EUDR for furniture and wood-product importers: beyond the timber regulation

On December 30, 2026, a beech-framed armchair unloaded in Antwerp will need to be traceable to the plots where that beech was felled, latitude and longitude included. That is the step change between the EU Timber Regulation (EUTR), applied since March 2013, and Regulation (EU) 2023/1115 on deforestation-free products, the EUDR, which replaces it. For a furniture importer or distributor, the question is no longer only whether the wood was harvested legally. You must show it does not come from land deforested after December 31, 2020, and declare it before the product reaches the market.

From the EUTR to the EUDR: what legality no longer covers

The EUTR asked for one thing: due diligence establishing that the timber was harvested in line with the laws of the country of harvest. The EUDR keeps that legality requirement and adds the deforestation test. Wood must come from plots that were not deforested after December 31, 2020, the regulation's cut-off date, and its harvest must not have caused forest degradation, a criterion specific to the wood commodity.

The machinery changes as much as the substance. Three differences will do most of the work in your files:

1. Geolocation. The due diligence file must contain the coordinates of every plot where the wood was harvested, as latitude and longitude with at least six decimal digits, and as a polygon for any plot larger than four hectares. The EUTR asked for the country of harvest, sometimes the region. The EUDR asks for the plot.
2. The due diligence statement. Under the EUTR, due diligence stayed in your drawer until an authority asked. Under the EUDR, a due diligence statement is filed in the EU information system before the product is placed on the market or exported, and its reference number follows the product down the chain.
3. Exports and penalties. The EUDR covers exports as well as imports, and it sets a floor for sanctions: the maximum fine must reach at least 4% of a company's total annual EU-wide turnover.

The calendar has moved twice. Regulation (EU) 2025/2650, published on December 23, 2025, sets application at December 30, 2026 for medium-sized and large companies and June 30, 2027 for micro and small ones. It also reserves the filing of the statement to the operator that first places the product on the market: downstream distributors keep the reference numbers and the traceability records, without filing their own statement.

Annex I covers far more than solid wood

Only products listed in Annex I are in scope, and the wood entry is long. It takes in the whole of customs chapter 44, from fuel wood and charcoal to sawn timber, particle board, plywood, joinery, and wooden kitchenware. It adds pulp (chapter 47) and paper and paperboard (chapter 48), except when made from bamboo or recovered paper. Then come the lines that matter most to this readership: wooden seats (part of heading 9401), wooden furniture under codes 9403 30 to 9403 60 plus wooden parts under 9403 91, and prefabricated wooden buildings under 9406 10. One line has gone the other way: Regulation (EU) 2025/2650 deleted printed books, newspapers, and the other chapter 49 printed products from Annex I in December 2025, so a publisher's finished books are out of scope, even though the paper they are printed on, bought as paper, is not.

Several of those lines are new. The EUTR never covered charcoal, wooden sticks and poles, or wooden seats. A retailer importing barbecue charcoal enters the scope for the first time. A furniture importer already knew the EUTR through codes 9403 30 to 60; the seats in its catalog, from dining chairs to wooden-framed sofas, join them.

Composite products: the customs code decides

Scope is determined by the combined nomenclature code declared at customs, and by nothing else. A metal desk pedestal, classified under 9403 10, stays out of scope even if its drawer fronts are wood, because that code is not listed in Annex I. The same pedestal in wood, classified under 9403 30, is covered. Classification follows customs rules, so you cannot pick the code that suits you.

In the other direction, no small quantity gets a product out. The European Commission's guidance is explicit: the EUDR has no de minimis threshold, by weight, by value, or by percentage of wood content. If the code is listed, the product is in, and due diligence applies to the wood it contains. For an upholstered sofa on a wooden frame, the frame's wood needs geolocation; the fabric and the foam do not.

Two genuine exemptions remain. Packaging that only supports, protects, or carries another product is out of scope, so the pallet under your delivery is not your problem; the same pallet sold as a product in its own right is. And products made entirely from material that has completed its lifecycle, such as recycled paper, are exempt.

Good to know: your import declarations for the last twelve months already carry every combined nomenclature code you use. One extraction from your customs broker is enough to build the list of covered references in an afternoon.

What must be ready before December 30, 2026

Start with the data your suppliers will have to hand over for each covered product: the species with its scientific name, the country of production, the geolocation of the plots, the range of harvest dates, and the documents establishing legal harvest. None of that can be reconstructed at the port, so it belongs in your purchase orders now.

Country benchmarking sets how heavy the exercise is. Implementing Regulation (EU) 2025/1093 of May 22, 2025 classifies every country as low, standard, or high risk. Wood from a low-risk country, a list that includes all EU member states, the United States, and China, qualifies for simplified due diligence: you collect the information, geolocation included, without the risk assessment and mitigation steps. Four countries are classified high risk: Belarus, Myanmar, North Korea, and Russia. For edge cases, composite products among them, check the latest editions of the Commission's guidance document and its FAQ on EUDR implementation; both are updated regularly. Wood harvested before June 29, 2023 remains under the EUTR's transitional regime.

Three worksites carry the load between now and December: extract your customs codes to establish the covered catalog, identify the suppliers behind those references, and write geolocation into the next purchase orders rather than waiting for the first statement. A live test on one product line, coordinates included, will tell you better than any audit whether your chain can answer.

FAQ

Is furniture with only a few wooden parts covered by the EUDR?

It depends on the customs code, not on the amount of wood. If the product is classified under a code listed in Annex I, such as 9403 30 to 9403 60 for wooden furniture or 9401 for wooden seats, it is covered with no minimum threshold. A product classified under a non-listed code, such as metal furniture under 9403 10, is out of scope even if it contains wooden parts.

When does the EUDR apply to furniture and wood-product importers?

From December 30, 2026 for medium-sized and large companies, and from June 30, 2027 for micro and small enterprises, following the one-year postponement adopted in Regulation (EU) 2025/2650 in December 2025.

What geolocation data does the EUDR require for wood products?

The coordinates of every plot of land where the wood was harvested, expressed as latitude and longitude with at least six decimal digits. Plots larger than four hectares must be described as polygons. The data goes into the due diligence statement filed in the EU information system.

Does the EU Timber Regulation disappear when the EUDR applies?

Yes. The EUTR is repealed when the EUDR becomes applicable, on December 30, 2026 for medium-sized and large companies. Timber harvested before June 29, 2023 remains subject to the EUTR under a transitional regime that runs until December 31, 2029.