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Your furniture is in scope

Wood is one of the seven commodities, and Annex I catches finished furniture, not just raw timber. [Reg. 2023/1115, Annex I] The relevant headings are:

• Wooden seats — HS 9401 (seats with wooden frames, and wooden parts of seats): dining chairs, stools, wooden-framed sofas.
• Other wooden furniture — HS 9403, covering office (9403 30), kitchen (9403 40), bedroom (9403 50) and other wooden furniture (9403 60), plus wooden parts (9403 91): tables, wardrobes, sideboards, shelving.

If the piece has a wooden frame or is substantially made of wood, treat it as a relevant product. A purely metal-and-glass table would not be caught by these headings; a wooden one is.

You're a trader, not an operator — and that changes everything

This is the point most furniture retailers get wrong. The heavy obligations — full due diligence, geolocation, filing the DDS — land on the operator, meaning the first person to place the furniture on the EU market. [Reg. 2023/1115, Art. 2(15)] For a factory in Vietnam or a wholesaler that imports, that is them. If you buy stock that has already been placed on the EU market and simply resell it, you are further down the chain as a trader. [Reg. 2023/1115, Art. 2(16)]

What a downstream furniture retailer actually has to do

As a trader buying already-placed goods, your obligations under the 2025 simplification are practical and mostly about paperwork you receive, not paperwork you produce:

• Collect and keep the DDS reference numbers that come with your incoming furniture, and be able to pass them on. This is largely a passive duty — record the number when it reaches you. [Reg. 2025/2650]
• Keep records of your suppliers and business customers for each relevant product for five years. [Reg. 2023/1115, Art. 5]
• Don't sell goods you know are non-compliant. If you become aware that a line does not meet the Regulation, you cannot place it on the market and must inform the authorities. [Reg. 2023/1115, Art. 5 & Art. 8]

You do not file a DDS, geolocate any plots, or run a risk assessment. That is the operator's job, and their reference number is what you inherit and store.

If you're not an SME, there's a bit more

Size decides how far your duties reach. A furniture retailer that is not an SME — broadly, 50 or more employees, or turnover and balance sheet above the €10m thresholds — must additionally register in the EU Information System, keep the reference numbers it receives, and be able to show it checked that due diligence was done upstream before selling on. [Reg. 2025/2650] An SME retailer has the lightest position of all: collect and keep the reference numbers and records, with no registration and no DDS. SME status is fixed as at 31 December 2024. [Reg. 2025/2650]

What this determines — and what it doesn't

Screening your furniture range tells you scope, your role as operator or trader, your deadline and the documentary obligations you owe. It does not verify that any forest is deforestation-free — that depends on the operator's geolocation-plus-evidence far up the chain. Your job as a retailer is narrower and clearer: know which of your lines are in scope, and make sure the DDS reference numbers reach you and are kept.

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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