Wood and Timber and the EUDR: What Indonesian Exporters Must Know
EUDR wood and timber Indonesia guide: how SVLK, FLEGT and the EUDR fit together, what EU buyers need from concessions, plantations and community forests.
Indonesian wood and timber products sold into the EU must be traceable to the areas where the trees were harvested, come from land with no deforestation or forest degradation after 31 December 2020, and be legal, with the EU operator filing a due diligence statement. Indonesia’s SVLK legality system and its FLEGT licensing with the EU give exporters a head start on legality, but they do not by themselves supply the geolocation and deforestation-free evidence the EUDR adds.
From the Timber Regulation to the EUDR
The EU Timber Regulation (EUTR) required importers to minimise the risk of illegal timber. Indonesia responded by building SVLK, the timber legality and sustainability verification system (Sistem Verifikasi Legalitas dan Kelestarian), and signed a Voluntary Partnership Agreement with the EU. Indonesia became the first country to issue FLEGT licences, which meant licensed timber was treated as legal under the EUTR.
The EUDR replaces the EUTR and goes further. It asks not only whether timber was legally harvested, but whether the harvest area was deforested or degraded after the cut-off date, and it requires geolocation of the plots of land where the trees were harvested. Commission guidance indicates that operators previously covered by the EUTR follow the 30 December 2026 date even if they are micro or small enterprises; confirm this on the Commission site.
Where Indonesian wood comes from
| Source | Typical products | EUDR issues |
|---|---|---|
| Natural forest concessions (PBPH, formerly HPH) | Plywood, sawnwood, mouldings from meranti and other species | Geolocation of annual cutting blocks; degradation if converted |
| Industrial plantation forests (PBPH for plantations, formerly HTI) | Pulp and paper, some plywood and sawnwood from acacia and eucalyptus | Plantation establishment after 2020 on natural forest is degradation or deforestation |
| State forest enterprise in Java (Perhutani) | Teak, pine, mahogany | Well-mapped compartments |
| Community and private forests (hutan rakyat) | Sengon, jabon, teak, mahogany for plywood, furniture and pallets | Thousands of small woodlots, often mixed with crops |
| Land clearing for other uses | Logs from conversion | Non-compliant if land was forest after 2020 |
See PBPH licences for the concession framework.
SVLK and the EUDR
SVLK covers forest management units, industries and traders, with chain of custody through the timber administration system. Its documents track timber from harvest to export. Small community forest producers use a supplier declaration of conformity rather than a full audit.
How SVLK helps under the EUDR:
- Legality. Strong evidence of legal harvest and trade. Check the Commission guidance on how FLEGT-licensed timber is treated under the EUDR.
- Chain of custody. Existing traceability from forest unit to mill.
- Supplier lists. Industries know their source forest units.
What SVLK does not do:
- Provide plot geolocation in the format the EUDR needs for every harvest area.
- Test for deforestation or forest degradation against the 31 December 2020 cut-off.
- Exclude timber from land converted after 2020 if the conversion was legal.
See wood due diligence.
Forest degradation: the wood-specific test
The EUDR defines forest degradation as converting primary or naturally regenerating forest into plantation forest or other wooded land, or primary forest into planted forest. For wood, this is a separate test. Acacia pulpwood from a plantation established on natural forest after 2020 fails, even though the land remains forest. See the forest definition.
Community forest timber
Java’s hutan rakyat supplies a large share of the fast-growing timber used in plywood, light construction and furniture. These are smallholder woodlots on private land, often mixed with crops. Most are on long-established farmland, so deforestation risk is low, but geolocation and traceability through log traders are hard. See wood smallholders.
Products covered
Annex I covers many wood products, from logs and sawnwood to plywood, pulp, paper and furniture. See wood derived products.
Pulp and paper
Pulp and paper is one of Indonesia’s largest wood-based export sectors, supplied by acacia and eucalyptus plantations, many on peat in Sumatra and Kalimantan. For EU-bound pulp and paper, each supplying compartment needs geolocation and an establishment date showing no conversion of natural forest after 2020. See wood risk assessment.
Where to start
- Classify your products against Annex I.
- Map your supply chain to forest management units and woodlots.
- Obtain harvest area geolocation from each source.
- Screen harvest areas for deforestation and degradation since 2020.
- Use SVLK documents as legality evidence and fill the gaps.
See the EUDR hub for the full topic map and our EUDR compliance services for mapping and screening support, or message us on WhatsApp.
Frequently asked questions
Does the EUDR apply to Indonesian wood products?
Yes. Wood is a covered commodity, and Annex I lists many wood products, including logs, sawnwood, plywood, pulp, paper and wooden furniture. They need geolocation of harvest areas, deforestation- and degradation-free evidence since 31 December 2020, and legality.
Is an SVLK or FLEGT licence enough for the EUDR?
No. SVLK and FLEGT licensing are strong evidence of legality, but the EUDR also requires geolocation of the harvest area and proof of no deforestation or forest degradation after the cut-off date.
What is different for wood compared with crops?
Wood is also tested for forest degradation: converting natural forest into plantation forest after 2020 makes the wood non-compliant, even if it stays forest.
Does the EUDR replace the EU Timber Regulation?
Yes. The EUDR replaces the EU Timber Regulation, with transitional arrangements. Operators already covered by the EU Timber Regulation follow the earlier application date.