Home/Guides/EUDR for builders' merchants

Your timber range is almost entirely in scope

Nearly everything on the timber side of a merchant's yard sits in chapter 44 of Annex I: [Reg. 2023/1115, Annex I]

• Sawn and planed carcassing, C16/C24, decking — sawn wood over 6 mm thick under HS 4407.
• Profiled timber, skirting, architrave, matchboard — continuously shaped wood under HS 4409.
• Chipboard and OSB — particle board and oriented strand board under HS 4410.
• MDF and hardboard — fibreboard under HS 4411.
• Plywood, shuttering ply, sheet materials — plywood and laminated wood under HS 4412.
• Doors, window frames, staircases, glulam — builders' joinery and carpentry under HS 4418.

Since Annex I catches products "made using" wood, engineered panels count even though they are manufactured, not raw — a sheet of OSB is as much in scope as a length of sawn softwood. [Reg. 2023/1115, Art. 2(1)] Non-wood lines — cement, aggregates, plasterboard, steel — are outside the seven commodities, so screening is really about drawing the line down the middle of your catalogue.

Operator or trader? It hinges on where the timber enters the EU

This is the question that decides your workload.

• You import timber into the EU yourself — buying plywood direct from a mill outside the EU, for instance. You are the operator: the first to place it on the market, so you run full due diligence and file the DDS before it clears customs. [Reg. 2023/1115, Art. 4(2)]
• You buy timber already placed on the EU market from an EU importer, agent or national wholesaler, then resell it to trade and retail customers. You are a downstream trader: you collect and keep the DDS reference numbers, you may not sell stock you know to be non-compliant, and you keep the buy/sell records. [Reg. 2025/2650]

Size then decides how heavy the trader role is. A non-SME merchant must register in the information system before selling on; an SME merchant has the lightest touch — collect and keep the reference numbers, don't sell known non-compliant stock. [Reg. 2025/2650]

Your deadline: timber gets no extension

The 2025 postponement gave micro and small businesses in most commodities until 30 June 2027. Wood is the exception. The timber exception keeps micro and small operators that were already covered by the old EU Timber Regulation on the 30 December 2026 date, in line with medium and large operators. [Reg. 2025/2650] A small independent merchant that imports timber therefore gets no extra time. If you only ever buy EU-placed stock as a trader, your practical task is having your suppliers' reference numbers in hand by that date.

What to collect from your timber suppliers

Whether you file or merely reference, the same origin data has to move up the chain. For each timber line, get: [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• The DDS reference number from your supplier for each product you buy in.
• Plot geolocation of the harvest — coordinates, and polygons for plots over 4 hectares — where you are the operator.
• Species and country of harvest (which sets the risk tier).
• Harvest dates and legality evidence for the origin.

Keep the reference numbers and buy/sell records so you can produce them if a competent authority asks. The regulation removed the duty to pass reference numbers further down the chain, but you still collect and keep them. [Reg. 2025/2650]

Origin risk tiers for construction timber

Under Implementing Regulation (EU) 2025/1093, the country of harvest sets the scrutiny level. Much construction timber is EU-grown or from other low-risk origins (simplified due diligence); tropical hardwoods and some plywood come from standard-risk origins (full due diligence). [Impl. Reg. 2025/1093] Birch plywood is the live one: much of it originates in Russia or Belarus, both high-risk, which means enhanced scrutiny and a higher chance of inspection. Know the true origin of your ply, not just the country you bought it from.

What this determines — and what it doesn't

Screening your range tells you scope, role, deadline and the documentary obligations you owe. It does not verify that any forest is deforestation-free — that depends on the geolocation-plus-evidence your suppliers provide and any satellite check. You don't need a traceability platform to begin; you need to know your position on each supply line and exactly what to ask each supplier for.

General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free. Confirm your classification with counsel before relying on it for a market-access decision.

Questions