Danzer EUDR-Readiness: Frequently Asked Questions

Latest update: October 1, 2025

As of the date above, we are presenting the questions received by Danzer customers with the most up-to-date answers. Please note that these answers reflect how Danzer currently interprets the EUDR based on the information and guidance available at this time. Questions and answers will be updated as we receive them and as our EUDR-readiness adapts to the evolving EU framework.

On September 23, the EU announced that the start of the EUDR will be postponed by one year. While this shifts the timeline, it does not change our course. This gives us all more time — but it does not change our course and the requirements remain unchanged.
All wood harvested since June 2023 will still fall under the regulation once it takes effect.
Danzer is already prepared, we will continue collecting geo data and carrying out due diligence as planned.
Our systems are in place, and we will use the extra time to further streamline processes and ensure smooth integration with your systems. This means that when the rules take effect, you can rely on us for fully compliant, low-risk sourcing — without last-minute pressure.

If you do not find your specific question here, please contact us at . We appreciate your interest in ensuring EUDR-readiness.

1. GENERAL PRINCIPLES OF EUDR

1.1 Is it the harvest date or the production date that is considered for the EUDR?

Answer: The harvest date is what counts. The EUDR applies as of December 30, 2025 based on the date of harvest, not the date of further production or sale. This means only wood harvested on or after June 30, 2023, falls under the EUDR. Wood harvested before that date falls under the EUTR (see EU Guidance April 2025 at pages 8-9).

1.2 If the wood was harvested before June 30, 2023, and we start Manufacturing in 2026 using this wood, will we be subject to the EUDR?

Answer: Not necessarily. Wood harvested before June 30, 2023, is subject to EUTR (the previous regulation) until 2028, not the EUDR – regardless of when it is processed or sold. Wood harvested after June 30, 2023 is not subject to EUDR so long as it enters the EU market in some form before December 30,2025. Any export from the EU market after that date, would be subject to EUDR.

Wood harvested between June 30, 2023 and December 30, 2025 anywhere outside of the EU, and manufactured outside of the EU to be imported to the EU after December 30, 2025 (inclusive) must comply with the EUDR.

For Danzer wood

• harvested between June 30, 2023 and December 30, 2025 and
• placed on the EU market, then
• exported in some form to Danzer customers outside the EU between those dates, and later
• imported as a manufactured product to the EU after December 30, 2025 (inclusive),

Danzer will provide necessary data to its customers to enter the relevant material onto the EU platform, or, if a customer of Danzer Veneer Europe, Danzer will enter the material on the platform at that time (after December 30, 2025) and provide a reference number to the customer.

1.3 Will EUDR geolocation data satisfy the UKTR supply chain mapping requirement?

Answer: Not necessarily. Danzer will provide UK customers with geo location data for the harvest area of the timber product. Danzer is however, contractually obligated to maintain confidentiality of name and business address with our low-risk suppliers, and will do so.

1.4 Is it possible that material harvested prior to JUNE 30, 2023 might be mixed in the materials we order in 2026? And, if so, how will this be identified for customs clearance?

Answer: Yes. Danzer’s system identifies the source of every product in mixed batches. Any items harvested prior to June 30, 2023 and subject therefore to EUTR will not be included with the geo-coordinates of post December 30, 2025 harvested material. Since the EU Trace platform does not allow entry of harvest dates, the report does not include this data. Upon request, a separate report would have to be prepared for the customer with the specific harvest dates.

2. DANZER’S DUE DILIGENCE SYSTEM AND LEGAL COMPLIANCE

2.1 Is Danzer planning to do the deforestation checks required by the EUDR? And what does that entail?

Answer: Yes. Danzer will verify that wood was not harvested from deforested land by either comparing aerial and satellite imagery before 2020 with recent images or confirming third-party verification of sustainable forest management. This process applies to each geolocation polygon for wood harvested since June 30, 2023 if med-to-high risk, and by quality control sampling if low risk.* We are trying different tools to optimize efficiency, and schedule checks according to risk of deforestation.

*Please note that Danzer’s low risk ranking is a much narrower category than used by the EU or most third party certifications.

2.2 Does Danzer have a document to support this statement that the land is not deforested? If so, can you send it to us?

Answer: Not at this time. Danzer is presently evaluating additional tools to provide the images we need to do these checks in an efficient and complete way. Our plan is that we will perform only the necessary deforestation checks for relevant products. ---

When we upload our product information to the European platform, it will include our due diligence statement with our confirmation of the deforestation check procedure. We encourage you to maintain a dialogue with us.

In most cases, especially for our majority low-risk supply, 3rd party certification of sustainable forest management is enough to demonstrate that the forest is intact and has been for at least since 2020 (our hardwood resource demands logs of an age between 40 and 120 years).

2.3 Can you provide all the documentation from the harvest site of the wood that is listed in the EUDR Guidance?

Answer: No. The documentation in the various EUDR documents depends on the assessed risk level and the items listed in the guidance are examples, many of which do not apply to the hardwood products Danzer provides. For low-risk regions (e.g., North America, Europe), Danzer uses a combination of supplier contracts, third-party certifications, and our internal due diligence system. This has been our practice since the EUTR and continues under the EUDR. Furthermore, Danzer is bound by confidentiality with our suppliers where no prerequisites for disclosure exist, like sources in high-risk regions where there are no alternatives like 3^rd party verification. Please inquire about the document, "Confidence Built Into Every Step," which is the Danzer Due Diligence explained.

2.4 Your latest customer letter says less about legality. Is a communication on this subject planned?

Answer: Yes – and this FAQ serves as that communication. Danzer's due diligence includes legal compliance across the supply chain. All suppliers agree to our General Purchase Conditions, and our third-party certifications confirm compliance with rights-to-land, labor, local laws, and human rights. These steps are part of our long-standing Due Diligence System and are documented in our sustainability reporting. Please inquire about the document, "Confidence Built Into Every Step," which is the Danzer Due Diligence explained.

3. DATA AND DOCUMENTATION PROVIDED BY DANZER

3.1 Would it be possible to provide us with geolocation information for the wood we purchase and eventually ship to the EU?

Answer: Yes. Danzer will provide a due diligence statement reference number*) and verification number for each product produced in the EU via the EU Trace DDS, once it is live (scheduled for December 30,2025). For Danzer operations outside of the EU, geo-coordinates can be made available in Excel format or GeoJSON. If imported before 30 December, the reference number (and corresponding geo data) will not be required.

*) The due diligence statement, which receives a unique EU reference number upon submission, confirms that a product's supply chain has been assessed for deforestation risks and associated legal compliance.

3.1.1 Some North American suppliers are providing us with a legality statement and polygon mapping from an AHEC system. Will Danzer be providing this? If no, why not?

Answer: No. Danzer is not a member of the American Hardwood Export Council, though the organization was initiated by a Danzer executive in 1985. Danzer believes the polygons we provide are more accurate, as procurement areas for individual mills or log yards often extend well beyond the county the yard is located in. Danzer works with its suppliers to verify the procurement radius and fine-tune the polygons within the procurement area.

Similar to the AHEC model, Danzer bases its United States polygon approach on declaring the area “in excess” because individual plots are not mapped digitally in the US and pallets of veneer and lumber are bulk commodities that contain so many bundles or boards from such a variety of log sources (sorted for quality grade) that it is akin to the “soy bean in a silo” example explained in the EUDR FAQ document at 1.18. Danzer’s due diligence ensures that “the risk of non-compliance (regarding the deforestation-free and the legality requirement) has been assessed by Danzer in accordance with Art. 10(2) EUDR ; that, in such assessment, the operator has taken particular account of criteria (i) and (j), of Art. 10 EUDR; and that such risk is negligible for all plots of land.”

3.1.2 The AHEC system provides a legality statement but no deforestation check. What is Danzer providing in this regard?

Please see Answers 2.2 and 2.4 above.

3.1.3 How does Danzer take responsibility for the traceability and compliance risks associated?

Please inquire at about entering into a contract with Danzer to ensure any faults in the data provided are remedied.

3.2 Could you please explain how the due diligence statement number will be managed?

Answer: Sure. The due diligence statement reference number and its corresponding verification number will be available on the EU Information System. The way the EU FAQ reads at this time, is foreseen that you would simply login to the Information System, create a Draft due diligence statement and insert the due diligence statement reference number you receive from Danzer under the tab ‘Referenced Statements.’ The system will check the validity of the due diligence statement reference numbers and verification numbers.

3.3 When raw materials come from Europe and are sent to non-EU sites, will Danzer complete the due diligence statement?

Answer: Yes. Danzer will complete the due diligence statement for products exported from the EU and pass the reference numbers to you. If you are further processing the material, you only need to input the reference and verification numbers and add data for any non-Danzer components.

3.4 Is it possible that Danzer only send geo data for materials that I have already prepared to ship to the EU? This would eliminate unnecessary processing of information for products that are not exported to the EU.

Answer: Yes. Danzer would also prefer to send information only as needed. Simply send your request to your sales representative with the relevant invoice number(s) for the Danzer production material and the file will be sent to you in a form ready for upload to the EU Trace platform. Some pre-manufactured trade materials produced outside of the EU may not have geo-data available. If this is the case, your invoice will indicate this.

3.5 How can I perform my own risk assessment and due diligence if I am only getting the information before shipment? 

Answer: Good question. Danzer is happy to demonstrate the due diligence Danzer conducts to assure a legal, sustainable and deforestation-free supply chain. For low-risk supplies, especially where the supply chain is short (forest to Danzer production), a periodic review of our due diligence system should satisfy your needs. Danzer employs a higher-level of due diligence for products from higher-risk regions and complex supply chains. We understand if more questions are raised about these products and ask that some lead time be provided to satisfy your own due diligence prior to shipment. 

4. CERTIFICATION AND CHAIN OF CUSTODY

4.1 Our final product is not claimed as a certified product, but the wood is certified as controlled wood. Is this compliant with the EUDR?

Answer: No. The EUDR does not recognize any certification as direct proof of compliance. However, sustainable forest management certifications are helpful elements in Danzer’s due diligence system, supporting our due diligence efforts.

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