Who is responsible for EUDR compliance in the timber supply chain?

Under EUDR, responsibility is allocated by role: 'Operators' (those who first place timber on the EU market — importers, or EU-based harvesters) bear full due diligence obligations including geolocation, risk assessment, and due diligence statements. 'Traders' (those who make timber available on the market after the operator — dealers, merchants, distributors) must maintain records of suppliers and customers, and for large traders (non-SME), must also conduct due diligence.

Under EUDR, responsibility is allocated by role: 'Operators' (those who first place timber on the EU market — importers, or EU-based harvesters) bear full due diligence obligations including geolocation, risk assessment, and due diligence statements. 'Traders' (those who make timber available on the market after the operator — dealers, merchants, distributors) must maintain records of suppliers and customers, and for large traders (non-SME), must also conduct due diligence. SME traders have simplified obligations (record-keeping and supplier identification only). In practice, timber dealers need to: verify their suppliers are compliant operators, maintain transaction records with traceability references, and for larger businesses, conduct their own due diligence assessments.

Why this matters

This question relates to Timber Traceability for Tenders: Meeting Due Diligence Requirements, which covers the broader topic in detail. Understanding this specific aspect helps architects, builders, and timber dealers make informed specification decisions.

For full context and additional technical detail, see our comprehensive guide:

→ Timber Traceability for Tenders: Meeting Due Diligence Requirements

Related questions

• What does timber traceability mean in practice?
• What are the EUDR requirements for timber traceability?
• How does FSC/PEFC chain of custody relate to EUDR compliance?

About this answer

This answer is part of the PuurModulair Knowledge Base — comprehensive timber specification guidance for architects, builders, and dealers across the UK, EU, and Scandinavia.