Which format: WGS84 lat/lon (ordinary GPS coordinates) or LKS-92 (the Latvian national system)? The regulation accepts both, but EU TRACES typically requires WGS84.
- Accuracy: the coordinates must be tied to the actual cirsma area, not to the cadastre as a whole. If your cadastre is 50 ha but cirsma covers 5 ha, the coordinates must describe those 5 ha, not the entire cadastre.
- Polygonal geometry: for sites of roughly 4 ha and above, the EU normally requires a polygon (a sequence of vertices), not a single coordinate. This is a problem if you have no geospatial data at hand.
- Data source: the optimal route is to use VMD forest-compartment polygons (they already exist in the state register). A private owner can obtain them through the VMD personal account or through a commercial request.
- Through VMD: request the compartment polygon through the personal account at vmd.gov.lv or directly at the territorial branch. Free of charge, but a 2 to 4 week wait.
- Through a professional forest surveyor: GPS measurement of the site perimeter tied to the cadastre boundary. €30–80 per site, 1 to 3 days.
- Through our platform: MezaData can export the compartment polygon by cadastre_id from VMD open data in a format ready to attach to a DDS. See the section below.
- A coordinate at the centre of the cadastre, with no link to a specific compartment, is unsuitable when cirsma covers only part of the cadastre.
- A coordinate from a smartphone GPS receiver: accuracy is 5–15 m, which may be acceptable for a site under 5 ha but is insufficient for anything larger.
- A textual description ("the forest near village X") is unsuitable; the regulation requires machine-readable coordinates.
Who falls under 30.12.2026 versus 30.06.2027
This is a critical detail that many SIA operators interpret incorrectly. The application date depends on the operator's size under EU criteria, not on the history of EUTR registration.
EU SME criteria under Commission Recommendation 2003/361/EC:
Application dates under EUDR (after the 2024 postponement):
The practical effect:
If your cirsma buyer is a large or medium SIA, they must comply with EUDR from 30 December 2026, and without a complete DDS package they cannot legally buy your cirsma. If they are small or micro, they have another six months of deferral, but the requirements themselves are the same. Either way, document preparation needs to start before the deal.
- Microenterprise: up to 10 employees, turnover ≤ €2M or balance sheet ≤ €2M.
- Small enterprise: up to 50 employees, turnover ≤ €10M or balance sheet ≤ €10M.
- Medium enterprise: up to 250 employees, turnover ≤ €50M or balance sheet ≤ €43M.
- Large enterprise: anything above the medium threshold.
- Large and medium operators: 30 December 2026.
- Microenterprise and small enterprise operators: 30 June 2027 (carve-out by SME definition).
- Active forestry SIAs in Latvia often have turnover in the €5–50M range and fall into the medium segment. Their date is 30 December 2026.
- Smaller sawmills with turnover up to €10M and up to 50 employees may qualify as small enterprises. They then have a deferral until 30 June 2027.
- Prior EUTR registration (Regulation (EU) 995/2010) does not automatically determine EUDR size. Size is always assessed against the operator's current financial indicators.
Penalties: a 4% ceiling on EU turnover
The regulation provides for sanctions on infringements. Under Article 25 of Regulation (EU) 2023/1115, Member States set effective, proportionate, and dissuasive sanctions, including:
The exact size of the fine in Latvia and the procedure for applying it are set by national rules. Verify the current text on likumi.lv and through LVPR / VMD.
For a private forest owner there is no direct EU sanction, because a natural person does not qualify as an "operator" under the regulation. But the indirect effect, namely the inability to sell cirsma, is practically equivalent to a ban on commercial activity.
- A fine with a ceiling of at least 4% of the offending operator's annual EU turnover. This is the ceiling for the cumulative set of infringements at EU level; the specific amount per infringement is set by Latvian national legislation within that ceiling.
- Confiscation of the consignment that does not comply with EUDR.
- A ban on placing the relevant products on the EU market until the infringement is remedied.
- Public disclosure of the infringement and of the offending company.
MezaData in the EUDR context
Our platform aggregates VMD data on all 3 million forest compartments in Latvia, including the polygonal geometry of every compartment. This creates a direct product engagement point with EUDR:
We are rolling this functionality into the seller workspace of the product step by step; the target completion date is Q4 2026, ahead of the main EUDR deadline.
- Export of the GPS polygon for the compartment: by cadastre_id you receive a GeoJSON or Shapefile polygon ready for upload as a DDS attachment in EU TRACES.
- Cut-off compliance check: verification that the compartment was not cleared after 31 December 2020 (through comparison of VMD releases).
- Inventory documentation: dates of the most recent VMD inspections for legality evidence.
- Cadastre-level summary: a single document for the whole cadastre, broken down by compartment, prepared for the buyer-operator.
What to do right now
In May 2026, about seven months remain until the main EUDR deadline. Practical steps for a private owner planning cirsma in 2026–2027:
- Check whether your buyer holds an EUTR registration and what their EUDR readiness looks like. If the buyer is not ready by 30 December 2026, they will face problems, and so will you.
- Pull together the documents for your cadastre: a fresh extract from the Land Book (Zemesgrāmata), a fresh VMD extract with inventory data, and a cirsma contract in standard form.
- Request the GPS polygon of the compartment from VMD (or wait for our feature release in the second half of 2026). Without a polygon, no DDS can be filed.
- Check that the stand has not been cleared after 31 December 2020. If felling took place on the site after that date, verify whether it fell under a permitted sanitary felling or planned felling with a regeneration obligation. If yes, that is a legal harvest and is not caught by the cut-off. If not, you have a problem.
- Deals where timber is placed on the EU market before 30 December 2026 are not caught by EUDR; the regulation is not retroactive. But "placing on the market" is not the date the cirsma contract is signed, it is the date of delivery to the final operator. If your cirsma is felled in December 2026 and only enters the EU market in February 2027, a DDS is already mandatory.
FAQ
I am a private natural person. Does EUDR apply to me directly?
No. EUDR applies to "operators", which are legal entities that first place a product on the EU market or export it. Natural persons are not operators. But the buyer of your cirsma is an operator, and without satisfying the requirements they cannot purchase your timber after the deadline.
What if I sell cirsma to another natural person rather than to an SIA?
Technically both of you remain outside EUDR obligations. But if that other natural person has no processing channel, they are unlikely to buy cirsma in commercial volumes. The real market for private cirsma is sales to SIA operators, and all of them are caught by EUDR.
What counts as "deforestation" under EUDR?
Conversion of forest to non-forest use (agricultural land, construction, infrastructure). Regular harvesting with regeneration is not deforestation, because the stand remains forest. A final felling with a mandatory regeneration obligation (under Forest Law (Meža likums) §11) is fully compatible with EUDR. The problem arises if you cleared forest after 31 December 2020 and did not regenerate it (for example, converted it to pasture), and now want to sell what is left.
Can I file a DDS before 30 December 2026?
Test registration in EU TRACES has been available since late 2024. Real DDS submissions only begin from the date of application. Until 30 December 2026, the simplified EUTR rules continue to apply.
What happens if a piece of freshly cleared forest shows up on my site in satellite imagery?
The EU uses Global Forest Watch and similar open datasets for verification. If satellite imagery shows forest-cover loss at your site coordinates after 31 December 2020, that is an automatic red flag. Your buyer-operator cannot legally file a DDS and will not buy the cirsma. If the loss occurred under a lawful harvest with a regeneration obligation, that is documented through a Forest Law (Meža likums) permit and the DDS clears. If the loss is illegal, you already have a problem under Latvian law, and EUDR will only make it worse.
Sources
This text is not legal or regulatory advice. EUDR is a complex regulation whose requirements are still being refined by European Commission acts and Latvian national legislation. Before making business decisions, consult a licensed EU-law adviser and/or your industry association. All dates, fines, and procedures cited above are stated as of the date of writing (May 2026) and may change.
- Regulation (EU) 2023/1115 — main EUDR text (eur-lex.europa.eu).
- Regulation (EU) 995/2010 — EUTR, the previous regulation (eur-lex.europa.eu).
- EU TRACES — DDS submission system (traces.ec.europa.eu).
- European Commission implementation guidance — DG ENV, 2024–2026 updates.
- Forest Law (Meža likums) (likumi.lv) — the Latvian legislation referenced by the legality requirement.
- VMD — geospatial data on forest compartments and inventories (vmd.gov.lv).
- Global Forest Watch — open data on deforestation (globalforestwatch.org).
- LVPR (Latvijas Valsts mežu padome) — sector guidance on EUDR readiness.