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How wood and furniture get caught

Wood is on the list of seven commodities the regulation covers, next to cattle, cocoa, coffee, oil palm, rubber and soya. Being a listed commodity is only half the test though. The product itself also has to sit in Annex I, which pins each commodity to specific customs codes. For wood, that reaches a long way down the chain.

Two blocks matter to a furniture or timber business:

• Chapter 44 — timber and articles of wood. Roughly the 4401–4421 range: fuel wood and chips, rough and sawn timber, veneer, plywood and particleboard, and finished wood articles like tool handles, frames and joinery. If you import raw or worked timber, you are almost certainly here. [Reg. 2023/1115, Annex I (ch. 44)]
• Chapter 94 — wooden furniture. Annex I does not list all of heading 9403 blanket. It names the wooden-furniture sub-codes — office (9403 30), kitchen (9403 40), bedroom (9403 50), other wooden furniture (9403 60) and wooden parts (9403 91) — along with wooden seats under ex 9401. A flat-pack oak bookcase is caught. A steel-and-glass desk with no wood is not. [Reg. 2023/1115, Annex I (9401/9403)]

Chapters 47 and 48 — pulp, paper and paperboard — are also in Annex I, so paper-based packaging and printed matter that is itself the product can be caught. One thing that came out: printed products (the "ex 49" heading — books, catalogues, leaflets) were removed from Annex I in the simplification round, so a leaflet packed alongside your furniture is not itself a relevant product. [Commission EUDR implementation page] Check your own tariff codes against the current Annex I rather than working from memory — the list has been edited.

The cut-off: 31 December 2020

The core test is a date. Nothing you place on the EU market can come from land that was deforested or forest-degraded after 31 December 2020. [Reg. 2023/1115, Art. 3] For a furniture importer that means the harvest plot behind every wooden component has to be shown as forest that was standing, and legally worked, on that date. It is not about when the tree was cut or the wardrobe assembled — it is about the status of the land the wood came off.

Your deadline — and the timber trap

The December 2025 amendment (Regulation (EU) 2025/2650) set two application dates:

• Large and medium operators — 30 December 2026. [Reg. 2025/2650]
• Micro and small operators, and natural persons — 30 June 2027. The later date is a genuine deferral for smaller businesses.

Who does what after the December 2025 role change

The amendment reshaped who files what. In plain terms:

• The first operator files the DDS. Whoever first places the goods on the EU market runs due diligence and submits the due-diligence statement, with the geolocation data, into the EU information system. That statement gets a reference number, and the reference number is what lets the goods move. [Reg. 2023/1115, Art. 4]
• Downstream operators and traders collect and pass on the reference number. If you buy finished furniture or worked timber from an EU party who already filed, you are generally downstream — you gather and keep the DDS reference numbers and pass them along, rather than filing a fresh statement for wood already covered upstream. Larger (non-SME) downstream companies carry extra verification duties on top. [Reg. 2025/2650]

So the first practical question is not "am I in scope" — you are — it is "am I the operator who files, or a downstream party who references." If you import furniture or timber from outside the EU, you are usually the first operator, and the filing is yours. See operator vs trader for where the line sits.

What to demand from your suppliers

The DDS stands or falls on origin data, and for wood the chain can be long — a single sofa might carry a hardwood frame, a plywood base and softwood battens from three different forests. For every wooden component, ask your supplier for: [Reg. 2023/1115, Art. 9 & Art. 2]

• Geolocation of the harvest plots — coordinates, and polygons for any plot over 4 hectares. Not the factory address, not the port. The forest.
• Harvest dates — tied to the plots, so the 31 December 2020 cut-off can be checked.
• Country (and where relevant, region) of harvest — which sets the risk tier and how much diligence you owe.
• Legality evidence — that the wood was harvested lawfully under the rules of the country of harvest (permits, concession rights, species restrictions).
• The DDS reference number, where an upstream operator has already filed for that wood.

A "country of origin: Vietnam" line on a commercial invoice does not meet this. The species-and-plot detail is the part suppliers are slowest to produce, so the demand needs to go out early — and in writing. What you're asking for, and where each item comes from in the chain, is covered in coordinates vs polygons.

What this determines — and what it doesn't

Screening your furniture and timber tells you scope, which role you play, your 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 hand over and any satellite check run against it. Knowing you're caught, and knowing exactly what to demand, is the part you can settle now.

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 and tariff codes with counsel before relying on it for a market-access decision.

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