This guide is based on (EU) 2023/1115 and its amendments current as of September 2026 (EU 2024/3234, EU 2025/2650 and the 2026 delegated/implementing acts). Provided for compliance reference only; not legal advice.
| Date | Legal instrument | Key point |
|---|---|---|
| 29 June 2023 | (EU) 2023/1115 enters into force | EUDR formally enters into force, replacing the EU Timber Regulation (EUTR); originally to apply from 30 Dec 2024 |
| 19 December 2024 | (EU) 2024/3234 | First postponement: application delayed by 12 months (Member States and industry cited information-system and readiness gaps) |
| 19 December 2025 | (EU) 2025/2650 | Second postponement + simplification: application delayed by another 12 months; roles redefined into "operator / downstream operator / micro-primary operator", concentrating the DDS obligation on the first company placing products on the EU market |
| 13 July 2026 | Delegated act + implementing act | Annex I product scope updated (see "Scope"); rules for the EUDR information system (based on TRACES) established; simplification package (multilingual guidance + FAQs) completed |
Seven commodities: cattle, cocoa, coffee, oil palm (palm oil), rubber, soy and wood.
Annex I lists derived products by HS code. Directly relevant to wood product exporters:
Note: with leather removed, leather shoes and leather goods are in principle no longer covered by EUDR. However, if raw hides are not placed on the market as an independent product but declared along with cattle-related products, customer requirements may still apply. Scope is ultimately determined by Annex I HS codes.
Relevant products may be placed on the EU market or exported from it only if all three of the following are met; otherwise placement is prohibited:
| Role | Definition | Core obligations |
|---|---|---|
| Operator (non-SME) | The company first placing relevant products on the EU market or exporting them | Full due diligence (information → risk assessment → risk mitigation) + file the DDS, and pass the reference number downstream |
| Downstream operator | A company further processing or placing on the market / exporting goods made from inputs already covered by a DDS (new category) | No new DDS required; collect and retain upstream DDS reference numbers; non-SMEs must register in the information system |
| Micro/small primary operators | Natural persons or micro/small enterprises in low-risk countries placing on the market / exporting products they themselves produced or sourced | File a single simplified declaration (new Annex III) |
| Trader | Resellers in the supply chain | Non-SMEs must register; collect and retain DDS numbers and supplier/customer information |
Record-keeping: all roles must retain supplier/customer information for 5 years.
| Risk level | Basis | Impact on companies |
|---|---|---|
| Low risk | Commission assessment: limited forest loss/degradation, cooperation arrangements with the EU, etc. | Simplified due diligence (may rely on collected information, no need per batch) |
| Standard risk | Default level | Full due diligence |
| High risk | High deforestation rates, agricultural/forestry expansion, serious governance issues, etc. | Full due diligence + enhanced on-the-ground checks by Member States |
Member State authorities check companies at rates tied to the level (high risk 9%, standard 3%, low risk 9% but simplified checks). The benchmarking list is published and updated by the Commission — although Chinese companies are outside the EU, exports are traced back to source-country plots; timber, palm oil etc. from high-risk regions will face stricter scrutiny.
Moreover, private citizens and NGOs can file complaints, and EU citizens and environmental organisations can seek judicial review under the Aarhus Convention — there are many channels through which supply chain compliance gaps get exposed and reported.
| Dimension | EUTR (replaced) | EUDR (current) |
|---|---|---|
| Product coverage | Wood and wood products only | Wood + cattle/cocoa/coffee/oil palm/rubber/soy — seven commodities |
| Legality requirement | Legal harvesting only | Legal + deforestation-free / no forest degradation (31 Dec 2020 baseline) |
| Plot traceability | No mandatory plot coordinates | Mandatory geolocation / polygons |
| Declaration | Internal due diligence system (weak DDS concept) | Electronic DDS via the central information system, reference number follows the goods |
| Penalties | Set by each Member State | Fines of at least 4% of EU turnover + confiscation + exclusion |
| Trade direction | Imports | Placing on the EU market + exports from the EU |
Yes — "indirectly but fatally". The DDS is filed by your EU customer (the importer), but they need you to provide plot coordinates, legality evidence and batch traceability. If you cannot, they cannot complete their DDS, and they will switch suppliers. EUDR effectively transfers compliance cost and responsibility down the whole supply chain, to Chinese factories.
The harvesting permit is an important legality document, but EUDR requires plot-level WGS-84 coordinates (polygons for large plots). Many older Chinese permits contain only boundary descriptions or local coordinate systems (e.g. CGCS2000 Gauss-Krüger projection), which must be converted to WGS-84 lat/long, with GPS field measurements where necessary. This is precisely the real weakness of most Chinese factories.
As part of the supply chain you must pass plot information and legality evidence downstream (to the EU customer); if upstream suppliers cannot provide it, you must either switch suppliers or help them build traceability — EU customers only accept chains that ultimately trace to the plot.
Wooden furniture is in Annex I. Leather (bovine hides, leather goods) was removed from scope by the July 2026 delegated act. Mixed-material furniture (e.g. wood frame + fabric) is judged on its wooden part and remains a relevant product.
No. Voluntary schemes like FSC/PEFC can serve as one input to risk assessment, but they cannot replace EUDR due diligence — EUDR is a legal obligation; certification is only supporting evidence. Conversely, an EUDR traceability system also helps with FSC CoC audits.
Quite the opposite: collecting plot coordinates involves many upstream farmers/forest farms and is the most time-consuming, least controllable part of the chain, typically taking 6-12 months. Your EU customers must file DDS from 30 December 2026, so they will demand data from Chinese suppliers well before that. Starting now is just in time; starting next year most likely means lost orders.
We provide EUDR documentation systems, coordinate conversion and supply chain traceability coaching built on real factory scenarios.
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