Forest Plot to DDS: A Practical US Strategy for EUDR Compliance
- Joe H
- May 16
- 7 min read
Updated: May 20
The European Union’s new deforestation regulation (EUDR) requires companies to prove that every shipment of wood-based products is legal, deforestation-free, and traceable to the source.
But what happens when products like particle board, paper, or even sawn lumber are made from logs harvested across multiple forest plots?
This proposal offers a straightforward system to solve that.
Using a national, USDA-managed system of registered forest plots and Plot IDs, U.S. suppliers could meet EUDR traceability requirements—even when wood is mixed from multiple sources during processing.
📦 Example: Mixed-Origin Products
Let’s say a sawmill processes logs from four different forest plots:
• Plot A: Private family woodland in Tennessee
• Plot B: State-certified tract in West Virginia
• Plot C: TIMO land in North Carolina
• Plot D: Tribal forest in Kentucky
Each of those plots was:
• Pre-registered in a national database with GPS coordinates
• Documented for legality and land-use history
• Confirmed to be deforestation-free post-2020
When those logs are processed and bundled into a shipment of flooring stock or structural panel cores, the mill includes all four Plot IDs in the product documentation. The EU-bound exporter pulls up those Plot IDs in the database, retrieves the supporting documents, and submits a Due Diligence Statement (DDS) listing all four.
Because all sources are individually traceable and verified, the shipment qualifies under EUDR’s "negligible risk" standard—even if the wood is mixed.
Why This Matters Even in "Low-Risk" Countries
🌍 Country Risk Benchmarking
By June 30, 2025, the EU will publish a classification of countries into low, standard, or high-risk categories concerning deforestation. This classification will influence the stringency of due diligence requirements:
Low-Risk Countries: May benefit from simplified compliance procedures.
High-Risk Countries: Will be subject to more rigorous due diligence obligations.
The United States' classification will determine the level of scrutiny required for its wood products.
Some may assume that if the U.S. is classified as a "low-risk" country under EUDR, these steps won't be necessary. But under the regulation as it still stands, geolocation and legality documentation are still required from all countries, regardless of risk level.
"Low risk" simply means operators may not need to perform extensive risk mitigation steps, like audits or third-party verification. However, they are still obligated to:
• Provide precise plot-level geolocation (GPS or polygon data)
• Prove legal harvest according to U.S. laws
• Confirm that the wood is deforestation-free post-December 2020
This system is designed to meet those core requirements in a way that fits how U.S. forestry and supply chains actually work—without forcing major changes to operations or business models.
With that in mind, here is the full structure of the proposed compliance framework:
Building a National Compliance Infrastructure: A Practical Strategy for EUDR Compliance in the U.S. Forestry Sector
Overview
The European Union Deforestation Regulation (EUDR) presents a major challenge for the U.S. wood industry due to its requirement for precise, plot-level geolocation and legality documentation for all timber used in products sold on the EU market. Given the fragmented nature of forest ownership in the United States and the high degree of mixing at sawmills, traditional compliance models are unworkable for many U.S. suppliers.
This proposal outlines a centralized, federally managed compliance infrastructure that would allow U.S. wood product suppliers to meet EUDR obligations in a realistic, scalable, and verifiable way.
Problem Summary
EUDR Compliance requires operators to submit a Due Diligence Statement (DDS) with geolocation, legality, and deforestation-free assurances for each shipment of wood-based products.
U.S. timber supply chains are composed of thousands of small, non-industrial forest landowners, often harvesting only once per generation.
Sawmills receive timber from hundreds of distinct plots annually, resulting in mixed-origin lumber that is impractical to trace to individual logs.
Current systems in the U.S. are not equipped to generate, store, or pass along standardized compliance data.
Proposed Solution
A federally managed, plot-based compliance database maintained by the U.S. Department of Agriculture (USDA), with the following structure:
1. Pre-Registration of Forest Plots
Forest landowners voluntarily register plots in a centralized database.
Each plot is geolocated using precise GPS or GIS polygon data.
Ownership documentation, harvest permits, sustainability certifications, and land-use history are uploaded and verified.
Large plots may be subdivided into grid-based identifiers, allowing harvest-level specificity within large parcels.
2. Unique Plot Codes Issued
Each sub-plot or harvest unit receives a unique identifier (Plot ID).
Landowners retain these codes and provide them to harvesters at time of logging.
3. Digital Handoff in the Supply Chain
Harvesters provide Plot IDs, harvest date ranges, and species information to the receiving sawmill.
Sawmills maintain a ledger of batch inputs, linking them to Plot IDs.
When batches are processed and product is sold, the resulting shipment includes a list of all contributing Plot IDs.
4. DDS Support for Exporters
Exporters or EU-bound operators use the Plot IDs to access the national database.
From the registry, they retrieve all data required for the DDS: geolocation, legality documentation, deforestation-free status, and harvest timeline.
Even if a shipment includes wood from multiple plots (e.g., A, B, C, D), the operator can affirm compliance for each source individually and submit the full list.
Verification of Compliance with EUDR Requirements
The proposed system structure fully aligns with the core data and due diligence requirements specified in Regulation (EU) 2023/1115:
Plot-level geolocation and polygon data are pre-verified and stored centrally.
All legal documentation and deforestation-free assurances are linked to unique plot identifiers.
Operators are able to submit a Due Diligence Statement listing all origin plots used in a shipment, meeting Article 9.1(d) and Annex II requirements.
By identifying wood sources as "Plot A, B, C, or D — all verified legal and deforestation-free," operators demonstrate negligible risk, as defined under Article 10.
This traceability structure enables compliance even when wood is mixed during processing, ensuring integrity without requiring individual log tracking.
This approach ensures that the proposed system is not only operationally realistic but also legally sound under current EUDR provisions.
What Does EUDR ACTUALLY Require?
There is persistent confusion around whether the EU Deforestation Regulation (EUDR) demands tracking of individual logs from stump to shelf. The short answer is: no, it does not.
According to Article 9(1)(d) of Regulation (EU) 2023/1115, operators must submit a Due Diligence Statement (DDS) that includes:
"the geolocation of all plots of land where the relevant commodities were produced, as well as the date or time range of production."
This language makes it clear that the obligation is to trace wood products back to the plots of land where they originated—not to individual logs.
The regulation consistently refers to "plots," "commodities," and "shipments" — not logs, boards, or units.
Even under Annex II, which outlines the data fields required in a DDS, there is no requirement for:
• Unique log identifiers
• Log-by-log movement records
• Individual log geolocation
Instead, the emphasis is on ensuring that all contributing plots of land:
• Are geolocated with sufficient precision (typically via GPS or GIS polygon)
• Have documentation of legality of harvest under the producer country's laws
• Are deforestation-free as of December 31, 2020
The regulation also introduces the concept of "negligible risk" in Article 10. This allows an operator to submit a DDS covering wood from multiple verified plots (e.g., A, B, C, D), provided all of them are proven compliant.
In other words: If every source plot is known, documented, and compliant, then the shipment is compliant — even if the logs were mixed during processing.
There is no requirement to say, "Log A21 came from GPS coordinates X/Y."
As long as operators can:
1. Identify every source plot contributing to a product or shipment,
2. Prove those plots meet the legal and environmental standards,
3. Provide the appropriate geolocation and harvest date range,
...then the requirements of the EUDR are met.
🔹 Illustrative Example
Imagine wooden chairs being sold into the EU. The seats, backrests, and legs are made from hardwood sourced from different forest plots.
Each of these plots:
• Has been geolocated and registered
• Includes documentation proving legality of harvest
• Shows no deforestation since December 31, 2020
The sawmill that processed the logs tracked the Plot IDs associated with each incoming load and retained that record. The manufacturer cannot say which plot provided the specific piece used in the chair arm — but they can confirm that all the wood came from compliant, registered sources.
The exporter retrieves the supporting documentation tied to each Plot ID, lists them in the DDS, and submits that to the EU.
Because every potential source is verified and compliant, the product meets the EUDR requirement for traceability and negligible risk — even though the exact log-to-part relationship is unknown.
This is the legal standard. Absolute certainty of individual log identity is not required — comprehensive documentation of all source plots is.
This is exactly what the proposed USDA-style Plot ID system delivers: traceability by design, built for how U.S. forestry and manufacturing actually operate.
Key Advantages
Scalable: Works for any size landowner or mill without requiring one-to-one log tracking.
Minimally burdensome: Landowners register once; harvesters and processors pass simple numeric codes.
DDS-Ready: Data is stored in a form directly aligned with EUDR DDS fields.
National credibility: A USDA-managed registry offers authoritative verification for EU regulators.
Recommended Implementation
Pilot the system with a single state or region.
Use USDA Forest Service or NRCS channels for landowner outreach and registration.
Develop simple interfaces for uploading and retrieving documentation.
Create batch-tracking templates and education materials for sawmills.
Integrate with downstream export compliance tools.
Conclusion
The European Union has signaled that the EUDR will remain a central regulatory instrument with limited room for significant exemptions or modifications. As global sustainability and due diligence initiatives like the Corporate Sustainability Due Diligence Directive (CSDDD) continue to evolve, regulatory expectations around traceability, legality, and responsible sourcing are likely to expand.
Rather than viewing the EUDR as a temporary challenge, the U.S. forestry industry has the opportunity to establish a long-term compliance framework that meets current requirements while remaining adaptable to future demands. A federally managed, plot-based registry offers a realistic, credible, and scalable solution that not only preserves access to the EU market, but positions American operations to lead in a future defined by supply chain transparency.
For more information on EUDR:
Official EUDR webpage:
EUDR Regulation:
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