Responsible timber procurement in Germany operates at the intersection of EU regulation, national guidelines, and voluntary procurement standards adopted by public authorities and private sector buyers. This article explains the legal requirements that apply to timber buyers in Germany, how certification evidence is used in due diligence processes, and what public procurement rules say about specifying certified wood products.

From EUTR to EUDR: The Legal Baseline

The EU Timber Regulation (EUTR, Regulation 995/2010) entered into force in March 2013. It prohibits the placing on the EU market of timber that has been illegally harvested and requires operators — companies placing timber or timber products on the EU market for the first time — to exercise due diligence. Due diligence under the EUTR means gathering information about the timber's origin and characteristics, assessing the risk of illegal origin, and mitigating that risk where it is not negligible.

Germany transposed the EUTR into national law through the Holzhandels-Sicherungs-Gesetz (HolzSiG). The Bundesanstalt für Landwirtschaft und Ernährung (BLE) acts as the competent authority for enforcing the regulation in Germany.

The EU Deforestation Regulation (EUDR, Regulation 2023/1115), which is being phased in, goes further. It requires that certain commodities and derived products — including cattle, cocoa, coffee, palm oil, soy, wood, and rubber — placed on the EU market must be deforestation-free and produced in compliance with the relevant legislation of the country of production. For wood products, this means operators must be able to demonstrate, with geolocation data at plot level, that the wood did not come from land deforested after 31 December 2020.

EUDR scope for wood products

The EUDR covers sawn wood, veneer sheets, plywood, particle board, fibreboard, wood in the rough, wood charcoal, pulp, paper, paperboard, printed books, and furniture, among other categories. Operators and traders have different obligations depending on their position in the supply chain.

How Certification Evidence Supports Due Diligence

FSC and PEFC certification are not mandatory under either the EUTR or the EUDR. However, they function as one form of evidence within a due diligence system. Holding a current CoC certificate from a certified supplier reduces the information-gathering burden and supports risk assessment by demonstrating that a third-party audit has verified the supplier's claims about material origin.

Under the EUTR, certification evidence was generally treated as reducing but not eliminating the obligation to verify legality. For high-risk countries of origin, additional documentation remained necessary even when certified suppliers were used. The same logic is expected to apply under the EUDR, where geolocation data and country-of-production compliance documentation are required regardless of certification status.

For low-risk sourcing regions — which include most EU member states and several OECD countries — certification from a recognised scheme, combined with supplier declarations, typically satisfies the risk mitigation requirements of a proportionate due diligence system.

Public Procurement in Germany

Germany's public procurement rules are set out in the Vergabeverordnung (VgV), which implements the EU Public Procurement Directive (2014/24/EU). Public authorities in Germany can reference environmental criteria in technical specifications and award criteria, including criteria related to sustainable timber sourcing.

The Umweltbundesamt (UBA) and the Beschaffungsamt des BMI publish guidance for public buyers on sustainable procurement of wood products. This guidance generally recommends that public authorities specify timber from:

  • FSC-certified or PEFC-certified sources with valid chain of custody certification
  • Suppliers able to demonstrate legal compliance under the EUTR/EUDR due diligence framework
  • Alternatively, suppliers providing verified equivalent evidence of sustainable sourcing

Under EU procurement rules, contracting authorities cannot mandate a specific certification scheme by name. They must accept equivalent evidence where a supplier can demonstrate that their product meets the underlying criteria, even if they do not hold the specific certification named in the specification. In practice, buyers typically name FSC or PEFC as examples and include an "or equivalent" clause.

Private Sector Procurement Frameworks

Major German retailers, construction companies, and paper buyers often adopt procurement policies that reference certification. The following contexts are typical in German practice:

Retail and paper

German retailers affiliated with the European Paper Packaging Alliance (EPPA) or operating under own-brand sustainability commitments commonly require FSC or PEFC certification for wood-based packaging and paper products. Compliance is typically demonstrated through supplier self-declarations backed by a valid CoC certificate code that can be verified in the relevant database.

Construction timber

German construction contracts increasingly include sustainability specifications for structural timber, engineered wood products (such as CLT and glulam), and formwork. Architects and project managers specifying DGNB or LEED-certified buildings often require certified timber to contribute to points under material credits. The DGNB (Deutsche Gesellschaft für Nachhaltiges Bauen) system recognises both FSC and PEFC as acceptable certification schemes for timber materials.

Furniture manufacturing

German furniture manufacturers exporting to sustainability-conscious markets in the UK, Nordic countries, and North America often hold both FSC and PEFC certificates to satisfy the widest range of buyer requirements. The German furniture industry association (VDM) has issued guidance on certification requirements for its members.

What Buyers Should Check

When verifying a supplier's certification claim, buyers should confirm the following:

  • The certificate is currently valid (not suspended or expired)
  • The company name on the certificate matches the legal entity supplying the goods
  • The product scope on the certificate covers the specific product type being purchased
  • The certificate was issued by an accredited certification body

Both the FSC certificate database (info.fsc.org) and the PEFC certificate search (pefc.org) allow free searches by company name or certificate code.

Further Reading