Key facts: EUDR (Regulation (EU) 2023/1115) covers wood and wood-derived products including timber, plywood, paper, cardboard, printed products and wood furniture. All wood entering the EU market must be deforestation-free (no deforestation/degradation after 31 December 2020) and legally produced. Exporters must provide geolocations of harvest plots. Enforcement is active in 2026.
Does EUDR Apply to Timber and Wood Products?
Yes โ wood is one of the seven commodity categories in EUDR Regulation (EU) 2023/1115, alongside cattle, cocoa, coffee, palm oil, soya and rubber. For the timber sector, EUDR is the most significant regulatory shift in decades, replacing the weaker EU Timber Regulation (EUTR) with a mandatory due diligence and no-deforestation requirement backed by customs enforcement.
The regulation applies at the EU border โ the EU-based importer (operator) is responsible for filing the Due Diligence Statement (DDS), but they can only do this if they have received adequate documentation from the exporter, making the exporter's compliance system critical.
Which Wood and Paper HS Codes Are Covered?
| HS Chapter | Description | Examples |
|---|---|---|
| 44 | Wood and articles of wood; wood charcoal | Logs, sawn timber, plywood, veneer, OSB, MDF, flooring, joinery, charcoal |
| 47 | Pulp of wood | Chemical wood pulp, mechanical pulp |
| 48 | Paper and paperboard; articles thereof | Newsprint, kraft paper, coated paper, tissue, packaging board |
| 49 | Printed books, newspapers, pictures | Books, brochures, newspapers, maps printed on paper |
| 94 (partial) | Furniture of wood | Wood chairs, tables, wardrobes, beds (where wood is constituent) |
โ ๏ธ Wood in Composite Products
If wood is a constituent material of a product in another HS chapter โ for example wood components in a garden furniture set (Chapter 94) or wooden packaging โ the wood component still triggers EUDR if it meets the "relevant commodity" definition. Check your product's bill of materials against Annex I.
Key EUDR Requirements for Timber Exporters
To enable your EU buyer to file a compliant DDS, you must provide them with:
1. Geolocation Data
Every plot of land where the timber was harvested must be provided as GPS coordinates. EUDR requires either:
- Polygon coordinates: The boundary of the harvest plot (preferred for plots >4 hectares)
- Point coordinates (latitude/longitude): For plots โค4 hectares
Coordinates must have sufficient precision to allow deforestation verification using satellite monitoring. The EU will cross-reference submitted geolocations against the deforestation satellite database.
2. Deforestation-Free Declaration
Documentary evidence that the land was not deforested or forest-degraded after 31 December 2020. This is the cut-off date โ land cleared before this date is not covered. Evidence may include:
- Forest management plans showing the plot was under active forest management before 31 December 2020
- Certified land-use history records
- FSC or PEFC forest management certificate (significantly simplifies the evidence burden)
- Government-issued forest land titles predating 2020
3. Country of Origin and Legality Documentation
All wood must have been legally harvested under the laws of the country of origin. Documentation includes timber legality verification, CITES permits where applicable, and compliance with national forestry laws including concession rights, harvesting rights, protected area rules and export regulations.
FSC and PEFC Certification: Does It Satisfy EUDR?
FSC (Forest Stewardship Council) and PEFC (Programme for the Endorsement of Forest Certification) are the two major forest management certification schemes. Both require deforestation-free sourcing as part of their standards. The EU has recognised FSC and PEFC as benchmarked certification schemes that substantially reduce the due diligence burden under EUDR โ though they do not provide a complete exemption.
For exporters with FSC or PEFC forest management certificates and valid chain-of-custody certificates: your certified products can enter the EU market with simplified due diligence (simplified DDS), which still requires submitting geolocation data but reduces the additional evidence burden for deforestation risk assessment.
Country Risk Classifications and EUDR
The European Commission assigns countries a low, standard or high risk classification based on deforestation risk. For timber exporters:
- Low-risk country: Simplified due diligence โ reduced evidence burden, still requires geolocation
- Standard risk: Full due diligence โ complete evidence package plus risk assessment
- High-risk country: Enhanced due diligence โ plus enhanced scrutiny and possible regulatory notification
High-risk timber producer countries include the DRC, Brazil, Indonesia and several other tropical forest nations. Many European timber producers (EU member states, some Scandinavian and Eastern European exporters) may qualify for low-risk classification once the country benchmarking process is finalised.
EUDR Due Diligence System for Timber: What to Build
- Map your timber supply chain: Identify every forest source โ concession, community forest, plantation. Collect geolocation data from each source.
- Establish harvest traceability: Each consignment of timber shipped to the EU must be traceable to its harvest plot. This requires a batch/lot tracking system linking processing records to forest sources.
- Collect and verify legality documentation: Forest management certificates, harvesting licences, export permits.
- Build a geolocation database: Secure, exportable format โ the EU TRACES NT system requires specific coordinate formats.
- Assess residual deforestation risk: Even with documentation, you must assess whether there is a risk the timber originated from deforested land. Risk assessment methodology must be documented.
- Issue DDS-ready data packages to EU buyers: Your EU buyer cannot file their DDS without the data package from you.
Frequently Asked Questions
Need EUDR Due Diligence Support for Timber?
We build EUDR due diligence systems for timber and wood products exporters โ geolocation data collection, traceability documentation, risk assessment and DDS-ready data packages for your EU buyers.
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