On 17 September 2026, the EUDR Community of Practice (CoP) held its latest open public session, bringing together Competent Authorities (CAs), industry representatives, NGOs, certification experts and the European Commission. With more than 1,200 participants engaged across the wider community, the discussion provided valuable insight into some of the most pressing implementation challenges facing EUDR-affected sectors.
While the session covered multiple commodities, timber emerged as a complex area, particularly around legality verification, certification schemes, substantiated concerns and the role of due diligence. Our Support Team member, Ben Gunneberg, attended on behalf of the BMRC.
A Community Growing in Importance
The Community of Practice continues to establish itself as an influential forum for practical EUDR implementation discussions.
Representatives from Competent Authorities, NGOs and the European Commission all emphasised the value of the initiative.
Jenny Sverker from the Swedish Competent Authority described the past six months as highly productive, highlighting the benefit of both online collaboration and the in-person meeting held in Barcelona. She noted that smaller working groups enabled participants to explore difficult implementation questions in greater depth and stressed that a common understanding of how the regulation should be applied remains essential for success.
WWF’s Anke Schulmeister echoed these sentiments, describing the CoP as a constructive space where stakeholders with different perspectives can work towards practical solutions. However, she also cautioned against creating loopholes that could undermine the objectives of the Regulation.
Karolina Zazvorkova, representing the European Commission as an observer, confirmed that discussions within the CoP are feeding into wider policy considerations and praised the forum as a neutral space for exploring solutions to implementation challenges.
Legality Remains the Number One Concern
One of the clearest outcomes from the session was that legality remains the most significant concern for operators. More than 100 responses were received through the Community of Practice legality survey, with discussions focusing on how operators should assess compliance where legal frameworks, documentation standards and enforcement systems vary significantly between countries.
The message from both authorities and experts was consistent: collecting documents alone is not enough. Operators must demonstrate they understand the legal risks associated with their sourcing areas and undertake appropriate risk assessments. Certification, government records and third-party services may support this process, but none can replace an operator’s responsibility under the EUDR.
For timber businesses, this reinforces the importance of understanding what the available documentation and assurance systems demonstrate, while also considering other credible information relevant to the risk assessment.
Testing the Regulation Against Real-World Scenarios
An important feature of the Community of Practice has been the use of commodity case studies and practical supply-chain scenarios to test how EUDR requirements may operate in real situations. These have covered beef and soy, palm oil, cocoa and coffee, and timber, examining issues including legality, traceability, land rights, certification, smallholders, third-party information and changing roles within supply chains.
The value of these exercises is that they expose areas where the Regulation may appear relatively straightforward in principle, but becomes more difficult to interpret when applied to actual sourcing and trading arrangements.
Lessons from the Timber Case Study
The timber case study generated significant interest, particularly regarding sourcing from higher-risk regions such as Brazil.
A key theme was the difference between traditional certification systems and EUDR requirements.
Sam Lawson of Earthsight highlighted cases where timber suppliers continued to hold valid certification despite facing accusations of legal breaches. Under some certification systems, allegations may not affect certification status until all legal appeals have been exhausted.
However, EUDR operates differently.
Where credible evidence exists indicating legal non-compliance, operators must assess whether negligible risk can still be demonstrated. Reliance on certification alone may therefore be insufficient.
The timber case study highlighted a number of additional sources of information that operators may need to consider where concerns have been identified, including:
- Review annual audit reports in detail.
- Investigate ongoing court cases and legal proceedings.
- Monitor NGO reports and watchdog databases.
- Consider all available information when assessing risk.
The wider point is that certification and other assurance mechanisms need to be considered alongside any credible additional information relevant to the operator’s risk assessment.
Certification as Part of Due Diligence
Across the various commodity discussions, there was broad agreement that certification schemes can play an important role in supporting EUDR due diligence, although under the current approach they do not provide an automatic “green lane” into the EU market.
Certification can provide valuable evidence on traceability, legal compliance and control systems and can help operators understand applicable national legal requirements. The key issue is how certification is integrated into the operators’ due diligence system and how it is considered alongside other relevant information.
The timber case study presented illustrates the particular challenge where credible information emerges that may conflict with, or go beyond, the assurance provided by a certificate. In those circumstances, the operator still needs to consider that information when reaching its own risk conclusion.
The discussion around national systems also highlighted their potential value in supporting EUDR due diligence. National systems can provide detailed knowledge of applicable national laws and the mechanisms used to demonstrate and verify compliance. Understanding how these systems and the evidence they generate can be effectively integrated into operator’s due diligence systems will therefore be an important area for further development.
Operators must still reach and document their own negligible-risk conclusions.
The Challenge of Third-Party Service Providers
The role of service providers and geospatial assessment firms was another major topic.
More than 60 service providers contributed feedback through the Community of Practice process.
While participants acknowledged that these services often reduce the burden on operators, concerns were also raised about overly risk-averse approaches that can unintentionally exclude smallholders or smaller suppliers.
One recurring challenge is transparency.
Operators increasingly rely on external tools for legality assessments, satellite monitoring and geolocation validation. However, authorities expect operators to understand the methodologies being used rather than simply accept conclusions at face value.
As EFI’s Josil Murray explained, there is currently no minimum transparency threshold specified. Instead, the burden remains on the operator to determine whether the information is sufficiently verifiable and conclusive to support a negligible-risk finding.
For timber businesses using third-party monitoring platforms, understanding how risk scores are generated may become just as important as the results themselves.
Supply Chain Dynamics Remain Challenging
The case studies also highlighted how EUDR obligations can become more complex as products move through supply chains. Issues discussed included mixing and aggregation, the loss of visibility where intermediaries are involved, re-imports into the EU of products previously exported from the EU, and situations where companies may have different regulatory roles at different points in the supply chain.
These scenarios demonstrated that traceability is not simply about collecting information at the point of origin. Operators also need to understand how information, product identity and due diligence conclusions are maintained as commodities move between suppliers, processors, traders and markets.
Several of these questions remain under discussion, illustrating why practical testing of real supply-chain scenarios is an important part of the Community of Practice’s work.
Substantiated Concerns: An Area Still Evolving
One of the most debated topics of the webinar was the treatment of substantiated concerns.
No definitive conclusions emerged, but several important themes did.
Competent Authorities acknowledged that operators may face challenges responding to concerns within the 30-day timeline currently discussed.
Perhaps more significantly, the Dutch Competent Authority indicated that operators should consider informing authorities whenever significant concerns arise, even where there is uncertainty about whether the issue formally meets the definition of a substantiated concern.
Participants also discussed the distinction between:
- Formal substantiated concerns.
- Other relevant information that may indicate risk.
A recurring point in the discussion was that operators should not ignore relevant information simply because it does not meet the formal threshold of a substantiated concern.
For timber importers this means monitoring NGO reports, media investigations, legal cases and third-party alerts as an important part of ongoing due diligence.
Obligation of Means or Obligation of Results?
One of the most thought-provoking debates centred on a fundamental legal question.
Some participants argued that EUDR should be viewed as an “obligation of means”, requiring operators to demonstrate proportionate good-faith efforts.
Others, particularly NGO representatives, argued that EUDR is more accurately an “obligation of results”, meaning both due diligence and product compliance must ultimately achieve a specific outcome before products can be placed on the market.
The discussion highlighted that this issue remains unresolved and will likely continue to shape regulatory interpretation in the months ahead.
Whatever the eventual interpretation of this debate, operators will need both to document their due diligence and to be able to substantiate the negligible-risk conclusions on which placing products on the EU markets depends.
What Timber Companies Should Be Doing Now
As implementation deadlines approach, timber operators should focus on four priorities:
- Ensure legality assessments consider both documentary evidence and other credible information relevant to identified risks.
- Understand how certification and chain-of-custody systems can be integrated effectively into the operator’s wider due diligence system.
- Monitor relevant external information sources, including legal proceedings and NGO reports.
- Prepare procedures for handling substantiated concerns and other new risk information.
The webinar reinforced the importance of bringing these different sources of evidence and assurance together within a coherent and documented due diligence system.
Final Thoughts
Perhaps the most important message from the Community of Practice was that achieving EUDR compliance will depend on continuous dialogue and shared learning.
The timber sector faces unique challenges due to complex supply chains, legality risks and varying governance standards across sourcing regions. However, the discussions demonstrated a growing willingness among authorities, industry and civil society to work through these issues collectively.
As further Community of Practice reports are published, particularly the upcoming timber-focused outputs and TRACES discussions, businesses should continue engaging with these forums. The practical insights emerging from the CoP are increasingly becoming one of the most valuable resources available for understanding how EUDR will work in practice rather than simply on paper.
Further Reading
The EUDR Community of Practice case studies and supporting materials provide considerably more detail on the scenarios discussed during the session:
EUDR Community of Practice resources and case studies
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