ForestryBrief Professional Extra 🌳💰

I know you just looked at your calendar thinking it is already Friday, since you just received another issue of ForestryBrief Professional. And neither do you see two, nor does your email system malfunction. You just received an issue of EFP, and now an issue of FB Professional arrived. If you look closely you can see that this issue has no number and is not about carbon but about EUDR (Carbon continues tomorrow on the regular Professional schedule). Since the EUDR deadline is less than 100 days away and things are starting to heat up, I decided to drop an extra issue dedicated to the topic. Also got a few new pieces of intel for you. Enjoy…

So TRACES went live in December 2024. Not testing. Not pilot. Fully working.

By September 2025, companies had filed over 350,000 Due Diligence Statements. Germany leads 18 countries asking for easier rules. Consultants promise delays. But hundreds of thousands already complied.

The September 10 PEFC webinar revealed a truth. Two groups are forming. Not compliant versus non-compliant. It's those who know the real rules versus those following the written ones.

Next available trainings from the European Commission:

Training dates for November will be announced in due course.

September sessions filled up fast. October might be your last chance. The Commission posts updates through their newsletter. After November, you're probably on your own (you’re not, ForestryBrief is here to help, but you can make it easier for you).

May 2025 brought the country risk list. High-risk countries: Belarus, Myanmar, North Korea, Russia. These countries send almost nothing to Europe.

Most countries got "low-risk" status. Sounds good, right? Wrong. The guidance says low-risk disappears if "violations or risks" appear. One complaint kills your simple process.

LiveEO's benchmarking study estimates €133 billion in EU export value faces risk from data quality issues. Their comparison with JRC models showed 98% accuracy matters—false positives create unnecessary exclusions, false negatives create compliance exposure.

The Commission's FAQ has a bombshell. SME traders get easy rules. If you have under 250 workers and make less than €50 million yearly, listen up.

Gábor Lovasi from the Commission confirmed it: "SMEs not subject to the obligation don't need due diligence statements."

What SME traders must do:

That's it. No risk checks. No complex systems. A filing cabinet works.

Non-EU companies need EU representatives to file their DDS. Article 7 says so. But here's the secret: anyone in the EU can do this. No special license needed.

The system takes DDS through web or API. The API exists and works. But it has limits they don't advertise.

The Commission says you can draw polygons on maps. Or upload GeoJSON files. They don't mention when it breaks.

Each DDS gets a unique number. Pass it down your supply chain. But the visibility settings create problems. Hide your location data? Customers get suspicious. Show it? Competitors see your sources.

The Commission published enforcement targets in their guidance:

Inspection rates by country risk:

For standard-risk countries—where most trade occurs—97% of operators face no inspection.

The penalty structure outlined in Article 34 sets maximum fines at 4% of annual EU turnover. But maximums aren't minimums. The Buyer's Guide reveals financial penalties range widely, with confiscation of goods and revenue recovery as alternatives to fines.

The law says countries must accept each other's approvals. Reality is different.

The EUDR Summit Q&A admits it: "Guidance may evolve in 2025." Each country reads the rules differently.

Timber shows the mess. Wood cut before June 29, 2023 follows old rules until 2028. Wood cut between June 2023 and December 2025? Different rules based on sale date. Every country decides differently.

PEFC and FSC developed EUDR alignment modules—acknowledgment that certification overlaps substantially with EUDR requirements. Preferred by Nature offers "EUDR Due Diligence System - PEFC" integration.

But certification doesn't equal compliance. From the EUDR Summit: "certification schemes can support the risk assessment process, they are not a substitute for the due diligence obligations."

The cost burden concern raised at the summit remains: producers bear compliance costs while buyers demand certificates. The suggestion to use "shared due diligence frameworks" and "government-supported traceability platforms" acknowledges the system's fundamental unfairness.

Each member state designated competent authorities for enforcement. But designation doesn't mean preparation.

The Commission's centralized help desk handles IT questions. For substance? Contact your national authority. Their preparedness varies wildly.

From the guidance: risk assessment must occur with each DDS submission, not annually. This means every shipment needs fresh assessment unless referencing previous DDS for identical products.

The feedback deadline approaches September 30. But individual operator feedback matters less than understanding your national authority's position.

Immediate actions based on verified intelligence:

1. Register for one of the trainings listed above Not for the content—for the Q&A. Real questions reveal real problems.

2. Claim your TRACES account The system is live. Early registrants avoid December verification delays.

3. Understand your category

4. Document your basis When guidance "evolves," your documented interpretation becomes your defense.

5. Test with small batches The API's real limits appear under load. Discover them before December.

The PEFC webinar had nearly 1,000 people watching. They're worried. But worry doesn't mean understanding.

Those 350,000 DDS submissions prove something. Early movers take EUDR seriously. But they also show the system can't handle this volume.

Brussels wrote theory. Markets create workarounds. The gap between them? That's where smart companies win.

December 30 isn't a hard stop. It's a starting line. The race isn't for perfect compliance. It's for good enough paperwork that proves you tried.

Winners won't have the best forests. They'll have the best understanding of what really matters versus what's just written down.

Primary Sources:

Official EU Resources:

Certification Body Resources:

Industry Analysis:

Friday: We’re continuing the Carbon Series, Part 2 drops in the morning. Last week, I showed you why a €1,000 carbon credit pays forest owners €200. This week, I'm going to show you exactly where the other €800 goes. Name by name. Fee by fee. Cut by cut.

ForestryBrief Professional: €49/month for intelligence that pays for itself. Find €1,000 in value within 30 days or full refund.

Until tomorrow’s EFP!

Wish you all the best: Peter

P.S. What’s the biggest challenge you’re facing in forestry right now?
Hit reply and let me know — I read every message personally.

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