Wood is the one commodity where EUDR replaces an existing regime: the EU Timber Regulation (EUTR) that operators have worked under since 2013. If you already run an EUTR due diligence system, you have a head start - and a trap. EUDR keeps the due diligence skeleton but adds plot-level geolocation, a filed statement in TRACES, and a much longer product list. Compliance dates are 30 December 2026, or 30 June 2027 for micro and small enterprises.
Scope: far beyond sawn timber
Annex I for wood spans whole chapters of the tariff, not a handful of headings. The main groups:
| HS chapter / heading | Products |
|---|---|
4401–4421 | Fuel wood and charcoal, roundwood, sawn wood, veneer, plywood, particle board, fibreboard, joinery, tools, packaging |
47 | Wood pulp |
48 | Paper and paperboard |
9401 / 9403 | Seats and furniture of wood |
9406 | Prefabricated buildings of wood |
A furniture importer, a printer buying paper from outside the EU, and a garden-tool brand with wooden handles are all operators. Two useful carve-outs: packaging used exclusively to support or protect another product is out of scope (the pallet under your machine parts, not pallets sold as goods), and products made from material that has completed its lifecycle - recycled paper, reclaimed wood - are exempt, though virgin content mixed in is not.
What changes coming from EUTR
- Geolocation of harvest plots. EUTR wanted country (and sometimes concession) of harvest. EUDR wants coordinates for every plot of land where the trees were felled - polygons above 4 hectares, per the geolocation rules. For forestry, plots are usually well above 4 ha, so expect polygon work, typically from harvest-block shapefiles.
- A filed statement, not an internal file. EUTR due diligence lived in your drawer until an authority asked. EUDR requires a DDS in TRACES before each placing on the market, returning reference numbers quoted at customs. See the DDS field guide.
- Deforestation-free and degradation-free. Beyond legality, wood must not come from land deforested after 31 December 2020, and - unique to wood - must not have been harvested in a way that induced forest degradation: converting primary or naturally regenerating forest to plantation or other wooded land after the cutoff.
- Species declaration. The DDS carries the common and scientific species name - carried over from EUTR practice, still mandatory.
The degradation test is wood's hard part
For crop commodities the satellite question is binary: forest in 2020, cleared later. For wood, harvesting inside a managed forest is normal - what screening must catch is conversion of naturally regenerating forest to plantation forestry after the cutoff. Convergence-of-evidence screening in the style of the open WHISP methodology combines tree-cover loss years, primary-forest and plantation layers, and post-2020 alerts to separate a legitimate rotation harvest from conversion. Expect needs review verdicts more often than in coffee or cocoa; the answer is usually found in the forest-management plan, which belongs in your evidence file anyway.
Composite products and long chains
A plywood panel can contain core veneers from one country and face veneers from another; particle board aggregates residues from many mills. The DDS must cover the plots behind all the wood in the product. In practice this pushes the data request upstream to the mill: ask for harvest-block geometry per production batch. For pulp and paper the chains are longest, and the earlier you contract for data the more leverage you have. Where a component was already placed on the EU market with its own DDS, you reference that statement's numbers rather than re-proving the same plots.
FSC, PEFC and what they now hand you
Forest certification is ahead of most commodity schemes on EUDR: both FSC and PEFC have launched aligned modules that pass harvest-unit geolocation and deforestation evidence down certified chains of custody. If your supply is certified, ask for the EUDR data package by name - it converts a certificate from a marketing claim into actual polygons you can screen and file. The legal position stays the same as for every scheme: certification informs the risk assessment, it does not replace due diligence, and the DDS is still filed on your own conclusion. Chain-of-custody models matter too - credit-based volumes do not tell you which forest your particular shipment came from, so only physically traceable claims produce filing-grade data.
Country risk for timber origins
The country benchmark matters more for wood than most commodities because two major timber suppliers - Russia and Belarus - sit in the high-risk tier (alongside sanctions that already ban most of that trade). High-risk sourcing means a 9% inspection target and enhanced scrutiny; EU-origin wood is mostly low-risk, allowing simplified due diligence - geolocation still required.
Checklist for a timber or furniture importer
- Map every product you import against Annex I chapters - include packaging sold as product, paper and furniture components.
- Upgrade supplier contracts from "legality documents" to "harvest-plot polygons + species per batch".
- Screen inherited EUTR suppliers first: your risk is concentrated where the old system said "low" without coordinates.
- Test-file a DDS in TRACES well before your first mandatory one; species and geometry fields cause most first-filing failures.
A full comparison of the old and new regimes is in EUDR vs EUTR, and the two dominant tropical origins get their own guides: timber from Brazil and timber from Indonesia (where FLEGT licences still count, narrowly). Related reading: rubber shares the plantation screening logic, and cattle shows the one commodity where geolocation attaches to establishments instead of plots.