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Is your flooring in scope? (Yes, whatever the construction)

Flooring lives in chapter 44 of Annex I, and the different products land under different headings:

• Solid and engineered strips, and parquet not yet assembled — continuously shaped wood, tongued, grooved or moulded, falls under HS 4409. This is where most parquet and floorboard stock sits before it is boxed into panels. [Reg. 2023/1115, Annex I]
• Assembled parquet and flooring panels — builders' joinery and carpentry, including assembled flooring panels, falls under HS 4418 (parquet panels are commonly classified within 4418 7x). [Reg. 2023/1115, Annex I]
• Laminate — the decorative surface is a print, but the body is a wood-fibre board, usually HDF, which is fibreboard under HS 4411. That core is what pulls laminate into scope. [Reg. 2023/1115, Annex I]

The test is not the finish or the marketing name — it is whether the product is made using wood. Since Annex I catches products "made using" a relevant commodity, a floor built on a fibreboard or timber body is caught even when the top layer is a photographic laminate or a thin veneer. [Reg. 2023/1115, Art. 2(1)]

Which role are you? (Import decides it)

For flooring, the role usually turns on one fact: where you buy.

• You import flooring into the EU from outside it (a Chinese engineered-oak mill, a Vietnamese laminate factory, a UK distributor). You are the operator — the first person to place it on the EU market — so you run due diligence and file the DDS before it clears customs. [Reg. 2023/1115, Art. 4(2)]
• You buy flooring already placed on the EU market from an EU importer or wholesaler and resell it. You are a downstream trader: you collect and keep the DDS reference numbers, and may not sell stock you know to be non-compliant. A non-SME trader must also register in the information system; an SME trader has the lightest touch. [Reg. 2025/2650]

A non-EU supplier — say a UK or Turkish mill selling to your EU company — is not the operator. Its job is to hand you the origin data up the chain; yours is to file. [Reg. 2023/1115, Art. 2(15)]

Your deadline: no micro/small reprieve

Most commodities give micro and small businesses until 30 June 2027. Wood does not. The postponement kept a timber exception: micro and small operators that were already within scope of the old EU Timber Regulation stay on the 30 December 2026 date, alongside medium and large operators. [Reg. 2025/2650] A two-person flooring importer therefore gets no extra runway from being small. If you place timber flooring on the EU market, plan for December 2026.

What to ask your flooring supplier for

Whether you file or merely reference, you need the origin data in the chain. For each product, request: [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• Plot geolocation of the forest source — coordinates, and polygons for plots over 4 hectares.
• Harvest dates for the timber.
• Country of harvest (which sets the risk tier — see below).
• The tree species and legality evidence for the country of origin.
• The DDS reference number, where an upstream operator has already filed one.

Engineered and laminate floors complicate this because they mix timber sources — a birch-ply core, an oak wear layer, an HDF backer. Each wood component needs traceable origin, so ask your mill to break the bill of materials down by species and source rather than giving you a single line for "the floor".

Origin risk tiers for flooring timber

Under Implementing Regulation (EU) 2025/1093, the country of harvest sets the scrutiny level. Most flooring timber comes from standard-risk origins (full due diligence) or low-risk ones such as the EU itself and the United States (simplified due diligence). [Impl. Reg. 2025/1093] Watch for Russia and Belarus in birch-ply and laminate cores — both are high-risk, which means enhanced scrutiny and higher inspection rates. A single high-risk component pulls the whole plank up a tier.

What this determines — and what it doesn't

Screening your flooring 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 and exactly what to ask your mill 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.

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