Amendments to EUDR could harm EU efforts to block Russian and Belarusian ‘conflict timber’

Europe’s blood-stained birch problem

In mid-2022, in response to Russia’s invasion of Ukraine, the EU imposed sanctions on wood products from Russia and Belarus. These sanctions reflect the importance of the forestry sector to the Russian and Belarusian economies, and that the Russian military profits directly from timber sales. Russia’s timber business is also connected to oligarchs with close ties to the Kremlin – including some sanctioned by the EU. 

In January 2025, our Blood-stained birch investigation revealed that the EU had imported more than €1.5 billion of illegal Russian and Belarusian birch plywood since these sanctions took effect. That is the equivalent of twenty container-loads of birch ply arriving on EU shores every single day, in violation of sanctions as well as the European Union Timber Regulation (EUTR), which bans imports of all illegal wood.

Imports of conflict ply have continued since Earthsight’s last calculations, which were based on data until October 2024. New analysis shows that in the six months from November 2024 to April 2025, the EU has imported a further €273 million worth.

Our January investigation received widespread media coverage and prompted the EU Commission and Parliament to respond by calling for stronger sanctions enforcement and expansion of wood sanctions in March. Their stance served to reiterate crucial support for Ukraine in a stormy geopolitical climate. 

Then in May an internal threat emerged – a group of Member State agriculture ministers tabled a proposal calling for “substantial simplification” of the EU Deforestation Regulation (EUDR). A follow up letter spearheaded by Luxembourg garnered the support of more agriculture ministers, with the new German government also having made it a priority. These proposals are the latest in a series of efforts by a group of politicians in Europe to delay and weaken this much-improved successor to the EUTR.

The proposals call for the creation of a new ‘insignificant risk’ or ‘no-risk’ category of producer countries in addition to the existing low, standard and high-risk categories already envisaged by the EUDR. A ‘no-risk’ rating would be given to countries having insignificant deforestation risk, and where national laws already limit deforestation and forest degradation. 

Though this seems a relatively harmless suggestion, it is far from it. Companies would be exempt from providing geolocation data – a core pillar of the EUDR – for goods sourced from the new ‘no-risk’ countries. EU states’ national enforcement authorities would not be obliged to scrutinise those goods. The agriculture ministers’ proposal also calls for doing away with the EUDR’s current requirement for authorities to carry out a minimum number of checks to detect illegality or deforestation-tainted goods for the new category of no-risk countries. 

On 9 July, the EU parliament also voted for a non-binding resolution which asked the Commission to overturn the current country benchmarking and introduce a ‘no risk’ category. However those who voted for the non-binding resolution may not have grasped the wider consequences a no-risk category would inevitably entail.

Earthsight’s analysis, based on in-depth investigations into the illegal wood trade, shows that if the European Commission were to introduce a ‘no-risk’ category into the law, it would not only open the EU to more illegal timber, it would also hinder the implementation of EU sanctions on Russian and Belarusian wood. 

Due to take effect from the end of December 2025, the EUDR is the EU’s most meaningful effort yet to end its complicity in skyrocketing levels of forest destruction and affiliated human rights abuses. It does this by regulating the trade in timber, palm oil, soy, beef and other products driving that destruction. The law would also greatly aid efforts to stem the EU’s imports of conflict plywood from Russia and Belarus.

Here’s why the latest attempt to gut the EUDR could hinder the EU’s enforcement of its sanctions on Russian and Belarusian wood imports.

Laundering routes for Russian wood could be exempt from scrutiny under the proposed ‘no-risk’ category 

Earthsight’s nine-month undercover investigation showed that the only method by which Russian timber is still able to enter the EU after sanctions took effect is via third countries - particularly Turkey, Georgia, Kazakhstan and China. Repackaged and relabelled by launderers in these third countries and accompanied with fraudulently issued certificates of origin, the goods are often passed off as being made from trees harvested in those third countries, rather than in Russia or Belarus.

All these third countries have low deforestation rates, meaning they would likely be eligible for ‘no-risk’ status under the new proposal. Authorities in EU countries would not have to carry out any checks on goods from those countries. So while Russia and Belarus have been designated ‘high-risk’ countries, adding a new ‘no-risk’ category could offer easy access to goods from countries well-known to be laundering their timber.

Along with bypassing EU legislation, the illegal imports are also a threat to the EU timber industry. They are undercutting EU plywood producers - who have long-warned of the influx of sanctioned wood - and other EU wood users who have made a concerted effort to change their supply chains after the invasion of Ukraine.

An intact EUDR would provide vital additional tools missing from sanctions law - but the ‘no-risk’ proposal could hamstring enforcement

Our report called for sanctions authorities to work closely with EUTR authorities. Some recent actions to enforce sanctions on Russian wood have been undertaken with the help of those authorities. This cooperation between the two sets of authorities will be even more important to stamp out Russian wood imports when the EUDR is in place.

Sanctions only ban the import of Russian and Belarusian wood products if the finished products themselves are made in Russia or Belarus. They do not cover wood products made in a third country (such as China) using Russian or Belarusian timber. This loophole allows Russian oligarchs to continue to profit from EU sales. It also makes it easier for companies to evade sanctions by buying Russian plywood in Europe via a third country and pretending that it was processed in that third country, even when the plywood was entirely manufactured in Russia.

This is where the EUTR comes in: it prohibits imports of all wood from Russia or Belarus if there is a risk that it was harvested illegally. National authorities in EU countries have held that all Russian and Belarusian wood should be considered at risk of illegality. Plywood containing Russian raw material is illegal under the EUTR even if it was processed in China or Kazakhstan.

The EUDR, which will replace the EUTR, will be a stronger piece of legislation, requiring all wood shipments to be accompanied by geolocation data showing where the wood was harvested, submitted in advance of the shipment entering the EU. 

Armed with information on geolocation, both EUDR and sanctions enforcement agencies could scrutinise the probability of timber being produced in a particular region, assessing if imported quantities of wood could plausibly come from a declared patch of forest. Timber launderers, including those investigated by Earthsight, frequently use false harvest location data or offer fake harvest permits to cover Russian wood imports. Our report even documented countries with scarcely any birch forest exporting enormous quantities of laundered birch ply to the EU. Requiring geolocation makes such fraudulent harvest claims much more difficult to pull off. Once geolocation data is known, the same authorities could also use emerging technologies, including isotopic testing, to catch launderers in a lie. 

While Member State authorities can already ask importers for geolocation data on a case-by-case basis under the EUTR, the EUDR makes this a requirement across the board, boosting their ability to find and prosecute sanctions-busters.

Under the new proposal, companies buying conflict wood from ‘no-risk’ countries would be exempt from the geolocation requirement. At minimum, this will mean that enforcement authorities would have to request this information on a case-by-case basis where they have suspicions, as they do now, taking away one of the EUDR’s advantages. But the ‘no-risk’ proposal could have even worse consequences. For example, the proposal could be drafted to prohibit Member State enforcement authorities from requesting any geolocation data for goods coming from ‘no-risk’ countries, which would undermine sanctions enforcement much more significantly.

The same countries supporting the ‘no-risk’ proposal are key entry points for Russian and Belarusian wood

Of the top ten importers of birch plywood in recent months, eight are Member States that have supported the calls to introduce a no-risk category. These countries include Bulgaria (where we linked banned Russian imports to the largest manufacturer of climbing walls in the world), Croatia (gaining prominence as an importer of likely illegal birch plywood in 2025), Czechia, Estonia, Italy, Poland, Portugal and Slovenia.

Together, this group accounts for more than 67% of all EU imports of conflict wood, at a total value of €1.27 billion. When speaking to Earthsight’s undercover investigators, several Russian manufacturers and companies in the laundering countries for Russian wood admitted to having customers in some of these European countries, or using them as entry points for their goods in the EU.

Some policymakers want stronger action on sanctioned wood –  but their EUDR proposal would make that action much more difficult

Policymakers from a range of countries and across the political spectrum have supported open letters and parliamentary resolutions calling for stronger enforcement or expansion of EU sanctions on Russian and Belarusian wood. They have called for strong penalties for those facilitating or greenwashing the war-fuelling trade. Their support is crucial and their interventions have been timely. However, if the ‘no-risk’ proposal were to pass, it would hinder the stronger actions on conflict wood that politicians have also demanded. 

The ‘no-risk’ proposal is a hindrance to the proper enforcement of the EU’s ban on Russian and Belarusian wood imports. The EU Commission must categorically reject this latest attack against the EUDR.