Guides / Choosing a Supplier
EUDR Due Diligence for Sawmills: The Geolocation and Log Data to Collect Now
February 15, 2027
An EU buyer who places hardwood lumber on the EU market has to file a due diligence statement, and the statement needs data that only the mill has: the species, the net weight, the country of production, the geolocation of every plot where the logs were harvested and the harvest dates. A sawmill outside the EU is usually not the filer, but it is the only party that can supply that data, and the request lands on the mill first. This guide is for sawmills, yards and exporters. It lists what to collect, shows how to record it at log intake and explains where the hard part is for hardwood: one load of lumber can come from logs harvested on many different properties.
This is general information as of October 2026, not legal advice. Our guide to EUDR for hardwood lumber buyers covers the buyer side. Confirm your own role and deadline with a customs broker or counsel before you rely on anything here.
Dates and roles in short
The Commission’s EUDR page gives these application dates: 30 December 2026 for large and medium operators, 30 June 2027 for micro and small operators and 30 December 2026 for micro and small operators already covered by the old EU Timber Regulation. In May 2026 the Commission published a simplification review package, with updated guidance and FAQs, that prepares for the regulation to apply by the end of this year. Check the Commission pages for any later change.
The roles come from Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650:
- An operator places relevant products on the EU market or exports them from it. The operator exercises due diligence and submits the statement. The reference number of the statement then travels down the chain.
- Downstream operators and traders collect and keep supplier and customer details and the reference numbers they receive. They do not submit their own statement.
- A mill outside the EU is none of these by itself. It supplies the information to its EU customer. If you place lumber on the EU market yourself, you are an operator and the rest of this guide applies to you directly.
What the regulation asks for
Article 9(1) lists the information an operator must collect, organize and keep for five years, accompanied by evidence. For sawn hardwood the items that reach your mill are:
| Item | What it means for a mill |
|---|---|
| Description, with the common name of the species and its full scientific name | Genus and species for every line, not “oak” |
| Quantity | Net mass in kilograms when the product enters or leaves the EU market, and the supplementary unit of the customs tariff where one applies. Board feet or cubic meters are not enough |
| Country of production, and parts of it where relevant | Where the logs were grown, not where you sawed them |
| Geolocation of all plots of land where the wood was produced, and the date or time range of production | One entry per plot, with harvest dates |
| Names and addresses of your suppliers and customers | Your log suppliers, with the email address |
| Evidence the wood is deforestation-free | Wood harvested without inducing forest degradation after 31 December 2020 |
| Evidence the wood was produced under the laws of the country of production | Harvest permits, land rights or contracts where they apply |
Two definitions matter for a hardwood mill. A plot of land is land within a single real-estate property, as recognized by the law of the country of production, with sufficiently homogeneous conditions. So logs from three properties are three plots. Geolocation is latitude and longitude with at least six decimal digits, and plots larger than four hectares must be given as polygons that describe the perimeter. The EU Information System accepts coordinates in bulk as a GeoJSON file and has an API for machine-to-machine submission, so keep your data in a form that can be exported that way.
Why hardwood is hard
A veneer or plywood plant buys logs from known stands. A hardwood sawmill often buys from many sellers, mixes logs in a yard and dries boards from different lots in one kiln charge. The Wisconsin Department of Natural Resources forest products specialist wrote in February 2026 that geolocation is the single biggest compliance challenge for US hardwood, that a shipment could contain wood aggregated from hundreds or thousands of properties and that the supply chain was not built to segregate wood from small properties through the mill. Whether or not that matches your mill, it is the question your buyer will ask.
Low-risk status does not remove the work. The Commission’s country list in Implementing Regulation (EU) 2025/1093 includes the United States among the low-risk countries. Under Article 13 an operator whose wood all comes from low-risk countries does not have to carry out the risk assessment and mitigation steps of Articles 10 and 11, but it still has to collect the Article 9 data and must be able to show that the risk of mixing with wood of unknown or higher-risk origin is negligible. AHEC made the same point on a 2024 page: geolocation applies irrespective of the level of risk.
Mixing is also a stated risk criterion for the inspectors. The amended Article 16 tells competent authorities to take into account the complexity and length of supply chains, “including whether mixing of relevant products is involved”. A mill that can show lots staying separate has an easier time.
What to record at log intake
The regulation sets what must be collected, not how a mill does it. This is a practical layout, not a legal requirement:
- One record per log delivery. Date, supplier name, address and email, truck or ticket number, species (common and scientific name), number of logs, volume and net weight from the scale.
- Origin of that delivery. Harvest location as coordinates or a polygon for each property, the harvest start and end dates and the country. If the supplier cannot give a polygon, ask for the property identifier and a map that you can convert.
- Legality papers. Whatever your jurisdiction uses to show the harvest was lawful: permits, contracts, deeds or landowner consent. Scan and file them with the delivery record.
- A lot number. Give every delivery or pile a lot number, and write it on the sawing and drying records.
- Lot to bundle link. Record which lots went into which kiln charge and which bundle tags, so a bundle on a tally sheet maps back to its lots. Our guide to writing a lumber tally sheet shows where bundle tag numbers sit on the paperwork.
- Weight at shipment. Container and bundle weights for the shipping documents, so the net mass the buyer reports is a measurement and not a guess.
- Retention. Keep all of it for at least five years, and longer if a buyer asks.
If lots from different properties are mixed in one bundle, say so on the record and give the geolocations of all the lots in it. The operator has to cover every plot in the shipment. Hiding a mix does not help, since the data has to match the wood.
What exists for US mills
The American Hardwood Export Council (AHEC) and its members run American Hardwood Assured (AHA), a platform for US companies. A Hardwood Floors magazine article from August 2025 describes it as providing deforestation-free due diligence statements with county-level harvest origin data, free of charge through at least 2027, with registration open only to US companies with an EIN. The Wisconsin DNR article says AHA treats a statewide risk assessment as adequately conclusive and verifiable information in place of individual harvest-site documents.
Treat that as an industry position, not a settled EU ruling. I found no EU source saying that county-level data satisfies the plot-level geolocation rule, and the trade article does not address EU acceptance either. Ask the EU operator you supply whether it will accept AHA statements for its filing, and get the answer in writing before you rely on it. An AHEC page from March 2024, since dated, reported that a pilot of the EU Information System accepted at most 200 geolocations per entry and that some US consignments could have a thousand or more. Check the current limit with your buyer’s compliance contact.
Answering a buyer’s data request
- Say what you can document today. A sample record for one real past shipment is worth more than a promise. Do not describe your records as complete when they cover only some suppliers.
- State the unit you can supply. Net kilograms from scale tickets, plus board feet or cubic meters for the commercial invoice, with the conversion method written down.
- Offer the data as a file. A spreadsheet with one row per lot and a GeoJSON file for plots is easier to load than a PDF.
- Say what you cannot yet do. If a log supplier cannot give coordinates, say so and say what you are doing about it. The buyer will find out anyway at filing time.
- Keep the paperwork consistent. The species name on the data sheet, the tally and the invoice should match. Our guide on what a sawmill should publish for export buyers covers the other fields buyers look for before they ask.
The plant health papers and legal timber declarations are separate from EUDR data. See our guide to phytosanitary and fumigation rules for the plant health side.
Next step
If you sell hardwood lumber to buyers who ask for traceability data, register your mill or yard. Tell us the species and grades you sell, your drying and tally basis, the papers you can issue and whether you can supply plot-level origin data. We pass a buyer’s spec to you only when it fits. Each request goes to 3 suppliers at most and the buyer deals with you directly. We reply within 24 business hours, and we make no promise of orders.
Sources
- Regulation (EU) 2023/1115 on deforestation-free products, EUR-Lex
- Regulation (EU) 2025/2650 amending the EUDR, EUR-Lex
- Implementing Regulation (EU) 2025/1093, country classification, EUR-Lex
- European Commission, deforestation-free products regulation page and EUDR Information System page
- Transition Pathways, Commission publishes simplification review of the EU Deforestation Regulation
- Wisconsin DNR Forestry News, EUDR update and the hardwood industry (February 2026)
- AHEC, EUDR latest developments (page dated March 2024)
- Hardwood Floors magazine, AHEC launches deforestation-free tool (August 2025)
Frequently asked questions
Does a sawmill outside the EU file the EUDR due diligence statement?
Usually not. The operator who places the lumber on the EU market files it, which is normally your EU buyer. But that buyer cannot file without your data, so the mill supplies species, quantity, country, plot geolocation and harvest dates. An EU mill that sells on the EU market is an operator itself.
How precise must EUDR geolocation be?
The regulation defines geolocation as latitude and longitude with at least six decimal digits. For a plot of land larger than four hectares, it must be given as a polygon with enough points to describe the perimeter. The EU Information System accepts coordinates in bulk as a GeoJSON file.
Does low-risk country status remove the geolocation requirement?
No. For operators, low-risk origin removes the risk assessment and mitigation steps in Articles 10 and 11 of the regulation, but the Article 9 data, including geolocation, is still collected. The United States is on the Commission's low-risk list in Implementing Regulation (EU) 2025/1093.
How long should a mill keep EUDR records?
The regulation makes operators keep the Article 9 information for five years from placing on the market or export, and traders and downstream operators keep supplier information for five years. Ask each EU buyer what it needs from you and keep your log intake and lot records at least that long.
Know what you need? Send the spec.
Tell us the species, grade, thickness and board feet. We pass it to up to 3 mills or yards that carry it and reply within 24 business hours.
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