A supplier questionnaire screens the factory; the EUDR asks about the wood

Oct 27

5 min read

Updated: 4 days ago

Most timber and wood-product importers send their suppliers a questionnaire each year. It comes back with certificates attached. It goes in a file. It was built to screen factories, and it does that reasonably well.

The EU Deforestation Regulation (EUDR) asks a different question. Where was the wood in this product grown, and can you show the plot was not deforested after 31 December 2020? A questionnaire almost never answers that.

The date is now fixed, after some wavering. Under the amending Regulation (EU) 2025/2650, published in the Official Journal on 23 December 2025, the EUDR applies from 30 December 2026. It covers large and medium-sized operators, and micro and small operators already covered by the EU Timber Regulation. Other micro and small operators follow on 30 June 2027. In its review of 4 May 2026 the Commission said there would be no further delay. Businesses that place wood on the EU or Northern Ireland market, or supply those that do, have until 30 December.

Britain is exposed on three fronts

The UK depends on imported wood. Forest Research's Forestry Facts and Figures 2025, drawing on FAO data, ranks the UK as the world's second-largest net importer of forest products in 2023. In 2024 the UK imported 6.3 million cubic metres of sawnwood worth £1.8bn. It imported 3.1 million cubic metres of wood-based panels worth £1.2bn.

The EUDR reaches UK businesses in three ways. Under the Windsor Framework it applies in Northern Ireland from 30 December 2026, phased in the same way as in the EU. EU customers will need data from their UK suppliers to file their own statements. And in Great Britain, Defra announced on 23 June 2026 that it will bring in its own rules under Schedule 17 of the Environment Act 2021.

Those rules will cover businesses with turnover above £1m. They will follow the EUDR's due diligence and geolocation requirements. At first they will target only deforestation that is illegal in the producing country. A consultation is due later in 2026, and legislation in 2027. The UK Timber Regulations continue to apply in Great Britain meanwhile.

The statement concerns the goods, not the supplier

A questionnaire asks whether a supplier is legitimate, certified and well run. The information behind a due diligence statement is about specific goods. Under Article 9 the operator must hold, for each product:

a description, including for wood the common and scientific name of the species;
the quantity and the country of production;
the geolocation of every plot of land where the wood was harvested, as a single point for plots of 4 hectares or less and as a polygon above that, to six decimal places;
the date or time range of harvest;
the suppliers and customers involved; and
verifiable evidence that the wood is deforestation-free and was harvested legally under the producing country's laws.

The information must be kept for five years. Penalties are set by member states. The regulation, though, requires maximum fines of at least 4% of a company's EU-wide annual turnover, alongside confiscation of goods and exclusion from public contracts. A forest certificate supports the risk assessment. It does not replace plot geolocation.

A certificate tells you about the factory. The statement has to tell you about the wood.

Lighter rules, but not for the first importer

The December 2025 amendment and the May 2026 review took a good deal of work out of the system. The Commission estimates annual compliance costs falling from €8.1bn to €2.0bn, about 75%. Most of that saving goes to businesses further down the chain. Downstream operators and traders no longer file their own statements. Only the first downstream business has to collect the reference numbers it receives, and that duty is passive. The Information System reopened at the end of June 2026. Implementing Regulation (EU) 2026/1565 lets operators group earlier statements under one reference.

For the business that first places the wood on the EU market, the core duty has not changed. For a UK firm selling into the EU or Northern Ireland, that business is often your customer. They will ask you for the plot data. The work moves upstream to you. It does not disappear. Paperwork rarely does.

Where the files fall short

In my experience, files usually fall short in the same three places.

First, geolocation is missing or too broad: a region, a concession name or a sawmill address, rather than the harvest plot. Second, mixed products such as plywood, particleboard and engineered flooring draw on many sources, and nobody upstream records which logs went into which batch. Third, the link to the shipment is weak. Data is held per supplier, not per consignment, so it cannot be matched to the goods on a given invoice or customs entry.

Test the file against one real load

The quickest way to see where you stand is modest. Take one recent container of your highest-volume product. Try to fill in each line of the Article 9 list for that load alone. Mark each line in one of three ways:

Held: we have it for this consignment, on file, today.
With the supplier: they say they have it, but we have not seen it.
Unknown: nobody in the chain has given it to us.

Repeat for your three or four hardest products, usually panels and composites. The pattern of unknowns shows which suppliers need a different conversation. It also shows which products may need a different source before the end of December.

What to do first

Rank your products by volume and by how hard they are to trace, and start with the panels and mixed products.
Run the one-load test on the top five and record every gap against a named supplier.
Write the Article 9 data, including plot geolocation, into supplier contracts and purchase orders, with a delivery date before your first EU or Northern Ireland shipment after 30 December.
Set up records per consignment, not per supplier, so each invoice links to its plots and its statement reference number.
Check the latest Commission guidance, the Northern Ireland position and Defra's consultation on Great Britain regularly. Dates and details have moved before.

Collecting information back through several tiers of supply takes months, not weeks. Starting with the hardest products puts the most time where it is needed.

Sources

Figures are taken from the sources listed and were correct at the time of writing. Where rules are described, check the latest official guidance and take qualified advice before acting.