EU Timber Regulation (EUTR): Its Repeal by the EUDR and the Transition Rules to 2029

The EU Timber Regulation (EUTR), Regulation (EU) No 995/2010, bans placing illegally harvested timber on the EU market since 3 March 2013 and is repealed with effect from 30 December 2026 by Article 37 of Regulation (EU) 2023/1115, with its rules kept until 31 December 2029 for timber produced before 29 June 2023. Which law then governs a plank or a ream of paper?

Its successor is the EU Deforestation Regulation, which tests timber for legality and deforestation alike and adds six commodities to wood.

The four key figures are listed below.

• Application: 3 March 2013 (Article 21 of Regulation (EU) No 995/2010).
• Repeal: with effect from 30 December 2026 (Article 37(1) of Regulation (EU) 2023/1115).
• Residual period: until 31 December 2029 for EUTR timber produced before 29 June 2023 (Article 37(2)).
• Scope: 1 commodity and a legality test, against 7 commodities under the EUDR.

What Is the EU Timber Regulation (EUTR)?

The EU Timber Regulation is the EU regulation that prohibits placing illegally harvested timber and timber products on the internal market and requires operators to exercise due diligence; it tests legality only, not deforestation. In German it is the EU-Holzhandelsverordnung, in French the règlement bois de l'UE (RBUE).

Regulation (EU) No 995/2010: Adoption, Entry Into Force and Application

Regulation (EU) No 995/2010 was adopted on 20 October 2010, entered into force on 2 December 2010 and applies from 3 March 2013 (Article 21). The legal basis is Article 192(1) of the Treaty on the Functioning of the European Union (TFEU).

The identity of the regulation is summarised below.

What Did the EUTR Prohibit and Require?

The EUTR sets three obligations: a prohibition, a due diligence system for operators and traceability for traders. The three obligations are listed below.

• Prohibition: "The placing on the market of illegally harvested timber or timber products derived from such timber shall be prohibited" (Article 4(1)).
• Due diligence system: operators collect information such as species, country of harvest, quantity and supplier, assess risk against criteria such as the prevalence of illegal harvesting and UN or EU sanctions, and mitigate risk unless it is negligible (Articles 4(2) and 6), maintaining and regularly evaluating the system (Article 4(3)).
• Traceability: traders identify their suppliers and, where applicable, their customers, and keep that information for at least five years (Article 5).

Operator and Trader Under the EUTR

An operator under the EUTR is any natural or legal person that places timber on the market, and a trader is any person that, in a commercial activity, sells or buys timber already placed (Article 2(c) and (d)).

The EUDR replaces this pair with four roles since 26 December 2025: operator, micro or small primary operator, downstream operator and trader (Article 2(15), (15a), (15b) and (17) of Regulation (EU) 2023/1115). Whether a company is an operator, downstream operator or trader follows from those definitions.

Which Products Does the EUTR Annex Cover?

The EUTR Annex covers fuel wood, wood in the rough, sawn wood, panels, packing, joinery, pulp and paper, wooden furniture and prefabricated buildings, with three exclusions. Article 2(a) excludes products from timber that has completed its lifecycle and would otherwise be waste.

The Annex codes are listed below in Annex order.

Codes as in the 2010 text; the Annex is unamended since 2010 and was never aligned with EUDR Annex I.

Packing under heading 4415 is covered only as a product in its own right. Its EUDR treatment is under EUDR and wood and paper packaging.

FLEGT and CITES Timber Under EUTR Article 3

Under Article 3 of the EUTR, FLEGT-licensed timber from partner countries of Council Regulation (EC) No 2173/2005 and timber of species in Annex A, B or C of Regulation (EC) No 338/97, each complying with its regulation, are "considered to have been legally harvested".

The EUDR keeps only the FLEGT presumption, for legality alone (Article 10(3)), and the consolidated EUDR contains no reference to Regulation (EC) No 338/97. Regulation (EC) No 2173/2005 is neither repealed nor amended by the EUDR; see FLEGT licences and the EUDR.

Monitoring Organisations Under EUTR Article 8

A monitoring organisation under Article 8 of the EUTR is a Commission-recognised body that maintains a due diligence system, grants operators its use, verifies proper use and notifies competent authorities of significant or repeated failure. It needs legal personality and establishment in the Union, expertise and no conflict of interest (Article 8(2)), and authorities check it at least once every two years (Implementing Regulation (EU) No 607/2012, Article 6). The Commission list updated on 21 December 2021 names 11.

The EUDR has no such concept: due diligence stays with the operator, and authorised representatives under the EUDR may only submit statements on its behalf (Article 6 of Regulation (EU) 2023/1115).

Secondary Acts, Guidance and the Only Amendment

Two Commission regulations, one guidance notice and one amending regulation complete the EUTR. The four instruments are listed below.

• Delegated Regulation (EU) No 363/2012 of 23 February 2012 (OJ L 115, 27.4.2012, p. 12): recognition and withdrawal of monitoring organisations.
• Implementing Regulation (EU) No 607/2012 of 6 July 2012 (OJ L 177, 7.7.2012, p. 16): due diligence per product type and supplier within at most 12 months (Article 2); operator records for 5 years (Article 5(1)).
• Commission Notice C(2016) 755 final of 12 February 2016: the EUTR guidance document.
• Regulation (EU) 2019/1010 (OJ L 170, 25.6.2019, p. 115): the only amendment, replacing Article 20(1) to (3) on reporting from 1 January 2020.

Both regulations are recorded on EUR-Lex as in force with no end date as of 24 October 2026. The EUDR's own notice, Guidance C/2026/3896, is indexed under EUDR guidance.

EUTR Case Law: C-370/23 and C-117/24

On 21 November 2024, the Court of Justice held in Case C-370/23, Mesto Rimavská Sobota (CELEX 62023CJ0370), that a person who contracts another to harvest wood under its direction or supervision, remains owner under national law and transfers ownership after harvesting is an operator placing timber on the market (Article 2(a) to (c)).

On 13 November 2025, in Case C-117/24, JYSK (CELEX 62024CJ0117), the Court held that a group operator's access to a due diligence system of its parent, or of a monitoring organisation the parent uses, is not sufficient (Articles 4(2), 4(3) and 6(1)). The Commission cites JYSK in FAQ Version 5 (April 2026), 5.3, on the individual nature of EUDR due diligence.

How Does the EUDR Repeal the EUTR Under Article 37?

Article 37 of Regulation (EU) 2023/1115 repeals the EUTR in three paragraphs, as replaced by Regulation (EU) 2025/2650 (in force since 26 December 2025): a repeal date, a residual period and a derogation.

Article 37(1) of Regulation (EU) 2023/1115: Repeal With Effect From 30 December 2026

Article 37(1) reads: "Regulation (EU) No 995/2010 is repealed with effect from 30 December 2026". The repeal sits in Chapter 9 of Regulation (EU) 2023/1115 and takes effect on the day its Articles 3 to 13, 16 to 24, 26, 31 and 32 apply (Article 38(2)).

Article 37(2) and (3): Timber Produced Before 29 June 2023 Until 31 December 2029

Article 37(2) keeps Regulation (EU) No 995/2010 applicable "until 31 December 2029" to timber and timber products as defined in its Article 2(a) "that were produced before 29 June 2023 and placed on the market from 30 December 2026". Only EUTR-Annex products made before the EUDR entered into force qualify.

Article 37(3) applies "by way of derogation from Article 1(2)": the same timber placed on the market from 31 December 2029 must comply with Article 3 of the EUDR (deforestation-free, legal, covered by a statement or simplified declaration). Article 1(2) keeps every other product produced before 29 June 2023 outside the EUDR.

Was the EUTR Repeal Delayed? Regulations (EU) 2024/3234 and 2025/2650

Yes, twice: Regulation (EU) 2024/3234 moved the repeal from 30 December 2024 to 30 December 2025, and Regulation (EU) 2025/2650 moved it to 30 December 2026, each time shifting the residual end by one year. Neither superseded date ever applied. Both moves belong to the EUDR delay history. No further delay is proposed as of 24 October 2026.

The three versions of Article 37 are compared below.

Which Law Applies to Timber From 30 December 2026? The EUTR to EUDR Transition Matrix

EUTR-Annex timber placed on the market from 30 December 2026 falls under the EUDR, except timber produced before 29 June 2023, which stays under the EUTR until the end of 2029 (Article 37(2) above). The Commission considers that placing up to and including 30 December 2029 is EUTR and from 31 December 2029 inclusive EUDR (Guidance C/2026/3896, section 3, third edition, Official Journal C of 20 July 2026, non-binding under Article 15(5)), settling the overlap between Article 37(2) and (3).

The matrix below shows the applicable law by production date and placing date.

EUTR-Annex timber; Guidance, section 3 (non-binding).

Timber placed before 30 December 2026 was placed under the EUTR, whatever its production date. Later sales of such stock are covered under EUDR transitional stock.

Paper and Derived Products Made From EUTR Timber

The Commission considers that paper placed on the market from 30 December 2026, made from timber harvested and placed between 29 June 2023 and 30 December 2026, must comply with the EUTR and needs no due diligence statement or simplified declaration (Guidance, section 3).

EUTR timber placed before 30 December 2026 and processed into a derived product outside the EUTR Annex is exempted from both regulations, in the same Guidance. Other paper rules are under EUDR and paper.

Wood Products in EUDR Annex I but Not in the EUTR Annex

The EUDR wood lines outside the EUTR Annex are 4402 (wood charcoal), 4404, 4405, 4417, 4419, 4420, 4421 and six ex 9401 wooden seat lines. For them the Commission applies the general rule (Guidance, section 3): no EUDR duty if produced before 29 June 2023 or placed before 30 December 2026, or before 30 June 2027 for 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. All wood entries are listed in EUDR Annex I.

Is There a 30 June 2027 Deferral for EUTR-Annex Products?

No: the 30 June 2027 date covers 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 apply from 30 December 2026, whatever the operator's size. Article 38(3) opens with "Except as regards the products covered by the Annex to Regulation (EU) No 995/2010" and concerns operators only; downstream operators and traders have no deferral. A qualifying micro undertaking importing sawn wood of heading 4407 applies the EUDR from 30 December 2026, but for wood charcoal of heading 4402, outside that Annex, from 30 June 2027 (Art. 38(3)). Size thresholds are under EUDR for SMEs.

The Commission's simplification review COM(2026) 191 of 4 May 2026 confirms it: "For micro- or small operators already covered by the EU Timber Regulation, the entry into application will be 30 December 2026." Every date in force, including 30 June 2027 (natural persons and micro or small undertakings established as such by 31 December 2024; products in the Annex to Regulation (EU) No 995/2010 from 30 December 2026), is on the EUDR timeline.

EUTR vs EUDR: What Changes for Timber?

The EUTR tests one condition, legality, while the EUDR tests three cumulative conditions for seven commodities: deforestation-free after the 31 December 2020 cut-off, produced legally, and covered by a due diligence statement or simplified declaration (Article 3 of Regulation (EU) 2023/1115).

The ten main differences are compared below.

Due Diligence System vs Due Diligence Statement

"DDS" means two things: under the EUTR the due diligence system operators use (Articles 4(2) and 6), under the EUDR the due diligence statement operators file. The EUTR system is a framework of procedures and measures for information, risk assessment and risk mitigation. Under the EUDR, DDS means the due diligence statement (DDS) of Annex II, submitted in the EUDR Information System before placing or export (Article 4(2)).

Checks and Penalties: EUTR Until 2029, EUDR From 30 December 2026

EUTR checks follow a risk-based plan with no minimum rate, while EUDR checks follow minimum annual rates from 30 December 2026. EUTR authorities check operators on a periodically reviewed plan and on substantiated third-party concerns (Article 10),. Penalties are set by each Member State and may include fines, seizure and immediate suspension of authorisation to trade (Article 19). National laws such as the German Holzhandels-Sicherungs-Gesetz of 11 July 2011 (BGBl. I S. 1345), in force as of 24 October 2026, lay them down; see EUDR in Germany.

EUDR rates apply to operators, non-SME downstream operators and non-SME traders, by country risk (Article 16(8) to (10)). The EUDR maximum fine for legal persons must be at least 4 % of total annual Union-wide turnover (Article 25(2)(a)), an EU floor the EUTR never had.

Country Benchmarking and Geolocation: New Under the EUDR

Country benchmarking and plot geolocation are new under the EUDR: the EUTR asks only for the country of harvest and, where applicable, region and concession (Article 6(1)(a)). The classes of EUDR country benchmarking in Implementing Regulation (EU) 2025/1093 (in force since 26 May 2025) are 140 low-risk countries, 4 high-risk (Belarus, North Korea, Myanmar, Russia) and every other country standard. Geolocation needs at least six decimal digits per plot (Article 2(28)).

Why Did the EUDR Replace the EUTR? The 2021 Fitness Check

The EUDR replaced the EUTR because, in the words of recital 32 of Regulation (EU) 2023/1115, the objectives of the EUTR and the FLEGT Regulation have not been met and focusing solely on the legality of timber is not sufficient. The Commission's Fitness Check of both, SWD(2021) 328 final of 17 November 2021, credited the EUTR with an improved situation in third countries and a flexible due diligence approach.

The same Fitness Check found the core objective of the Voluntary Partnership Agreements unmet: only 1 of 15 partner countries, Indonesia, operated a licensing system. Article 20 of the EUTR had required that Commission review by 3 December 2021.

Every provision on this page is checked against Regulation (EU) No 995/2010 and Regulation (EU) 2023/1115 on EUR-Lex; see our methodology and fact-checking.

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

How Does the EUTR Connect to EUDR Wood Products and Due Diligence?

The EUTR connects to the EUDR through wood, one of seven relevant commodities, and through operator due diligence. The full successor regime is in our EUDR guide.

Wood has 31 entries in EUDR Annex I, against the 2010 codes of the EUTR Annex. Codes and risks are under EUDR and wood.

EUTR due diligence already gathers information, assesses risk and mitigates it; the EUDR keeps those three steps (Article 8(2)) and adds geolocation and the deforestation-free test. The steps are under EUDR due diligence.

EUTR FAQ

Five further EUTR questions concern certificates, the official text, legal form, Northern Ireland and software. More answers are in the EUDR FAQ.

Is There an EUTR Certificate?

No: the EUTR required a due diligence system, not a certificate; Implementing Regulation (EU) No 607/2012, Article 4, let schemes count in the risk assessment if they met four criteria, including third-party field visits at intervals of no more than 12 months. No EUDR certificate exists either (FAQ 5.7); see certification and the EUDR. FSC is covered under FSC and the EUDR.

Where Is the Official Text of the EUTR?

On EUR-Lex: CELEX 32010R0995 (OJ L 295, 12.11.2010, p. 23), with the consolidated version 02010R0995-20200101 reflecting the only amendment. The legal basis is Article 192(1) TFEU.

Is the EUTR a Directive That Member States Had to Implement?

No: Article 21 makes the EUTR "binding in its entirety and directly applicable in all Member States", like the EUDR. National law adds only what the regulation leaves to Member States, above all the penalties of Article 19, which must be effective, proportionate and dissuasive.

Does the EUTR or the EUDR Apply in Northern Ireland?

The EUDR applies in Northern Ireland, replacing the EUTR, but not in Great Britain (Defra guidance of 17 July 2026). The territorial test is the customs territory of the Union (Article 2(34)), explained under where the EUDR applies.

Do I Need Software Beyond the EUDR Information System?

No: the only mandatory IT is the free EUDR Information System (Implementing Regulation (EU) 2024/3084, Article 18(1)); software, consultants and certification are never mandatory. Access works through the EUDR Information System, and responsibility for due diligence stays with the operator.