European importers of timber and wood products have operated under the EU Timber Regulation (EUTR) and the FLEGT (Forest Law Enforcement, Governance and Trade) licensing scheme for over a decade. The arrival of the EU Deforestation Regulation (EUDR) significantly changes the regulatory landscape — not by replacing these frameworks entirely, but by layering new, stricter obligations on top of existing ones.
This article explains how EUDR and FLEGT interact, where they differ, and what forest product importers must do to be compliant with both.
What Is FLEGT?
FLEGT is a voluntary partnership programme between the EU and timber-producing countries. Under Voluntary Partnership Agreements (VPAs), partner countries establish a national timber legality assurance system. Timber covered by a valid FLEGT licence from a VPA country was previously exempted from full EUTR due diligence obligations because legality was considered proven by the licence.
Countries with fully operational VPAs as of 2025 include Indonesia (the most mature VPA) and Ghana. Countries with signed but not fully operational VPAs include Cameroon, the Republic of Congo, Liberia, and others. No Latin American country has a fully operational FLEGT VPA, which is relevant for importers sourcing timber from Peru, Brazil, or Colombia.
What Changes Under EUDR for Timber Importers?
The EUDR brings fundamental changes for anyone importing wood and wood products:
1. The Scope Expands Beyond Legality
EUTR focused on legality: was the timber harvested in compliance with the laws of the country of origin? EUDR adds a new requirement: no-deforestation. Even if timber was harvested legally, it cannot enter the EU market if it comes from land that was deforested after 31 December 2020. Legal and deforestation-free are now both mandatory, independently.
2. FLEGT Licences No Longer Provide Full Exemption
This is the most significant change for FLEGT-reliant importers. Under EUDR Article 3, even timber covered by a valid FLEGT licence must meet the no-deforestation requirement. A FLEGT licence proves legality but says nothing about whether the forest the timber came from existed before 2020. Importers sourcing FLEGT-licensed timber must now also conduct geolocation-based deforestation verification.
The practical implication: your Indonesian FLEGT-licensed timber supplier must provide geolocation data for their harvesting concession, and you must verify it against a 2020 forest baseline. The licence does not exempt you from this.
3. The EUTR Is Effectively Superseded
The EUTR will be repealed once EUDR takes full effect. The legality requirement under EUDR (Article 3(b)) covers the same ground as EUTR but with expanded scope and higher penalties. Companies that built EUTR compliance systems will need to upgrade — not discard — them to meet EUDR requirements.
4. Geolocation Data Is Now Mandatory for Timber
Unlike EUTR, which required due diligence but gave flexibility on how legality was proven, EUDR mandates that operators collect geolocation coordinates for every plot of land where the timber was harvested. For large logging concessions, this means concession boundary polygons at minimum. For plantations, it means plantation boundaries. This data must be machine-readable and submitted with the due diligence statement.
How EUDR and FLEGT Will Interact in Practice
The European Commission is working on guidance on how FLEGT licences will be recognised under EUDR. The current expectation is:
- FLEGT licences will be accepted as evidence of legality (satisfying EUDR Article 3(b))
- FLEGT licences will not be accepted as evidence of no-deforestation (EUDR Article 3(a))
- Importers with FLEGT-licensed timber must still provide geolocation data and conduct deforestation verification
This means the due diligence burden for FLEGT-country timber imports will be significantly reduced compared to high-risk, non-VPA sources — but not eliminated.
Practical Implications for Latin American Timber Importers
For importers sourcing timber from Peru, Brazil, Bolivia, or Colombia:
- No FLEGT VPA applies — full EUDR due diligence required, including geolocation and deforestation verification
- Legal timber from Peru must come from authorized SERFOR concessions or communities — legality documentation is available but must be collected and retained
- Brazilian timber must be traced through the DOF/SINAFLOR system (Sistema Nacional de Controle da Origem dos Produtos Florestais)
- Deforestation verification must be conducted against Brazil's PRODES and SERNANP/MINAM baselines for Peru
Timeline: What to Do Before December 2025
- Now: Map your timber supply chain to country and sub-national origin level
- Q3 2025: Obtain geolocation data from all timber suppliers (concession polygons minimum)
- Q3 2025: Run spatial intersection against 2020 forest baselines — identify any RED or AMBER suppliers
- Q4 2025: Resolve all AMBER cases, exclude RED cases, and finalise your due diligence documentation system
- December 2025: Submit first due diligence statements through the EU Information System before placing timber on the market
How Terralyr Supports Timber Importers
Terralyr's spatial due diligence module is designed for exactly this use case: multi-tier supply chain traceability from harvesting concession to EU port. The platform integrates Peru's SERNANP protected area registry, Brazil's PRODES deforestation monitoring, and Colombia's environmental authority data to provide authoritative, audit-ready geolocation analysis for every timber shipment.