Companies that spent a decade complying with the EU Timber Regulation keep asking the same question: how much of our EUTR system survives? The honest answer is the skeleton survives and almost every load-bearing part changes. This guide is the precise comparison, so you can reuse what is reusable and stop trusting what is not.
The two regulations in one table
| EUTR (995/2010) | EUDR (2023/1115) | |
|---|---|---|
| Scope | Timber and timber products | Cattle, cocoa, coffee, oil palm, rubber, soya, wood, plus derived products in Annex I |
| Core test | Legally harvested | Deforestation-free after 31 Dec 2020 and legally produced |
| Location data | Country (sometimes region/concession) of harvest | Coordinates of every plot; polygons above 4 ha |
| Output | Internal due diligence records | A DDS filed in TRACES per placing, with reference numbers at customs |
| Downstream | Traders keep buyer/seller records | Downstream operators and traders keep DDS references and supplier/customer records for 5 years |
| Country tiers | None | Low / standard / high benchmarking with 1/3/9% check quotas |
| Penalties | National, uneven | Harmonised floor: fines up to at least 4% of EU turnover, confiscation, exclusions |
The changes that actually bite
Geolocation is the operational revolution. Under EUTR, "Sweden, spruce, these mills" was a defensible origin claim. Under EUDR the DDS carries the harvest-plot coordinates, which means your supplier questionnaires become data pipelines. Deforestation-free is a second, independent test. Perfectly legal harvest fails EUDR if it converted natural forest to plantation after the cutoff, a degradation rule unique to wood. And the filing is public infrastructure: EUTR files lived in your drawer until an authority knocked; a DDS is submitted before every placing, checkable by anyone you pass the numbers to.
What genuinely carries over
- The three-step due diligence habit (information, risk assessment, mitigation): EUDR's Articles 9 to 11 are recognisably EUTR's Article 6 grown up. Your assessment discipline transfers; its inputs expand. See the risk assessment guide.
- Species documentation: scientific names were EUTR practice and remain mandatory on wood statements.
- Supplier legality files: export permits, harvest licences and management plans remain the legality evidence, now joined by geometry.
- FLEGT licences: still recognised, more narrowly. A valid licence satisfies EUDR's legality limb for the timber it covers, but not the deforestation-free test, the geolocation or the DDS. Indonesian timber is where this matters most.
Timing and the transition
EUDR entered into force on 29 June 2023 and, after two postponements, applies from 30 December 2026 (30 June 2027 for micro and small enterprises). EUTR remains the applicable regime for timber until EUDR takes over, and wood harvested before EUDR's entry into force keeps EUTR treatment for a transitional period rather than escaping regulation. Practically: run your EUTR system to the handover date, and build the EUDR dataset in parallel now, because plot geometry for the 2026-27 shipping season has to be collected during 2026.
The trap in "we already do EUTR"
EUTR conditioning teaches that a good paper file is the finish line. EUDR moves the finish line to verifiable geometry: authorities can re-screen your declared plots against satellite archives without asking you anything, and the penalty framework assumes they will. Treat your inherited "low risk" supplier list as the first thing to re-verify with coordinates, not the last: risk under the old regime was scored on paperwork, and paperwork is exactly what geolocation was invented to check.