The 2023 update to the EU Timber Regulation (EUTR), originally adopted in 2013, marks a significant tightening of due-diligence expectations for importers of wood and paper products into the European Union. The revised guidance places greater emphasis on the need for companies to verify the legality of timber origins, prevent deforestation-linked sourcing, and ensure full traceability of forest-risk commodities. For pulp and paper manufacturers, furniture producers, and wood-product importers, this regulatory shift demands more robust systems for verifying harvest locations and a stronger commitment to public transparency about supply chain practices.

 

A central element of the updated EUTR due-diligence framework is the requirement to collect verifiable evidence of legal harvesting and supply chain integrity. The 2023 guidance underscores that companies must go beyond documentation provided by suppliers to independently assess risk using reliable data sources. Open GIS forest cover data, such as those provided by Global Forest Watch, Copernicus, or national forestry agencies, can play a critical role in this process. By overlaying supplier-provided harvest coordinates with GIS datasets, companies can confirm that wood was harvested from authorized concessions and not from protected areas or recently deforested land. This geospatial analysis enables firms to identify discrepancies, such as claims of legal sourcing that conflict with observed land-use patterns, and to take corrective action before timber enters EU markets.

 

To operationalize these enhanced vetting requirements, pulp and paper companies should integrate GIS verification into their standard supplier onboarding and renewal processes. For each batch of timber or wood fibre imported, firms should require suppliers to provide precise harvest location data, ideally in geocoordinate form. Compliance teams can then cross-reference these coordinates against open GIS forest cover datasets to verify that harvest sites align with legal and sustainable land use. This verification step should be documented in supply chain records, including maps, screenshots, or GIS files demonstrating how the assessment was conducted and what conclusions were reached. By embedding GIS validation into existing procurement workflows, companies can ensure compliance with EUTR requirements while reducing the risk of inadvertently sourcing from high-risk regions.

 

Beyond internal checks, the 2023 EUTR update encourages greater supply chain transparency through public disclosure of due-diligence processes and outcomes. Pulp and paper companies, as well as other wood-product importers, are expected to publish annual reports that detail their efforts to assess and mitigate forest-risk sourcing. A strong template for such disclosures should include key elements such as a description of the company’s supply chain due-diligence policies, an overview of supplier risk assessments conducted during the reporting period, a summary of GIS verification activities, and a list of corrective actions taken where risks were identified. Where possible, companies should publish aggregated data on harvest locations, supplier countries of origin, and the volume of wood or paper products sourced from low-, medium-, and high-risk regions.

 

The public disclosure report should also explain how the company engaged with suppliers to address identified risks. For example, if GIS analysis revealed that a supplier’s harvest site overlapped with a protected area or recent deforestation zone, the report should describe the remediation steps taken. These could include requiring the supplier to provide additional evidence of legal harvesting, suspending purchases until concerns are resolved, or switching to alternative, lower-risk suppliers. By documenting these actions, companies can demonstrate to regulators, customers, and stakeholders that they are meeting not only the letter but also the spirit of the EUTR.

 

To support effective public reporting, companies should establish internal procedures for regularly updating and consolidating supply chain due-diligence data. This may involve setting a quarterly or semi-annual schedule for GIS assessments and supplier risk reviews, with results fed into a centralized database that facilitates easy report generation. Leveraging digital tools for data management, mapping, and report creation can help streamline this process and ensure consistency across different business units and sourcing regions. Firms may also consider third-party verification of their public reports to further enhance credibility and demonstrate alignment with best practices.

 

The 2023 EUTR update reflects the European Union’s growing focus on combating global deforestation and promoting legal, sustainable trade in forest products. For companies operating in wood and paper supply chains, adapting to these strengthened due-diligence requirements is not only a regulatory necessity but also a strategic opportunity to build trust with customers and stakeholders. By adopting open GIS data verification methods and committing to transparent disclosure of their efforts, businesses can help protect forest ecosystems, reduce legal and reputational risks, and contribute to global sustainability goals.