EUDR and Wood: Covered Products, HS Codes, Supply-Chain Risks and Due Diligence

Yes: wood is a relevant commodity of the EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115), and its 31 Annex I entries apply from 30 December 2026. Operators that are natural persons or micro or small undertakings established as such by 31 December 2024 start on 30 June 2027 only for lines outside the Annex to Regulation (EU) No 995/2010; products in that Annex apply from 30 December 2026 (Article 38(3)).

The EU Deforestation Regulation makes the operator that first places wood on the EU market, or exports it, prove the wood is deforestation-free, legal and covered by a due diligence statement. Wood adds two elements: species names and the forest-degradation test.

The wood rules in force on 24 October 2026 are summarised below.

Which Wood Products Does the EUDR Cover?

Annex I lists wood in 31 entries since 18 September 2026, from ex 4401 to ex 9406 10 00. Commission Delegated Regulation (EU) 2026/2102, in force since that date, added the "ex" prefix and line-level exclusions, such as used products. No volume threshold applies (FAQ 2.3).

Chapter 44 and 94 Lines in Annex I: Logs, Sawn Wood, Veneer, Panels and Joinery

Sixteen of the 31 entries run from ex 4403 to ex 9406 10 00; all except ex 4408 exclude used and second-hand products. Sawn wood under ex 4407 exceeds 6 mm; veneer under ex 4408 does not. EU imports under Chapter 44 reached EUR 10.85 billion and 22,898,644 tonnes in 2025 (Eurostat Comext).

The 16 lines appear below in EUDR Annex I wording.

Deferral: operators that are natural persons or micro or small undertakings established as such by 31 December 2024 (Art. 38(3)); products in the Annex to Regulation (EU) No 995/2010 from 30 December 2026. Trade figures are EU imports under the heading, not scope.

The other six commodities are listed in EUDR Annex I.

Fuel Wood, Packaging, Pulp, Paper and Furniture: The Other Wood Entries

The other 15 entries form four groups with their own pages: fuel wood and charcoal, packaging, pulp and paper, furniture and seats. Sawmill chips and sawdust stay in scope under ex 4401 unless used exclusively as packing material (Guidance C/2026/3896, section 7(b), Q1).

The four groups compare as follows.

W waste; U used; R recovered; P1 single-use packing; P2 reusable packing from first use; C correspondence. Deferral as defined above.

Are Bamboo and Rattan Covered by the EUDR?

No: since 18 September 2026, Annex I note (4) excludes bamboo, rattan and other materials of a woody nature, also under wood lines. FAQ 2.12 treats bamboo as a non-wood forest product, following the FAO, so bamboo components of a wood product need no due diligence; its wood parts stay covered.

Which Wood Products Are Not Covered?

Five groups fall outside: used and second-hand products, goods made entirely from waste material, samples, printed products of Chapter 49 and aircraft and motor-vehicle seats.

These EUDR exemptions are narrow: beyond them, the Annex I line and the production date decide scope. All carve-outs sit under EUDR exemptions.

EUDR Timeline for Wood: When Do the Obligations Apply?

All wood lines apply from 30 December 2026 (Article 38(2)); operators that are natural persons or micro or small undertakings established as such by 31 December 2024 start on 30 June 2027 (Article 38(3)) only for ex 4402, ex 4404, ex 4405, ex 4417, ex 4419, ex 4420, ex 4421 and the six ex 9401 seat lines; products in the Annex to Regulation (EU) No 995/2010 apply from 30 December 2026. No wood line is among the 18 entries applying from 30 December 2027.

The wood timeline has seven dates.

Other dates sit on the EUDR timeline.

Does the EU Timber Regulation Still Apply to Timber Produced Before 29 June 2023?

Yes, until 31 December 2029: the EU Timber Regulation (EUTR), repealed from 30 December 2026, still applies to EUTR timber produced before 29 June 2023 and placed on the market from that date (Article 37(2)). Such timber must then meet Article 3 of the EUDR (Article 37(3)); other wood produced before 29 June 2023 stays outside (Article 1(2)). The transition is set out under EU Timber Regulation.

Who Carries Which EUDR Role and Obligation in the Wood Supply Chain?

Only the operator that first places wood on the EU market or exports it does due diligence and files a DDS; sawmills, merchants and retailers are downstream operators or traders since 26 December 2025.

The five wood actors compare as follows.

The four EUDR roles apply to every commodity; see EUDR roles.

Forest Owners and Harvesting Companies in the EU: Operators

EU-harvested wood is covered like imports (FAQ 2.4): whoever first makes the logs available on the Union market in a commercial activity is the operator (Article 2(15), 2(16)). The duties of EUDR operators bind private and corporate forest owners alike.

Timber Importers and Exporters: Operators

The EU company releasing logs, sawn wood or plywood for free circulation, or exporting wood, is the operator: it applies Articles 8 to 12 and files a DDS first. Its reference number goes to customs before release or export (Article 26(4)).

Are Sawmills and Panel Makers Downstream Operators?

Yes, if every input is covered: a company making sawn wood, panels or joinery from wood all covered by a DDS or a simplified declaration is a downstream operator (Article 2(15b)). Under Article 5 it files no DDS and keeps supplier and customer information for 5 years. For uncovered inputs, such as logs it imports itself, it is the operator (Guidance, section 9; non-binding under Article 15(5)), as explained for downstream operators under the EUDR.

Timber Merchants and Retailers: Traders

A timber merchant or DIY retailer selling wood already placed on the market is a trader (Article 2(17)) and files no DDS. A non-SME trader registers under Article 5, as set out for EUDR traders.

Small Forest Owners in Low-Risk Countries: The Simplified Declaration

A forest owner that is a natural person or micro or small undertaking in a low-risk country, placing wood it harvested there, submits a one-time simplified declaration (Article 4a, Annex III). All 27 Member States are low risk. This is not Article 13 simplified due diligence; see EUDR micro or small primary operators.

How Does EUDR Country Benchmarking Apply to Wood Origins?

Most Chapter 44 wood reaching the EU comes from low-risk countries under Implementing Regulation (EU) 2025/1093: about 82.8 % of 2025 import value, against 16.5 % standard and 0.0 % high (approximation: trade data record the partner country, not the country of production). The list names 140 low-risk and 4 high-risk countries and rates Article 3(a) deforestation risk only.

Wood origins compare as follows.

The four high-risk countries (Belarus, North Korea, Myanmar, Russia) carry checks on at least 9 % of actors and 9 % of quantity (Art. 16(9)). Every class is listed under EUDR country benchmarking.

Country of Harvest, Not Customs Origin: Processed Wood From China

The class follows where the wood was harvested (Article 2(24)), not customs origin (Article 2(23)): plywood made in China (low risk) from standard-risk logs needs full due diligence. Article 13(1) requires every input to be low risk, and Article 13(3) treats such processing as a circumvention risk. Chinese exports are covered under EUDR and China.

Does Low Risk Exempt Wood From Due Diligence?

No: low-risk wood still needs Article 9 information with species names and geolocation, a DDS and a due diligence system (Article 12). Article 13 removes only Articles 10 and 11 (FAQ 1.28), when circumvention or mixing risk is negligible.

What Does EUDR Due Diligence Require for Wood?

Wood due diligence has the same three steps (Article 8(2)), information, risk assessment against 14 criteria (Article 10(2)) and mitigation, plus two wood-only elements: species names and the forest-degradation test. The annual review is covered under EUDR due diligence.

Species Names: The Common Name and the Full Scientific Name

Article 9(1)(a) and Annex II point 2 require the common name of the species and their full scientific name for every product containing or made using wood, pulp and paper included. For mixed products, the operator lists each species that may have been used, for example following DIN EN 13556 of 1 October 2003 (Guidance, section 9). Other items are set out under EUDR information requirements.

Geolocation of Forest Plots and the Date of Harvest

Every harvest plot needs at least six decimal digits: a point up to 4 hectares (about 9.88 acres), a polygon above (Article 2(28)), with the date or time range of harvest (FAQ 1.25). Low-risk origins get no exception (FAQ 1.28); formats are under EUDR geolocation.

Deforestation-Free and Without Forest Degradation: The Two-Limb Test for Wood

Wood alone must pass two limbs: land not deforested after 31 December 2020 and harvest without inducing forest degradation after 31 December 2020 (Article 2(13); FAQ 4.3). Three definitions decide the second limb.

• Forest degradation: conversion of primary or naturally regenerating forests into plantation forests or other wooded land, or of primary forests into planted forests (Article 2(7)).
• Forest: more than 0.5 hectares (about 1.24 acres), trees higher than 5 metres, canopy cover above 10 % (Article 2(4)); wood plantations stay forest, since agricultural plantations exclude wood (Article 2(6)).
• Plot disqualification: deforestation or degradation on a plot disqualifies all its products (Article 9(1)(d)).

Other wooded land is a review item due by 30 June 2030 (Article 34(2)); the forest test is detailed under deforestation-free under the EUDR.

Legality, FLEGT Licences and CITES in the Country of Harvest

Wood must comply with the relevant legislation of the country of production, 8 headings of Article 2(40), including forest-related rules directly related to wood harvesting (point (c)). The risk class says nothing on legality. A licence from Indonesia (since 15 November 2016) or Ghana (since 8 October 2025) proves legality only (Article 10(3)), as explained for FLEGT licences.

The EUDR has no legality presumption for CITES timber; the headings are set out under EUDR legality requirement.

Log Yards, Stacks and Segregation: Why Mass Balance Is Not Compliant

Wood with EUDR information stays segregated because mass balance is not compliant; full identity preservation is not required (FAQ 1.4). Two log-yard situations follow.

• Stacks under first in, first out: the declaration covers all inflows since the stack was last empty, or at least 200 % of its capacity (FAQ 1.17).
• Mixed-origin panels: a board from logs of two or more plots needs every plot's geolocation (Article 9(1)(d)).

Mixing rules continue under EUDR traceability.

The Due Diligence Statement for Wood

The operator files one due diligence statement in the EUDR Information System before placing or export, with species names under Annex II point 2, and gives its reference number to customs (Article 26(4)). Filing is free (Implementing Regulation (EU) 2024/3084, Article 18(1)). An EUDR due diligence statement can be amended or withdrawn within 72 hours after the reference number is available (Article 5(1) of that regulation).

Can Certification Prove EUDR Compliance for Wood?

No: a forest or chain-of-custody certificate is complementary information under Article 10(2)(n); it never replaces due diligence, and the operator stays responsible (Article 4(3)). No "EUDR certificate" exists (FAQ 5.7), and no EU list of approved schemes exists as of 24 October 2026. Scheme limits are set out under certification and the EUDR.

Find Independent Providers and Suppliers for Wood Under the EUDR

Timber importers, forest owners, sawmills and non-EU exporters can describe what they need: plot mapping, species and risk assessment, audits, software or wood with EUDR information.

Facts are checked against EUR-Lex and the Commission sources named; see our methodology and fact-checking.

This guide explains the rules; it is not legal advice for an individual case.

How Does Wood Connect to the Other EUDR Commodities, Checks and Dates?

Wood is one of 7 relevant commodities and the only one with the forest-degradation limb and species names. The EUDR commodities hub compares all seven.

Coffee faces only the deforestation limb (EUDR and coffee). Oil palm plantations are agricultural plantations, never forest (EUDR and oil palm).

Cocoa follows agroforestry rules (EUDR and cocoa). Rubber has its own 10 lines (EUDR and rubber).

Why Is Wood One of the Seven Relevant Commodities?

Wood is covered because the research behind recital 38 attributed 8.6 % of EU-driven deforestation to it, a historical figure. "Deforestation-free" timber claims fall under EU green-claims rules (greenwashingdirective.com).

Checks and Penalties for Wood Operators

Authorities check at least 1 %, 3 % and 9 % of operators, non-SME downstream operators and non-SME traders yearly by origin class (Article 16(8) to (10)). For legal persons, the maximum fine must be at least 4 % of total annual Union-wide turnover (Article 25(2)(a)), detailed under EUDR penalties.

Is the EUDR Postponed or Simplified Again?

No further postponement is proposed as of 24 October 2026: 30 December 2026 stands. The review COM(2026) 191 of 4 May 2026 made no legislative proposal (EUDR simplification). Earlier steps sit under EUDR postponement.