European Forestry Pulse #123 🌲

Hello,

Something left the EU Deforestation Regulation last week.

Not a delay. Not a softening. A list of products that no longer need a due diligence statement. It became law on Friday. Most of the wood sector has not read it yet.

Here's what's moving European forestry this week:

A delegated act is a short law. The Commission writes it. Parliament and Council may object to it.

This one is Commission Delegated Regulation (EU) 2026/2102. It rewrites Annex I of the EUDR. Annex I is the product list. The Commission adopted it on 13 July 2026. Parliament and Council had until 13 September to object. Neither did. It appeared in the Official Journal on 17 September. It entered into force on 18 September.

Those dates are worth holding onto. For 67 days the text existed but was not law. Planning against it was a guess. Now it is not.

Out of scope:

Still in scope:

Read the packing-material wording carefully. The exemption covers material "used exclusively to support, protect or carry another product". A pallet under a load of bricks is packing. A pallet you manufacture and sell is a product.

Three things were added. Soluble coffee. A long list of palm oil derivatives. Frozen cattle tongues. None of it is wood.

And none of it applies yet. Each carries the same note in the Annex. The provision applies from 30 December 2027.

One rubber entry was narrowed rather than added. Retreaded tyres came out. What remains is the new tyre tread alone. That change applies now, not in 2027.

The reasons are written into the act itself.

Wooden vehicle seats came out for limited wood content and disproportionate burden. Cattle leather came out for low economic value and limited operator leverage. Waste, used goods and packaging came out to encourage circular practices and give legal certainty.

That is the stated ground. I am reporting it, not reading behind it.

The date. Large and medium operators come under the EUDR on 30 December 2026.

That date also catches micro and small operators. It applies to the timber products the old EU Timber Regulation covered. Being small does not move it. That is 99 days from today.

If you ship on pallets: your packing is probably out of scope. Check the wording against what you actually send.

If you trade reclaimed or second-hand timber: much of your range may now be out. Confirm it product by product.

If you handle wood waste or recycled fibre: the same applies. The waste directive is your test.

If you are building a due diligence system: the scope is now fixed. Build against the published Annex, not against last year's draft.

If you sell new sawnwood: nothing changed for you. Carry on.

Scope is the cheapest question to get wrong.

A product inside the scope brings duties. Exactly which ones depends on your role in the chain. The same product outside the scope brings none of them.

Friday moved the line. Find out where it sits now. Then build the system that has to respect it. And it is settled now. Ninety-nine days is short. A fixed target is still better than a moving one. Sources: Commission Delegated Regulation (EU) 2026/2102, Official Journal, 17 September 2026 | European Commission, EU Deforestation Regulation Update, 17 September 2026 | Commission EUDR page

Stora Enso finished its change negotiations on 16 September. The Veitsiluoto sawmill in Kemi closes permanently.

About 60 people will be made redundant. Production had been paused since early August. It will not restart.

Sawing moves to Oulu, Oulainen and Kalajoki. About 840 people stay across the business unit. That covers the board mill, three sawmills and port operations. The company gave its ground plainly. It cites "the need to improve the efficiency, profitability, and competitiveness" of its northern sawmills. It also expects sawmill profitability to stay challenging. Among the causes it names is "the high cost of logs".

One line matters for anyone selling logs nearby. Stora Enso addresses it directly for Northern Finland. It expects "only a minor impact" on the unit's wood supply and consumption.

Mind the two dates. August was a proposal. September is the decision. The 840 figure and the log-cost line appear only in the September release.

Why it matters: A mill that closes on weak demand is telling you about the market. A mill that closes on input cost is telling you about its margin.

The takeaway: Read the stated reason before the job number. Then read what the company says about its buying. Here the site goes, and the log demand largely stays. Those are two different pieces of news, and only one of them is bad. Sources: Stora Enso, 16 September 2026 | the earlier proposal, 12 August 2026

On 11 September the Lithuanian environment ministry instructed the state forest enterprise to act.

August storms brought down about 150,000 solid cubic metres of timber. The ministry wants the residues in the biofuel chain before winter. Its own wording is careful. This wood may become extra feedstock. Biofuel now costs about €27 per megawatt hour. That is almost 60% more than a year ago.

The ministry set a separate target. From 2027 it wants about 800 gigawatt hours of extra cheaper biofuel supply. That is roughly 400,000 cubic metres.

Keep those two numbers apart. The 150,000 cubic metres is measured storm damage. The 800 GWh is a ministry target for 2027. No wood has moved on that scale, and the ministry does not claim it has.

Why it matters: Storm wood has a short shelf life. Value falls every week it lies on the ground. An energy market can absorb volume and grades that sawmills will not take.

The takeaway: After a storm, the first question is how much fell. The second one decides the money. Which market can take it, and how quickly. A country with a hungry biofuel sector has somewhere to put the wood. Source: Lithuanian Ministry of Environment, 11 September 2026

Forest Research published its Nursery Survey on 17 September.

Nurseries sold 53.0 million Sitka spruce and Scots pine plants in Great Britain in 2024/25. Of those, 47.1 million came from improved stock. That is 89%.

This is a survey of sales, and of two species. It is not a count of every tree planted in Britain. Improved plants rose 9% on the year, a gain of 3.9 million. Scotland took 42.7 million plants. 38.5 million of them were improved, or 90%. That is a 7% rise.

"Improved" has a precise meaning here. It means seed orchard origin, or vegetative propagation from controlled crosses. In plain terms, the parent trees were chosen.

Read the coverage note too. Eleven of twelve nurseries replied, a 92% response rate covering at least 95% of sales. No estimate was made for the nursery that did not reply.

Why it matters: Improved stock is a yield decision taken forty years before the harvest. It compounds quietly. It never shows up on a balance sheet.

The takeaway: If you are planting, ask the nursery two things. What the stock is. Where the parent material came from. Buying a young plantation? Ask the same question about what went in the ground. The answer sits in a delivery note somebody filed years ago. Sources: Forestry Commission and Forest Research, Nursery Survey 2026 edition, 17 September 2026 | full statistical bulletin

Sort everything you sell into three piles.

Most of the cost of EUDR sits in the first pile. Most of the mistakes sit in the third. The exercise takes an afternoon. It is considerably cheaper than building due diligence for a product that never needed it.

Buying or selling a business? Ask for this list. How fast it comes back tells you how ready the operation really is.

"So the rules got easier for you. How convenient."

Someone will say this to you. A journalist, a neighbour, or a stranger under a post.

The accurate answer is long. A scope change is not a weakening, and explaining why takes two minutes. You will not be given two minutes.

There is a shorter answer that works. You can build it before you need it. Part 1 covers the questions that arrive without warning.

Scope is a valuation input. What you must prove about a product decides what it costs to sell.

Two identical pallets can carry different costs. One needs geolocation, a risk assessment and a filed statement. The other needs a line in a file.

That gap is margin. And it moves whenever somebody else rewrites a product list.

I wrote the Forest-Investment Dictionary with Danish forest economist Anders Tærø Nielsen. It has 151 pages, 11 chapters, 14 printable tools, and 3 calculators. Investors learn to read a forest. Foresters learn to read a term sheet.

When the market turns, the people who can read the numbers make the better calls. The price is €99. Get yours below.

A rule changed on Friday. Who in your organisation was supposed to notice?

Somebody has to read the Official Journal. Somebody has to work out what it means for your products. Somebody has to tell the sales team before a customer asks.

In most forestry organisations nobody owns that job. So it gets done late, by whoever happened to be paying attention.

I wrote The Organization, Part 3 of the Playbook. It has 165 pages, 10 chapters, 10 printable tools, and a survey. It shows what it takes to be heard, and who does the work.

Almost nobody in European forestry publishes what communication costs. The survey inside starts the count. The price is €149. Get yours below.

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Until Thursday!

Wish you all the best: Peter

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