ForestryBrief Professional #1 🌳💰

Dear Fellow Forest Professional,

You just received the first full issue of ForestryBrief Professional covering the current challenges and realities of the upcoming EUDR-compliance. The next issue will drop coming Friday continuing the EUDR-topic, but it will be only available to those who upgrade to a Professional subscription.

If you haven’t read this piece of intelligence yet, please by all means do so below this paragraph first. You won’t regret it. If you opened this just to get the subscription link because you already know how awesome FB Professional is, you can subscribe here. (Don’t worry, there is the same link at the end as well, so you can decide after reading how quickly you want to join the FB Professional community 😉. FYI: Since this is the first issue, don’t expect anything huge to happen after you upgrade. But you will get the next intel the coming Friday, and European Forestry Pulse subscribers will not get that…)

Have you ever stood under Norwegian spruce with a €5,000 GPS unit, watching it jump 10 meters because a tree trunk confused the satellites?

Brussels wants 11 centimeters of accuracy. This isn't a technical challenge. It's demanding that gravity work backwards.

And in 4 months, your forest operation can become illegal unless you know these three workarounds that competent authorities are quietly accepting...

The meeting room in Brussels was pristine. Floor-to-ceiling windows overlooked the Berlaymont building, and the conference table gleamed under LED panels designed to mimic natural light. It was here, in rooms like this, that bureaucrats wrote Article 2(28) of the EUDR, mandating "at least six decimal digits" for geolocation accuracy.

Six decimal digits. That's 11 centimeters of precision.

The people who wrote this requirement have clearly never stood under a Norwegian spruce canopy with a €5,000 survey-grade GPS unit, watching it struggle to maintain satellite lock as water-laden branches scatter signals like a hall of mirrors. They've never watched their position jump 10 meters because a tree trunk created multipath interference. They've never tried to map a Finnish forest plot in winter when ice crystals on pine needles might as well be signal jammers.

But many of us have. For several years. And I'm here to tell you what €50,000 consultants won't: EUDR compliance, as written, defies the laws of physics.

Let's start with what Brussels demands versus what physics delivers. The Commission's FAQ cheerfully instructs operators to "enter six decimals for geolocation," as if typing more numbers somehow improves satellite signal penetration through 40 meters of biomass.

Forest Service research—not opinion, not estimates, but peer-reviewed science—shows GPS positioning errors of 2 to 10 meters under dense canopy. Consumer devices average 4 meters of error with maximums exceeding 20 meters. Even survey-grade equipment, the kind that costs more than a car, manages only 8 meters root mean square error under optimal forest conditions (Czech Journal of Forest Science, 2018). For foundational GPS physics, see Global Positioning System: Theory and Applications and US government GPS Accuracy Standards.

Think about that gap. Brussels wants 0.11 meters. Physics gives you 8 meters. That's not a rounding error or a technical challenge—it's demanding that gravity work backwards.

The physics are unforgiving. GPS signals operate at frequencies that have, in the technical literature's understated language, "very little penetrating ability" through water-rich foliage. Every branch, every leaf, every trunk becomes an obstacle. Tree trunks don't just block signals; they create multipath interference, bouncing signals around until your receiver thinks you're standing 10 meters from your actual position. The constantly changing satellite constellation means that even if you somehow got a good reading at noon, by 2 PM you're dealing with entirely different geometry and new errors (USDA Forest Service Study, 2025). For further technical background, see GPS.gov: Performance and Accuracy.

A Czech forestry study put numbers to what every forester knows intuitively: "approximately 4m error on average and more than 10-20m at maximum" under typical canopy conditions. The researchers weren't using cheap smartphones—they tested professional equipment under real forest conditions. Their conclusion? The technology to meet EUDR requirements doesn't exist (Global Positioning System textbook).

Yet here we are, five months from implementation, and the entire European forestry sector is pretending that typing six decimal places into a form somehow solves fundamental physics limitations.

Behind closed doors, in the offices of competent authorities across 27 member states, a different reality has emerged. Instead of 11-centimeter precision, they're quietly accepting polygon boundaries for plots over 4 hectares. For smaller plots, "representative points" suffice. The German BLE guidance reveals this flexibility—they specify no meter-tolerance requirement, instead suggesting operators use "best available technology" and document their methodology. The magic phrase appearing in approved compliance documents? "Geolocation obtained using industry-standard practices" (BLE FAQ, April 2025).

Translation: We know you can't do what we're asking, so just do something and document it.

This creates a bizarre compliance theater where companies spend between €5,000 and €50,000 on systems that everyone knows don't meet the stated requirements. Software vendors promise "AI-driven precision" while their small print acknowledges "environmental factors may affect accuracy." Consultants charge premium rates to help companies document why they can't comply with requirements that can't be met.

While IntegrityNext and SourceIntelligence build businesses on this confusion, charging €10,000 to €50,000 annually for "compliance solutions," I'm about to show you how to build defensible EUDR documentation for free.

The European Space Agency's Sentinel-2 satellites provide 10-meter resolution imagery, updated every five days, completely free (Copernicus Sentinel-2 imagery; Sentinel-2 forest disturbance science). This resolution exceeds EUDR's 0.5-hectare detection requirement by a factor of five. You don't need a consultant to access this—just a web browser and an email address.

Here's your compliance process: Create an account at the Copernicus Open Access Hub. Search your harvest area using the coordinates you already have from existing forest management plans. Download images from before and after December 31, 2020—the EUDR cutoff date. Compare the Normalized Difference Vegetation Index values between dates. A significant drop indicates forest loss; stable or increasing values prove no deforestation. Export the analysis as a PDF with full metadata. Congratulations, you've just created compliance evidence that would cost €5,000 from a consultant.

For those comfortable with basic coding, Google Earth Engine provides even more power. The platform offers free access to petabytes of satellite imagery with cloud-based processing. Here's a simple script that analyzes your entire forest holding for deforestation since the EUDR cutoff date. Copy this script directly into Google Earth Engine:

The University of Maryland's GLAD alert system updates weekly with 30-meter resolution forest disturbance data. It's free, it's peer-reviewed, and it's already accepted by major certification bodies (FSC satellite data guidance; PEFC remote sensing for forests). Download KML files for your plots, import them into QGIS (also free), and you can generate professional reports indistinguishable from those produced by premium compliance platforms.

The total cost of this stack? Zero euros, plus perhaps two days of learning curve. The consultant replacement value? €50,000 or more.

Are your ears prickling already from the awesomeness of ForestryBrief Professional? Don’t want to miss any issue ever? You can subscribe here. (Don’t worry, there is the same link at the end as well, so you can decide after reading the entire intel how quickly you want to join the FB Professional community 😉. FYI: Since this is the first issue, don’t expect anything huge to happen after you upgrade. But you will get the next intel the coming Friday, and European Forestry Pulse subscribers will not get that…)

Five months before implementation, the political machinery is already preparing for failure. The EU's TRACES Information System, meant to handle all EUDR submissions, crashed during 2024 stress tests when multiple companies attempted simultaneous uploads (Global IT outage reporting). API specifications keep changing, breaking the integrations that larger companies spent millions developing.

The country risk classification system reveals the political theater's absurdity. Only four countries received "high risk" designation: Belarus, Myanmar, North Korea, and Russia. Combined, these represent 0.07% of EU imports. Brazil, Indonesia, and Malaysia—origins of the commodities EUDR supposedly targets—all received "standard risk" ratings. The European Parliament rejected this classification system in July 2025 with 373 votes against 289, but the Commission continues as if nothing happened (Greenpeace EPP and forests coverage).

Eighteen of the EU's 27 member states, led by Germany, signed a letter calling for "simplification" of EUDR requirements. Germany's coalition agreement goes further, stating the new government will ensure "EUDR does not apply to Germany" through a proposed "zero-risk alternative." This isn't bureaucratic fine-tuning—it's one of the EU's largest economies essentially declaring independence from EU environmental law.

Austria's MEP Alexander Bernhuber successfully pushed through amendments eliminating country benchmarking systems. Earthsight investigations reveal his party received hundreds of thousands of Euros from forest-risk commodity companies since 2018 (Earthsight investigations). The German CDU/CSU parties collected over a million Euros from companies including Mercedes-Benz and BMW over the same period. These aren't campaign contributions—they're investments in regulatory capture.

Behind the rhetoric about protecting forests and preventing climate change, EUDR implementation reveals itself as a battlefield where physics, politics, and profits collide. December 30, 2025, looms not as a deadline but as a starting gun for what insiders already call "the great pretending."

No member state has published detailed national guidance yet. Customs authorities face an impossible task—Rotterdam alone handled 13.8 million TEU in 2024 (Port of Rotterdam statistics). Checking even 1% of timber shipments would require hundreds of specialized inspectors who don't exist. The enforcement infrastructure simply isn't there, and everyone in the industry knows it.

The European People's Party continues lobbying for a "no-risk" category that would exempt EU producers entirely, creating a two-tier system that likely violates WTO non-discrimination rules. Commission President Ursula von der Leyen reportedly considers reopening EUDR negotiations, though officially the December deadline stands firm.

Meanwhile, the April 2025 "simplification measures" quietly walked back key requirements. Companies can now submit annual statements instead of per-shipment documentation. Groups can use authorized representatives for submissions. Large downstream companies need only collect reference numbers from suppliers. Each simplification acknowledges what Brussels can't say publicly: the original requirements were impossible (IISD summary of EUDR simplification; PackagingEurope EUDR simplification).

Intelligence from multiple member state authorities suggests the first 6 to 12 months will feature "educational enforcement"—bureaucratic speak for not enforcing the law. Expect warning letters instead of fines, acceptance of "good faith efforts" as compliance, and focus only on egregious violators who make no attempt at documentation.

The customs reality makes strict enforcement impossible anyway. Rotterdam, Europe's largest port, handled 13.8 million TEU in 2024. Even checking 1% of timber shipments would require hundreds of new inspectors trained in forestry, remote sensing, and international trade law. These inspectors don't exist.

The German rebellion signals what's coming. Their push for a "zero-risk alternative" essentially means EUDR wouldn't apply to German producers or importers dealing with "safe" countries. Eighteen member states support this approach. If implemented, EUDR becomes voluntary for most of Europe while maintaining strict requirements for tropical producers—a trade barrier dressed as environmental protection.

Focus countries for initial prosecutions have already been selected, according to Brussels sources. Indonesian palm oil tops the list—politically safe, environmentally visible. Brazilian soy follows, particularly from recently converted areas. West African cocoa will see token enforcement to demonstrate concern for smallholders while actually excluding them from markets. Notably absent from enforcement priorities: EU internal trade, US imports, Canadian timber.

The transport precedent offers a preview of creative compliance. FEFPEB confirmed wooden pallets are exempt when used exclusively for transport. This seemingly narrow exemption creates massive loopholes. Watch for creative "packaging" and "transport" classifications emerging as companies test boundaries (FEFPEB Statement, June 2025).

The impossible GPS requirement isn't a bug—it's a feature. By demanding the physically impossible, EUDR creates a system where everyone is technically non-compliant, giving authorities discretion to enforce selectively. This isn't environmental protection; it's regulatory arbitrage.

Large companies like UPM publicly claim full compliance while their systems show "phased rollout"—corporate speak for "we're winging it." Barry Callebaut mapped 669,174 cocoa plots at a cost minimal cost compared of executive compensation, not to ensure compliance but to exclude competitors who can't afford similar mapping (UPM compliance news; Barry Callebaut ESG/sustainability 2025).

The software vendors selling "AI-driven compliance solutions" know their products can't deliver what's promised. In private conversations, their engineers acknowledge accuracy limitations, data gaps, and the fundamental impossibility of tracking wood chips from forest to final product. But with a $1.5 billion market at stake, nobody has incentive to admit the emperor has no clothes.

For forest owners under 100 hectares, the message is clear: you're being regulated out of existence. Compliance costs of €200 to €500 per hectare make small-scale forestry economically unviable. The large operators absorbing these forests won't maintain the biodiversity, local employment, or careful management that small owners provided for generations (EUDR compliance cost study; Profundo EUDR cost analysis; Mongabay EUDR cost reporting).

The real tragedy isn't that EUDR fails to protect forests—it's that it pretends to while actually accelerating consolidation, excluding smallholders, and creating competitive advantages for those large enough to navigate its impossibilities. The regulation born from environmental necessity has become a tool for market manipulation.

As you prepare for December 30, remember this: You're not failing to comply with EUDR. EUDR was designed to be impossible to comply with. Document your efforts, use the free tools I've outlined, and understand that perfect compliance is not the goal because it's not achievable. The goal is surviving the theatre until political reality forces Brussels to acknowledge physical reality.

The GPS coordinates Brussels demands don't exist under forest canopy. They never have. They never will. And everyone involved knows it.

You have tasted the mere wonder of ForestryBrief Professional by now and I am sure you don’t want to miss any issue ever. You can subscribe here. FYI: Since this is the first issue, don’t expect anything huge to happen after you upgrade. But you will get the next intel the coming Friday, and European Forestry Pulse subscribers will not get that…

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You can subscribe here. (FYI: Since this is the first issue, don’t expect anything huge to happen after you upgrade. But you will get the next intel the coming Friday, and European Forestry Pulse subscribers will not get that…)

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And you could be right, if these were just emails. But they are not. They are invaluable industry intelligence.

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Until Friday!

Wish you all the best: Peter