Republished by Newlife - Flexstone. All rights belong to the original publisher; see Source below.

The dates after two postponements The main obligations of Regulation (EU) 2023/1115 have been postponed twice. Regulation (EU) 2024/3234 moved them back by a year. Regulation (EU) 2025/2650 of 19 December 2025 (OJ L, 2025/2650, 23.12.2025), in force since 26 December 2025, moved them again and lightened the duties further down the chain. The core obligations now apply from 30 December 2026.

Micro and small operators established by 31 December 2024 have until 30 June 2027, except for products listed in the annex to the EU Timber Regulation (EUTR), Regulation (EU) No 995/2010. So sawn wood, panels, joinery, paper and wooden furniture of heading 9403 are covered from 30 December 2026 whatever the operator's size. Wooden seats (9401), kitchenware (4419) and the articles of 4417, 4420 and 4421 were not in that annex, so small operators get the later date.

The EUTR is repealed from 30 December 2026 but still governs timber products produced before 29 June 2023 until 31 December 2029; after that, such old stock must meet the EUDR. In its simplification review of 4 May 2026 (COM(2026) 191), the Commission concluded that it was not appropriate to propose further amendments to the legal text. Delegated Regulation (EU) 2026/2102 of 13 July 2026 (OJ L, 2026/2102, 17.9.2026) has amended Annex I since 18 September 2026.

Which wood products are covered Annex I lists products by customs code; its wood lines run from fuel wood and pellets (4401) through sawn wood (4407), veneers, mouldings and parquet strips (4408, 4409), particle board, OSB, fibreboard and plywood (4410 to 4412), packing cases and pallets (4415), tool handles (4417), builders' joinery and assembled flooring (4418), kitchenware (4419) and other wooden articles (4420, 4421), to pulp and paper (chapters 47 and 48).

Chapter 94 covers wooden seats and seat parts of 9401, wooden furniture and parts under 9403 30 to 9403 60 and 9403 91, and prefabricated wooden buildings (9406 10). Coverage follows the code, not the share of wood: an upholstered seat on a wooden frame (9401 61) is covered, a metal-framed one is not.

The 2025 and 2026 acts took out printed matter of chapter 49, aircraft and motor-vehicle seats, bamboo and rattan products, samples, and used and second-hand goods in most wood lines. Furniture made entirely from reclaimed timber is outside the rules; any new wood in it is not. Packaging, single-use or reusable, is excluded when used exclusively to support, protect or carry another product.

The carton around a flat-pack wardrobe and the pallet under it are outside the rules; the wardrobe is inside. New pallets or empty cartons bought for resale are covered in their own right. Operator, downstream operator or trader The operator is whoever first places a product on the EU market, or exports it.

If the seller is outside the EU, the first EU company that makes the goods available is deemed the operator (Article 7), so a French wholesaler importing flat-pack furniture from Vietnam is the operator for that shipment. For exports, the Commission's guidance says the operator is usually the exporter named in the customs declaration.

Before selling, the operator collects the Article 9 information, assesses and mitigates risk, and files a due diligence statement in the EUDR Information System, launched on 4 December 2024.

For wood this includes the common and scientific name of each species, the quantity, the country of production, the geolocation of every plot where the wood was harvested with the date or period of harvest, and verifiable evidence that it was harvested legally and without deforestation or forest degradation after 31 December 2020. Geolocation means latitude and longitude to at least six decimal places, with a polygon for plots over four hectares.

Importers give the statement's reference number to customs, and records are kept for five years. Where every input comes from low-risk countries and the risk of mixing has been assessed, simplified due diligence without formal risk assessment applies (Article 13). Implementing Regulation (EU) 2025/1093 classes China, Vietnam, Türkiye, Ukraine and all EU member states as low risk, and only Belarus, Myanmar, North Korea and Russia as high risk.

The 2025 amendment added the downstream operator, which makes a covered product from inputs already covered by a statement, such as a joinery making doors from plywood bought in the EU. Neither it nor a trader, which resells unchanged goods, files statements.

What a reseller must keep A trader or downstream operator may only sell covered products if it holds, for at least five years the name, trade name or trade mark, postal address, email and website of each supplier and each business customer; where the supplier is the operator, the due diligence statement reference numbers or declaration identifiers for those products.

It hands these to the authorities on request and passes any substantiated concern to the authorities and its own customers. Non-SME traders and downstream operators must also register in the information system and, faced with a substantiated concern before selling, check that due diligence was done. Operators must pass the reference numbers down the chain.

Micro or small primary operators, small producers in a low-risk country selling their own harvest such as a small French forest owner, file a one-time simplified declaration and may give a postal address instead of geolocation. An operator that is a natural person or microenterprise may mandate the next, larger company in the chain to file its statement. Penalties are national; for companies the maximum fine must be at least 4% of annual EU turnover.

What to ask suppliers the reference number or declaration identifier on the invoice or delivery note for each covered line; the supplier's legal name, postal and email address, and the CN code of every item; for direct imports, the species, harvest geolocation and legality evidence listed in Article 9; a clause obliging the supplier to report new information that casts doubt on compliance. The Commission's review confirms that one statement may cover several shipments.

Source

- lubrixo-vente.com (2026-09-29) - Original article: EUDR for timber and wooden furniture: scope, roles and the dates that now apply · LUBRIXO Journal - https://lubrixo-vente.com/journal/eudr-timber-furniture