What is the EU Deforestation Regulation?
Regulation (EU) 2023/1115, known as the EUDR, covers cattle, cocoa, coffee, oil palm, rubber, soya, wood, and products listed by customs code in Annex I. The customs code, not your industry, determines coverage.
Article 3 requires a covered product to be deforestation-free, produced under the relevant laws of its production country, and linked to the declaration required for the operator. Under Article 2(13), its commodity cannot come from land deforested after 31 December 2020. Wood also faces a forest-degradation test.
Why does the EUDR matter to you?
Articles 3-13 apply on 30 December 2026. The 30 June 2027 date applies only to operators established by 31 December 2024 as natural persons or as micro or small undertakings, except for products covered by the former EU Timber Regulation. A customer may ask earlier for a product code, production country, plot data, or declaration reference.
An upstream operator cannot place or export a covered product when the required information is missing or the risk is more than negligible. Article 9 records and the due diligence file must be kept for five years.
How does the EUDR work?
First classify the product under Annex I, then identify your role. You are upstream when you first place a relevant product on the EU market, including by import, or export one that has not undergone upstream due diligence. Processing checked inputs into a new relevant product puts you downstream.
A full upstream file starts with Article 9. Record the product and wood species, production country and period, counterparties, every required plot, and proof of legality and deforestation status. For products entering or leaving the EU market, record kilograms of net mass and any applicable supplementary unit; for other transactions, Article 9 allows net mass or, where applicable, volume or number of items. Test the Article 10 risk factors. Use Article 11 documents, surveys, or audits until the risk is absent or negligible, then submit the due diligence statement.
A downstream operator or trader does not repeat the upstream operator's due diligence or submit a new declaration. It keeps supplier and buyer details for five years; if its supplier is the upstream operator, it also keeps the statement reference or declaration identifier. Non-SME downstream operators and traders must register in the information system and must verify due diligence when substantiated concerns arise before supply.
What mistakes should you avoid?
- Assuming every wood product is covered without checking its exact Annex I customs code.
- Using a warehouse, mill, or supplier address where Article 9 requires production-plot coordinates.
- Letting a certificate stand in for legality documents, plot links, and your own risk conclusion.
- Filing a due diligence statement when an unknown source or mixed batch still creates a non-negligible risk.
Which EUDR filing applies to you?
Most upstream operators submit a due diligence statement under Article 4 and Annex II. A natural person or micro or small undertaking based in a low-risk country that places products it grew, harvested, obtained, or raised there is a micro or small primary operator. It normally uses the one-time simplified declaration in Article 4a and Annex III. If all Annex III information is already available in a qualifying EU or Member State database, Article 4a(4) removes the separate submission; the operator must still wait for a declaration identifier. Downstream operators and traders file neither.
What geolocation data does the EUDR require?
Article 9 requires every production plot and its production date or period. Geolocation is a latitude-longitude point with at least six decimal digits; for non-cattle plots over four hectares, use a polygon around the perimeter. Article 4a(5) lets a micro or small primary operator provide the postal address of every plot or production establishment instead.
Does the EUDR cover wooden furniture?
On 19 August 2026, the Annex I in force lists wooden furniture under CN 9403 30, 9403 40, 9403 50, 9403 60, and 9403 91. C(2026)4920 would change these to ex entries and exclude used and second-hand goods. The Commission says this 13 July act is under European Parliament and Council scrutiny and has not entered into force. Recheck the published Annex I before applying the rule.