We recently sat down with Lukas Freise, Head of Resource Department at Geschäftsleiter Arbeitsgemeinschaft Rohholz im Hauptverband der Deutschen Holzindustrie e.V. (HDH, Association of the German Wood Industry), to discuss his experience and insights on the EU Deforestation Regulation (EUDR). For the past two years, Lukas has been closely involved with the topic, advising companies, working with European associations and ministries, and building networks to share vital EUDR-related updates.
In this interview, Lukas sheds light on common misconceptions, the challenges faced by both upstream and downstream participants, and how companies can prepare for what’s ahead.
Interu: To begin, can you give us an overview of HDH’s role and your work in relation to the EUDR?
Lukas: I lead the resource department at HDH, where EUDR has been a major focus for the past two years. My role involves advising numerous companies on compliance, staying in contact with European associations and German ministries, and establishing networks to share EUDR-relevant news among our members.
Interu: From your conversations with companies, what are the most common false assumptions you’ve heard about the EUDR?
Lukas: One big misconception is around the obligations of SMEs versus non-SMEs. For example, companies often ask their suppliers for unnecessary information, thinking it reduces their risk. But this actually creates difficulties for suppliers when it’s not required.
Another assumption is about direct traceability – people imagine it’s like tracing an egg back to the chicken. In reality, it’s not necessary to trace every wood product back to a specific forest or tree. This is because of the declaration in excess mechanism that can be used so you declare that material could come from a range of sources rather than pinpointing one.
And finally, there’s confusion about geocoordinates. They aren’t required for every part of the chain of custody, just the point of origin (where the risk of deforestation is). The European Commission realised the data volume would be unmanageable.
Interu: Why do you think the European Commission has made it optional for operators to sharing the geocoordinates included in a DDS with downstream stakeholders?
Lukas: Authorities will check the coordinates themselves. If the operator doesn’t have them in their own due diligence procedures and DDS, they’ll still need to collect them from suppliers. This means that in practice, both operators and authorities will be checking, and therefore the likelihood of handling materials linked to deforestation should be lower
There are also data security considerations. The sourcing areas can be sensitive – for example, roundwood buyers might not want competitors to know exactly where they source from.
Interu: A lot has been written about challenges for upstream participants in less developed markets. But what about in a developed EU market like Germany?
Lukas: Interestingly, I wouldn’t describe Germany’s forestry industry as highly developed. For instance, overseas producers of coffee or cocoa often use mobile technology. But here in Germany, 48% of forestry is privately owned, often in groups, and some of their members don’t even have email addresses.
The sector is still very paper-based and has resisted digitalisation. Many smaller forest owners just want to harvest every few years and aren’t commercially dependent on selling wood. With government subsidies, some may decide not to sell at all – which reduces the available supply of wood.
Interu: You’ve said before that companies who don’t digitise won’t survive. How are you supporting members with this digital transition?
Lukas: Not every member has an IT department – many rely on external software providers or need to adapt existing internal systems to meet EUDR requirements. Even among HDH members, most are struggling, and many say they won’t be ready by the end of the year.
EUDR is only as strong as the weakest link in the chain of custody. If we don’t have digital data from the forests, compliance becomes very difficult. We work with members to help them understand the requirements, but for those without even an email address, it’s hard for our communications to reach them.
Interu: You know us for our traceability platform used by the wood industry and wider to manage due diligence, store data and engage suppliers and customers. So when it comes to data management, what do you think a system specifically needs to do to solve for EUDR compliance?
Lukas: A strong system should manage reference and verification numbers efficiently. It needs to pool data, collect it from suppliers in different formats, connect incoming data with outgoing data, sort outdated reference numbers, and store everything for at least five years.
There’s also been discussion about whether SMEs should voluntarily prepare due diligence statements. The latest FAQs confirm they can, if they choose to.
Interu: Standards for data exchange seem fragmented across the industry. We are seeing our customers rely on GS1’s standard in EDI, and the CEPI standard for the paper and print industry in particular. What do you think needs to happen for a general standard to be adopted?
Lukas: There isn’t one universal standard. In Germany, for roundwood the ELDAT standard – and its latest version, ELDAT Smart – is already adapted for EUDR and available on GitHub. HDH was part of the committee that ensured the reference number became a required field.
Other countries use different standards: papinet for paper, which is older and not on GitHub; Austria has its own system; and in the furniture industry, EDI is widely used. The key is for IT companies to adopt these standards so data can be shared consistently across supply chains.
Interu: Finally, what would you say to companies waiting to see if EUDR will be delayed, simplified, or even cancelled?
Lukas: In my opinion, the EUDR will definitely be introduced. The question is timing – it might happen later this year, or at the end of 2026.
There’s currently an EU call for evidence on an environmental omnibus that might include EUDR. If simplifications are introduced, there wouldn’t be enough time to adjust before enforcement, so an extension is the only realistic option.
But the mechanism is too complex to fundamentally change, unlike CSRD where company sizes can be exempted. My advice is clear: prepare now, because EUDR is coming.
Another important topic is the transition period. We’ve seen inconsistencies between German and English versions of the official guidance documents, which causes confusion. And for wood, unlike soy or palm, transition is critical because it can take two years for stock to dry.
One idea to outsmart the EUDR at this point is mixing stock from the transition period with new stock come 2026 to ensure you always have a reference number to pass onto customers.
While enforcement timelines may shift, the EUDR is not going away. Companies need to digitise, standardise, and prepare their supply chains now – waiting for simplification is not a viable strategy.
To get in touch with Lukas you can reach him at: eudr@holzindustrie.de.
