Home/Guides/EUDR for wood pellet and biomass importers

Which biomass products are in scope?

Wood biomass fuel sits in chapter 44, heading 4401, and Annex I lists that heading in full. In practice that catches the whole biomass range:

• Fuel wood and firewood in logs, billets, twigs or faggots — HS 4401 11 (coniferous) and 4401 12 (non-coniferous).
• Wood chips and particles — HS 4401 21 (coniferous) and 4401 22 (non-coniferous), the feedstock for many biomass boilers.
• Sawdust, wood waste and scrap agglomerated into pellets or briquettes — HS 4401 3x, with wood pellets specifically at HS 4401 31 and other briquettes and agglomerated forms at 4401 39; loose sawdust and waste not agglomerated at 4401 40.

So a shipment of ENplus wood pellets, a container of wood chips, or a pallet of kiln-dried firewood are all relevant products. [Reg. 2023/1115, Annex I] The commodity is wood; the fact that it is burnt for energy rather than made into a table does not take it out of scope.

You are almost certainly the operator

The operator is the first person to place a relevant product on the EU market, or to export it. [Reg. 2023/1115, Art. 2(15)] If you bring pellets in from the US South, Canada, Vietnam or Russia and clear them through EU customs, that first placing is yours. You must:

• Collect the information — plot geolocation for the harvest area (coordinates, and polygons for plots over 4 hectares), harvest dates, country of production and legality evidence. [Reg. 2023/1115, Art. 9 & Art. 2(28)]
• Assess and mitigate risk, unless the wood comes only from low-risk countries, where a simplified route applies. [Reg. 2023/1115, Art. 10 & Art. 13]
• File the Due Diligence Statement in the EU Information System and carry its reference number before the goods are released for free circulation. [Reg. 2023/1115, Art. 4 & Art. 33]

The timber date: no June 2027 for fuel wood

The headline deadlines are 30 December 2026 for medium and large firms and 30 June 2027 for micro and small ones. [Reg. 2025/2650] But there is a carve-out that affects biomass significantly. The later small-firm date does not apply to products that were already covered by the old EU Timber Regulation (Reg. 995/2010), and fuel wood of heading 4401 is on that list. [Reg. 2025/2650] So a small pellet or firewood importer that assumed it had until mid-2027 is wrong: for these goods the date is 30 December 2026, the same as everyone else. If your business plan for compliance rested on the extra six months, check this first.

The proposed waste exemption — watch, don't rely

On 4 May 2026 the Commission published a draft delegated act proposing a set of horizontal exemptions, one of which is for waste. [Commission EUDR implementation page] That matters to biomass, because a large share of pellets and briquettes is made from sawdust and mill residues that could be argued to be waste-derived. But as at 10 July 2026 the draft is not adopted and not in force, the consultation has closed but scrutiny is not complete, and the final wording may change. Treat wood-waste pellets as in scope today and don't stand your due diligence down on the strength of a draft.

What this determines — and what it doesn't

Screening your biomass tells you scope, role, deadline, origin risk tier and the documentary obligations you owe. It does not verify that any forest stand is deforestation-free — that depends on the geolocation-plus-evidence your feedstock 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 demand from the mill that presses your pellets.

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