How the EUDR differs from the UK timber rules for importers selling into both markets

Many timber importers selling into both the EU and the UK still treat the two systems as variations of the same compliance job. They are not. The UK rules in force today are built around legality. The EU Deforestation Regulation, Regulation (EU) 2023/1115, adds a separate deforestation standard, mandatory geolocation and a formal filing step before goods are placed on the market. Businesses serving both markets can still organise much of the work once, but only if they understand where the regimes diverge and where assumptions create gaps.

What is live in the UK today

In Great Britain, the current timber regime is the UK Timber Regulation, usually called the UKTR. It has applied since 2013. Operators who first place timber or timber products on the market in Great Britain must exercise due diligence and maintain a due diligence system. That system must be evaluated regularly. Traders further down the supply chain must keep records that allow products to be traced back to the operator.

The important point for businesses preparing for the EUDR is that the UKTR is a legality regime. Its purpose is to prevent illegally harvested timber from entering the UK market. It does not require products to be deforestation free. It also does not require plot level geolocation data.

That difference matters operationally. A supplier pack that satisfies the UKTR today may still be missing key information needed for the EU market in December 2026.

Northern Ireland sits outside the UKTR system. Northern Ireland follows EU timber rules instead. Businesses moving timber products into Northern Ireland therefore need to treat those flows separately from Great Britain flows.

What the UK has proposed since June 2026

The UK government has also moved beyond the current UKTR framework, although the proposed regime is not yet in force.

The legal basis comes from Schedule 17 to the Environment Act 2021. Schedule 17 created powers to regulate “forest risk commodities”. As enacted, it sets out a framework only. It requires a due diligence system covering identification and information gathering, risk assessment and risk mitigation relating to compliance with relevant local laws in the country of production. It also defines forest as land larger than 0.5 hectares with tree canopy cover of at least 10%.

However, Schedule 17 does not itself impose operational duties yet. Secondary legislation still has to specify which commodities are covered, the thresholds that apply and the start date. The Schedule as enacted also excludes timber already covered by the UKTR, which means the future relationship between the two systems still needs to be reconciled in legislation.

On 23 June 2026, the UK government published “The UK’s approach to deforestation regulations”. The paper states that businesses in Great Britain with annual turnover above one million pounds that use forest risk commodities will need to establish a due diligence system, report on their activity and hold proof of compliance, including geolocation data on the origin of products.

The proposed commodity scope includes wood, cattle, cocoa, coffee, palm oil, rubber and soy, plus derived products such as furniture and chocolate. Implementing legislation is expected in 2027. No application date has been set.

That timing point matters. Businesses should prepare for change, but they should not treat the June 2026 policy paper as if it were already binding law.

How the UK proposal differs from the EUDR standard

The biggest practical difference between the systems is the legal standard itself.

Under the EUDR, timber and timber products placed on the EU market after 30 December 2026 must be both:

• Deforestation free, meaning the relevant products were not produced on land deforested or forest degraded after 31 December 2020.
• Produced legally, meaning relevant legislation in the country of production was complied with.

The UK proposal published in June 2026 does not use the same test. The proposed UK approach is based on compliance with local law in the country of production. In practice, that is an illegal deforestation standard rather than the EUDR’s broader deforestation free standard.

For importers, this means a product could potentially satisfy a future UK requirement if local law allowed land conversion, while still failing the EUDR deforestation free test.

This is why businesses selling into both markets should avoid building separate supplier conversations around “UK timber compliance” and “EU timber compliance”. The supplier needs to understand that the EU standard goes further.

Where filing and evidence duties differ

The second major difference is procedural.

The EUDR requires a formal due diligence statement to be submitted through the EU’s TRACES system before products are placed on the market. That filing requirement is central to the regime.

The due diligence statement must include geolocation data for the plots of land where the timber was produced. For plots larger than 4 hectares, polygon coordinates are required. For plots of 4 hectares or less, a single latitude and longitude point may be used.

The EUDR also requires businesses to retain evidence for at least five years. Enforcement risk is material. Penalties must include fines of at least 4% of EU turnover, and authorities may also confiscate goods or revenues or exclude businesses from public procurement.

The European Commission’s Joint Research Centre Global Forest Cover map is intended as a free reference source for screening forest cover risk.

There is currently no equivalent UK filing system for timber products comparable to the EUDR due diligence statement in TRACES. The existing UKTR focuses on maintaining and operating a due diligence system rather than filing transaction level declarations before placing products on the market.

Even under the June 2026 UK proposal, the government has described reporting obligations and evidence retention requirements, but it has not introduced an EUDR style pre market filing process.

What businesses should organise once for both markets

Most businesses do not want parallel supplier onboarding systems for the UK and EU. In practice, a shared supplier questionnaire and a single evidence pack can support both markets if they are designed around the stricter EU standard from the start.

A workable approach usually includes:

• Supplier identity and full supply chain mapping.
• Harvest country and species information.
• Evidence of legal harvest and export compliance.
• Plot geolocation data collected in EUDR compatible format.
• Production dates linked to the relevant plots.
• Risk assessment records and mitigation actions.
• Document retention controls aligned to the EUDR five year period at minimum.

Businesses already collecting EUDR level information will generally be in a stronger position if the UK introduces a geolocation based forest risk commodity system later. The reverse is not necessarily true. A legality only UKTR file will often be incomplete for EU purposes.

Many operators are also using the EUDR process to standardise supplier declarations across all markets instead of maintaining separate UK and EU forms. That reduces the chance of suppliers giving inconsistent answers to different customers.

Practical traps for importers selling into both markets

The most common mistake is assuming that compliance in one market automatically covers the other.

A UKTR due diligence file may demonstrate legality while containing no usable geolocation data and no evidence supporting a deforestation free assessment after 31 December 2020. That creates exposure when the same product is later sold into the EU.

Another trap is treating the June 2026 UK proposal as settled law. The government has stated an intended direction, but implementing legislation is expected in 2027 and no application date has been confirmed. Businesses should monitor developments closely without presenting proposed requirements internally or to suppliers as if they were already mandatory.

Supplier letters are another weak point. Some suppliers are currently issuing declarations drafted narrowly for one regime only. A letter confirming compliance with local harvesting law may help with UKTR style legality checks but say nothing about deforestation free status. Conversely, some EUDR focused supplier statements omit information needed for downstream UK traceability records.

Record retention periods also need attention. The EUDR requires evidence to be retained for at least five years. Businesses that apply shorter internal retention periods based on older UK practices may discover too late that supporting records for EU due diligence statements are no longer available.

Finally, importers should pay attention to how geolocation data is gathered and stored. The EUDR requires plot level information capable of supporting the due diligence statement filed in TRACES. Businesses relying on spreadsheets exchanged by email between suppliers, agents and customers often find that coordinates become disconnected from shipment records over time. A structured evidence workflow matters as volumes increase.

goEUDR helps timber importers manage supplier evidence, organise geolocation data and prepare and submit EUDR due diligence statements through a managed filing process built for mixed UK and EU supply chains.

This article provides general information only and does not constitute legal advice.