FLEGT Licences and the EUDR: Article 10(3), Voluntary Partnership Agreements and the Licensing Countries

(Article 10(3) of Regulation (EU) 2023/1115). Deforestation-free production, geolocation and the due diligence statement stay required. Which countries issue the licence?

A FLEGT licence has one defined role under the EU Deforestation Regulation, and exactly two countries issue licences as of 24 October 2026.

The rules below cover the definitions, Article 10(3), the licensing countries, ten agreements, customs checks, due diligence and dates. The key figures are listed below.

• Licensing countries: 2 (Indonesia and Ghana), as of 24 October 2026.
• Voluntary Partnership Agreements concluded: 10, of which 2 terminations are approved.
• Scope: legality only.
• Application: 30 December 2026.

What Is FLEGT?

FLEGT stands for Forest Law Enforcement, Governance and Trade, the title of the EU Action Plan set out in communication COM(2003) 251 final of 21 May 2003. Council Regulation (EC) No 2173/2005 created the FLEGT licensing scheme for timber imports and has been in force since 30 December 2005.

What Is a FLEGT Licence?

A FLEGT licence is a shipment-based or market participant-based document of standard format, forgery-resistant, tamper-proof and verifiable, issued and validated by a partner country's licensing authority, on paper or electronically (Article 2(5) of Regulation (EC) No 2173/2005). It is a state-issued shipment document, not a private certification, so "FLEGT certificate" is a misnomer. Indonesia names its licence "V-Legal Document/FLEGT licence" (Annex I to the same Regulation).

What Is a Voluntary Partnership Agreement (VPA)?

A Voluntary Partnership Agreement (VPA) is an agreement between the Union and a partner country to work together in support of the FLEGT Action Plan and implement the FLEGT licensing scheme (Article 2(3) of Regulation (EC) No 2173/2005). Imports of timber products exported from a partner country listed in Annex I are prohibited unless the shipment is covered by a FLEGT licence (Article 4(1)). Recital 81 of Regulation (EU) 2023/1115 states that VPAs could complement the EUDR on legality.

What Does Article 10(3) of the EUDR Do for FLEGT-Licensed Wood?

Article 10(3) deems wood products covered by a valid FLEGT licence from an operational licensing scheme to comply with the legality condition.

"Wood products which fall within the scope of Regulation (EC) No 2173/2005 that are covered by a valid FLEGT license from an operational licensing scheme shall be deemed to comply with Article 3, point (b), of this Regulation."

An operational licensing scheme is the scheme of a partner country listed in Annex I to Regulation (EC) No 2173/2005. Article 10(3) sits among the articles of Regulation (EU) 2023/1115 on risk assessment.

Legality Only: Deforestation-Free, Geolocation and the DDS Still Apply

A FLEGT licence satisfies the legality condition only, and leaves Article 3, point (a) (deforestation-free after the 31 December 2020 cut-off) and Article 3, point (c) (a due diligence statement or simplified declaration) untouched. Legality means the relevant legislation of the country of production, in eight headings (Article 2(40)); the EUDR legality requirement is explained there.

The Article 9 information stays required, including the geolocation of every plot, and so does the assessment of deforestation risk. Every plot is still mapped under the EUDR geolocation rules.

Which Wood Products and HS Codes Does Article 10(3) Cover?

Article 10(3) covers only wood products within Annex II to Regulation (EC) No 2173/2005 (headings 4403, 4406, 4407, 4408 and 4412, for all partner countries) or within the partner's own Annex III. Indonesian charcoal of heading 4402 is not in Indonesia's Annex III, so its legality is assessed under Article 10. The EUDR wood lines and their dates are set out under EUDR and wood.

Which Countries Issue FLEGT Licences?

Two countries issue FLEGT licences for the EU market as of 24 October 2026: Indonesia and Ghana, the partners listed in Annex I to Regulation (EC) No 2173/2005. The Fitness Check of the EUTR and FLEGT (SWD(2021) 328 of 17 November 2021) found licensing in 1 of 15 VPA countries, Indonesia.

Indonesia: FLEGT Licences Since 15 November 2016

FLEGT licensing for Indonesian timber products applies in the EU since 15 November 2016 (Article 3 of Delegated Regulation (EU) 2016/1387). The VPA (Council Decision 2014/284/EU of 14 April 2014) is in force since 1 May 2014, and Indonesia's timber legality assurance system, SVLK, underlies the licence; SVLK and the other Indonesian systems are covered under EUDR and Indonesia. It is standard risk under Implementing Regulation (EU) 2025/1093 (not listed in its Annex, Article 1(2)), so full due diligence applies, including geolocation.

Ghana: FLEGT Licences Since 8 October 2025

Ghanaian timber products in Annex III to Regulation (EC) No 2173/2005 need a FLEGT licence on import into the EU from 8 October 2025 (Article 3 of Delegated Regulation (EU) 2025/530, as amended by Delegated Regulation (EU) 2025/1201). Delegated Regulation (EU) 2025/1201 of 12 June 2025 moved the date from 8 July 2025 because Ghana could issue licences from 30 June 2025 at the earliest (recital 3). The Ghanaian system went live on 15 August 2025 (EU Delegation to Ghana, 18 August 2025), and the Timber Industry Development Division (TIDD) issues the licences.

Ghana is a low-risk country under Implementing Regulation (EU) 2025/1093, so simplified due diligence under Article 13 is available, while the Article 9 information including geolocation and the due diligence statement stay required. Cocoa and the other Ghanaian commodities are covered under EUDR and Ghana.

FLEGT VPA Countries: Agreement Status and EUDR Risk Class in 2026

Ten VPAs are concluded as of 24 October 2026: two with licensing, three in force without licensing, three without an entry-into-force date established as of 24 October 2026, and two with approved terminations.

VPAs in Force Without Licensing: Côte d'Ivoire, Viet Nam and Honduras

The VPAs of Côte d'Ivoire, Viet Nam and Honduras are in force without licensing, so their timber gets no Article 10(3) benefit and its legality is assessed under Article 10. The entry-into-force dates are 1 May 2025 for Côte d'Ivoire (Notice 2025/865), 1 June 2019 for Viet Nam and 1 September 2022 for Honduras. The EUDR rules for producers and exporters in Côte d'Ivoire are covered under EUDR and Côte d'Ivoire, and coffee and wood from Viet Nam under EUDR and Vietnam.

Cameroon and Liberia: VPA Terminations and No Article 10(3) Benefit

Council Decision (EU) 2025/1976 of 8 July 2025 approves the termination of the Cameroon VPA, and recital 5 states that Cameroonian timber gets no benefit of Article 10(3) in conjunction with Article 3, point (b). The Joint Declaration approved by the Decision sets 30 November 2025 as the end of the agreement. What Cameroonian exporters need is covered under EUDR and Cameroon.

Council Decision (EU) 2026/1771 of 10 July 2026 approves the termination of the Liberia VPA, which ceases to apply 12 months after written notification (Article 29 of the VPA). Recital 6 states that Liberian timber gets no benefit of Article 10(3). The end date of the Liberia VPA is not established as of 24 October 2026.

How Is a FLEGT Licence Checked at EU Import and Customs?

A FLEGT licence is checked at import when it is made available to the competent authority with the customs declaration for release for free circulation (Article 5 of Regulation (EC) No 2173/2005). Four checks apply, listed below.

• Lodge the licence with the customs declaration.
• Enter the licence number in box 44 of the Single Administrative Document (Article 11(1) of Regulation (EC) No 1024/2008).
• Keep volume or weight within 10 % of the licence (Article 10(2)).
• Lodge the licence before expiry, because a late licence is void (Article 6(3)).

Authorities verify further on a risk basis, customs may suspend release or detain the goods (Article 5), and each Member State sets its own penalties (Article 5(8)). The DDS reference in the declaration is covered under EUDR at customs.

How Do Operators Use a FLEGT Licence in EUDR Due Diligence?

Operators use a FLEGT licence to cover the legality part of due diligence only, and complete every other check. The licence fits into the three steps of EUDR due diligence (Article 8(2)).

This guide orders the checks; the Commission prescribes no FLEGT checklist, and Guidance C/2026/3896 has no FLEGT section.

FLEGT and EUDR Timeline: Dates From 2003 to 30 December 2026

Article 10(3) applies from 30 December 2026 (Article 38(2)), the date on which the EUTR is repealed (Article 37(1)). Every date in force is on the EUDR timeline. Operators that are natural persons or micro or small undertakings established as such by 31 December 2024 apply it from 30 June 2027 (Article 38(3)); products in the Annex to Regulation (EU) No 995/2010 from 30 December 2026. No further delay is proposed as of 24 October 2026.

Every rule on this page is checked against the consolidated texts of Regulation (EU) 2023/1115 and Regulation (EC) No 2173/2005; see our methodology and fact-checking.

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

How Does FLEGT Connect to the EUDR, the EUTR and Certification?

FLEGT is the predecessor framework for timber legality, and the EUDR keeps only its Article 10(3) legality presumption. FLEGT is one of the frameworks the EUDR builds on, next to the EUTR and private certification.

What Changes From the EUTR FLEGT Green Lane?

Article 3 of the EUTR deemed FLEGT-licensed and CITES timber legal, and the EUDR keeps only the FLEGT presumption (Article 10(3)). The repeal and the 2029 rules are set out under EU Timber Regulation (EUTR).

FLEGT vs FSC: State Licence or Private Certification?

A FLEGT licence is a state-issued shipment document that covers legality, while FSC is a private certification, and no certification scheme has a deemed-to-comply status under the EUDR. Certification is complementary information in the risk assessment (Article 10(2)(n)). What schemes prove is set out under certification and the EUDR. Alignment and gaps are covered under FSC and the EUDR.

FLEGT Licence FAQ

Five further questions follow. More answers are in the EUDR FAQ.

Is a FLEGT Licence an EUDR Certificate?

No: no EUDR certificate exists; the EUDR output is the DDS reference number, and a FLEGT licence is a partner country's shipment document. Micro or small primary operators receive a simplified declaration identifier instead.

Do Downstream Operators and Traders Have to Check FLEGT Licences?

No: since 26 December 2025 downstream operators and traders do no due diligence and file no DDS (Article 5). Who is a downstream operator or trader follows from Article 2.

Does a FLEGT Licence Make the Wood Low Risk?

No: the country class under Implementing Regulation (EU) 2025/1093 rates only the deforestation risk of Article 3, point (a), and a licence changes neither. Ghana is on the low-risk country list, Indonesia is not.

Do CITES-Listed Species Need a FLEGT Licence?

No: species in Annexes A, B and C to Regulation (EC) No 338/97 are exempt from the licence requirement (Article 4(3) of Regulation (EC) No 2173/2005).

Does the FLEGT Regulation End With the EUTR?

No: Regulation (EC) No 2173/2005 is neither repealed nor amended by the EUDR, which repeals only the EUTR from 30 December 2026. The licensing scheme continues for Indonesia and Ghana.