What the EUDR is and why it replaces the EU Timber Regulation
The EU Deforestation Regulation, Regulation (EU) 2023/1115 or EUDR, sets one rule for seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. A product made from them may only be placed on the EU market, made available on it or exported if three conditions are met. It must be deforestation-free, it must have been produced legally under the laws of the country of production, and it must be covered by a due diligence statement.4
For the timber trade this is the successor to the EU Timber Regulation (EUTR, Regulation (EU) No 995/2010), which since 2013 has banned illegally harvested timber from the EU market.3 The EUTR asked only whether wood was legal. The EUDR also asks where exactly it grew and whether that land was deforested or degraded. The EUTR is repealed from 30 December 2026, the day the EUDR obligations start.1
This article reflects the legal texts and Commission documents as of October 2026. It is a practical summary for buyers, not legal advice; for decisions on your own products, check with your national competent authority or a lawyer.
Deforestation-free and legal: the 31 December 2020 cut-off
"Deforestation-free" is defined against a fixed date. Commodities must come from land that has not been deforested after 31 December 2020. For wood there is an extra condition: it must have been harvested from the forest without inducing forest degradation after that date.4 Degradation has a narrow legal meaning. It covers converting primary or naturally regenerating forest into plantation forest or other wooded land, and converting primary forest into planted forest.4 Normal felling under a management plan, followed by regeneration of the same forest, is not degradation in this sense.
The legality test is broader than forestry law. It covers the laws of the country of production on land-use rights, environmental protection, forest management and biodiversity rules linked to harvesting, third-party rights, labour rights, human rights, free, prior and informed consent, tax, anti-corruption, and trade and customs.4
Which wood products are covered
Annex I of the EUDR lists the products by Harmonised System (HS) code. For wood it covers almost all of chapter 44 (fuel wood, logs, sawn wood, veneer, mouldings, panels, packaging, joinery and other articles of wood), pulp and paper, wooden seats, wooden furniture and parts, and prefabricated wooden buildings. Printed products were taken out by the December 2025 amendment.1,4
A further scope act, Delegated Regulation (EU) 2026/2102, was adopted on 13 July 2026 and published on 17 September 2026. For wood it does four things. It excludes used and second-hand products and, for certain codes, waste. It excludes bamboo, rattan and similar woody materials. It excludes packaging used only to support, protect or carry another product. And it replaces the broad "ex 9401" seat line with a list of wooden seat codes that leaves out aircraft and car seats.5 Commercial samples and items sent for testing are also excluded.5
| HS code | Products | EUDR Annex I | EUTR Annex |
|---|---|---|---|
| 4401 | Fuel wood, chips, sawdust | Yes (not waste) | Yes |
| 4403 | Logs | Yes | Yes |
| 4407 | Sawn wood over 6 mm, incl. end-jointed | Yes | Yes |
| 4408 | Veneer sheets up to 6 mm | Yes | Yes |
| 4409 | Continuously shaped wood: tongue-and-groove, mouldings, parquet strips | Yes | Yes |
| 4410–4412 | Particle board, fibreboard, plywood, veneered panels | Yes | Yes |
| 4415 | Packing cases, pallets (not when only carrying another product) | Yes | Yes |
| 4418 | Builders' joinery and carpentry, incl. assembled flooring panels | Yes | Yes |
| 4419–4421 | Tableware and kitchenware, ornaments, other articles of wood | Yes | No |
| 9401 (wood) | Wooden seats and wooden seat parts | Yes | No |
| 9403 30–60, 9403 91 | Wooden furniture and parts | Yes | Yes |
| 9406 10 | Prefabricated wooden buildings | Yes | Yes |
| 47, 48 | Pulp and paper (not recovered) | Yes | Yes |
Since 18 September 2026 used and second-hand products are excluded from most wood entries, and 9401 covers only the listed wooden seat codes (no aircraft or car seats). Source: Regulation (EU) 2023/1115, Annex I, as amended by Regulations (EU) 2025/2650 and 2026/2102; Regulation (EU) No 995/2010, Annex. The EUTR Annex uses the 2010 codes 9403 50 00 and 9403 90 30 for bedroom furniture and wooden parts.
The right-hand column matters for small companies, as the next section explains. It also shows where SARAL's own product groups sit. Sawn timber is 4407, tongue-and-groove cladding is 4409, wooden chairs are 9401 and furniture components are 9403. The exact code for a given product is a customs question, so confirm it with your customs broker.
The deadline saga: 2024, 2025, 2026
The EUDR entered into force in June 2023 and was originally meant to apply from 30 December 2024.4 It has been postponed twice. Regulation (EU) 2024/3234 moved the date to 30 December 2025, and to 30 June 2026 for micro and small operators.7 Regulation (EU) 2025/2650, adopted on 19 December 2025, moved it again by twelve months. It also changed who has to do what.1
| Date | What happened or happens |
|---|---|
| 31 Dec 2020 | Cut-off date: no deforestation or, for wood, forest degradation after this day |
| 29 Jun 2023 | Regulation (EU) 2023/1115 enters into force |
| 4 Dec 2024 | EUDR information system launched |
| 19 Dec 2024 | Regulation (EU) 2024/3234: first postponement by 12 months |
| 19 Dec 2025 | Regulation (EU) 2025/2650: second postponement, downstream operators, simplified declarations |
| 4 May 2026 | Commission simplification review COM(2026) 191: no further changes to the legal text |
| 3 Jul 2026 | Information system reopens for due diligence statements and simplified declarations |
| 17 Sep 2026 | Delegated Regulation (EU) 2026/2102 on product scope published |
| 30 Dec 2026 | EUDR applies to large and medium operators and to all operators of EUTR-Annex products; EUTR repealed |
| 30 Jun 2027 | Micro and small operators established by 31 Dec 2024, for products outside the EUTR Annex |
| 30 Dec 2027 | Products added by Regulation 2026/2102 (none of them wood) |
| 31 Dec 2029 | End of EUTR transition for timber produced before 29 Jun 2023 |
Source: Regulations (EU) 2023/1115, 2024/3234, 2025/2650 and 2026/2102; European Commission, COM(2026) 191 and EUDR web page; ATIBT (3 July 2026).
In its May 2026 review the Commission concluded that it was not appropriate to propose further amendments to the basic legal text, and it kept the dates.8 As of late October 2026 we found no proposal on EUR-Lex that would move them again. Trade press still reports political pressure for a third delay, but the date in force is 30 December 2026.9
Why most timber micro and small companies do not get until June 2027
Many summaries say that "small companies have until 30 June 2027". For timber that is mostly wrong. The amended Article 38(3) gives micro and small operators established by 31 December 2024 the later date "except as regards the products covered by the Annex to Regulation (EU) No 995/2010", which is the EUTR.1 The Commission's own page puts it simply: micro and small operators already covered by the EUTR start on 30 December 2026.2
The EUTR Annex lists fuel wood, logs, sleepers, sawn wood, veneer, continuously shaped wood, particle board, fibreboard, plywood, densified wood, frames, packaging, casks, builders' joinery, pulp and paper, wooden furniture under 9403 and prefabricated buildings.3 Anyone placing those products on the market starts in December 2026, whatever their size.
The wooden-seat exception
We checked both annexes line by line. The EUTR Annex lists wooden furniture only under heading 9403, with codes 9403 30, 9403 40, 9403 50 00, 9403 60 and 9403 90 30. It contains no line for heading 9401, which covers seats.3 The EUDR Annex I does cover wooden seats and their wooden parts.4 Since 18 September 2026 these are listed as codes 9401 31 00, 9401 41 00, 9401 61 00, 9401 69 00, 9401 80 00 and 9401 91 90.5
On the wording of Article 38(3), a micro or small operator established by 31 December 2024 that places wooden chairs on the market therefore falls under 30 June 2027 for those chairs. The same company placing sawn wood or wooden tables falls under 30 December 2026. The same reasoning applies to a few other EUDR wood codes that were never in the EUTR Annex: charcoal (4402), tool handles (4417), tableware and kitchenware (4419), ornaments and caskets (4420) and other articles of wood (4421).3,4
Two cautions. The Commission's summaries speak of operators "already covered by the EUTR" rather than products, so a company selling both chairs and EUTR products should confirm the reading with its competent authority. And the date only matters for operators. A chair maker that builds from wood already covered by a due diligence statement is usually a downstream operator, which is the subject of the next section. For more on how chairs are built and tested, see our guide to solid wood chair manufacturing.
Who does what after the December 2025 amendment
The 2025 amendment changed the chain of responsibility more than the dates. Under the original text every company that placed, transformed or traded a covered product, apart from SMEs, had to file its own due diligence statement. Now that responsibility lies with the first operator who places a relevant product on the market.1,8
Operators, downstream operators and traders
An operator places a relevant product on the EU market for the first time, or exports it. A downstream operator is new. It is any person who places on the market or exports relevant products "made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration".1 A trader makes products available on the market without being the operator or a downstream operator.
Downstream operators and traders no longer exercise due diligence or file due diligence statements. They must collect and keep, for at least five years, the name and contact details of their suppliers and customers. Where the supplier is an operator, they must also keep the reference numbers of its due diligence statements or declaration identifiers. Only non-SME downstream operators and traders have to register in the information system. If they learn that a product may not comply, they must inform the competent authorities.1
| Role | Typical example | Due diligence and statement | Register in the system | Records to keep (5 years) |
|---|---|---|---|---|
| Operator | First places the wood on the EU market or exports it | Yes: due diligence (simplified for low-risk origin) and a due diligence statement | Through its statements | Statements and all due diligence documents |
| Micro or small primary operator | Small forest owner in a low-risk country selling its own harvest | One-time simplified declaration; postal address may replace coordinates | Through the declaration | Declaration identifier travels with the product |
| Downstream operator | Makes products from wood already covered by a statement, e.g. a furniture maker | No | Only if not an SME | Suppliers, customers and, if the supplier is the operator, the reference numbers |
| Trader | Resells without being an operator or downstream operator | No | Only if not an SME | Same as a downstream operator |
Source: Regulation (EU) 2023/1115, Articles 4, 9 and 13, and Regulation (EU) 2025/2650, Article 1 (new Articles 2(15a), 2(15b), 4a and 5).
In practice, a furniture maker in Germany or Italy that buys Romanian beech panels or oak components covered by a due diligence statement is a downstream operator. It needs a clean supplier record and the reference numbers, not a second statement.
Micro or small primary operators
The amendment also created a lighter regime for producers. A micro or small primary operator is a natural person or a micro or small enterprise, established in a low-risk country, that places on the market products it has grown or harvested itself in that country. Instead of a due diligence statement it files a one-time simplified declaration. The information system then issues a declaration identifier that travels with the products. Such an operator may give the postal address of the plots instead of geolocation coordinates.1 For wood, this mainly concerns small forest owners selling their own harvest.
Geolocation and the due diligence statement in the information system
The core of EUDR due diligence is geolocation: the location of the plot where the wood was harvested. It is given as latitude and longitude with at least six decimal digits. For plots larger than four hectares a polygon describing the perimeter is required.4 The due diligence statement includes the HS code, the trade name and, where applicable, the full scientific name of the species, plus the quantity and the geolocation of all plots.4
Statements are filed in the EUDR information system, which the Commission runs on its TRACES platform. It was first launched on 4 December 2024.2 It reopened on 3 July 2026 for due diligence statements and simplified declarations. It has a live server, a separate acceptance server for testing and training, an API for automated submission, and GeoJSON upload for plot data.10
The updated Commission guidance has two points that matter to furniture and panel makers, as summarised by the European State Forest Association. Multi-component products such as furniture or particle board need geolocation for every wood component. And the system requires identification at species level, so the genus alone is not enough.11 A beech-and-oak table therefore needs both species and both origins documented.
Romania is low risk: what that does and does not change
Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025 classifies countries by deforestation risk. Romania is on the low-risk list, together with all other EU member states, Ukraine, Serbia, Moldova, Türkiye, the United Kingdom and the United States, among others. Only Belarus, North Korea, Myanmar and Russia are classed as high risk. Every country not listed is standard risk.6
Low risk allows simplified due diligence under Article 13. The operator does not have to carry out the risk assessment and risk mitigation steps. That only applies once it has checked the complexity of the supply chain and found negligible risk of circumvention or of mixing with wood from standard-risk, high-risk or unknown origins. It must be able to show that documentation to the authorities on request.4 Collecting the information, including geolocation, and filing the due diligence statement remain mandatory.
So "Romanian wood is low risk" is true, but it does not mean "Romanian wood needs no paperwork". It means the paperwork is shorter, provided the chain is clean.
SUMAL 2.0: Romania's timber-tracking system
Romania has run a national timber-traceability system for years. Its current version, SUMAL 2.0, replaced the first one in early 2021. Timber transports leaving the forest travel with electronic transport documents (avize) issued in the system. As of May 2026 SUMAL 2.0 had more than 92,000 users and issued about 20,000 transport documents a day.12 The public website and app "Inspectorul Pădurii", relaunched on SUMAL 2.0 in February 2021, shows the transport documents of the last 96 hours on a map. Anyone can search them by number plate, document code or the harvest permit (APV) the wood came from.13
In May 2026 the Ministry of Environment put out for consultation a draft decision for SUMAL 3.0. It is being developed by the Special Telecommunications Service and would add AI-based risk analysis, satellite, camera and LiDAR monitoring and a link to the RO e-Transport system. The ministry explicitly cited the new EU deforestation and traceability obligations.12 As of October 2026 we had not found a published final decision.
SUMAL is a national control system, not the EUDR information system, and it does not replace a due diligence statement. It does give an operator buying Romanian logs a documented chain from harvest permit to mill gate. The amended EUDR also allows micro and small primary operators to skip the simplified declaration where equivalent national traceability data are made available in the EU system.1 We found no announcement yet that Romania will use SUMAL data this way. Our article on Romania's hardwood forests in numbers covers SUMAL's role in the wider debate about harvest data.
Penalties and enforcement
Member states set the penalties, but the regulation sets a floor. For legal persons, the maximum fine must be at least 4% of the company's total annual EU-wide turnover in the year before the decision, and higher where needed to remove the economic benefit. Other penalties include confiscation of the products and of the revenue from them, exclusion from public procurement and public funding for up to 12 months, and, for serious or repeated breaches, a ban on placing products on the market. A company can also lose the right to use simplified due diligence.4 Competent authorities run risk-based checks on operators and traders, so a missing reference number can be enough to stop a delivery.
What changed in 2026: the simplification review and the scope act
The December 2025 amendment required the Commission to carry out a simplification review by 30 April 2026.1 It published the report on 4 May 2026 (COM(2026) 191).8 Its main conclusions:
- No new legislation. The Commission did not consider it appropriate to propose further amendments to the basic text.8
- Lower costs. Taken together, the 2024–2026 measures are estimated to cut annual compliance costs by about 75%, from about EUR 8.1 billion to EUR 2.0 billion a year. This is a Commission estimate.8
- Updated guidance and FAQ, plus the draft scope act that became Delegated Regulation 2026/2102.5,8
- Dates confirmed: 30 December 2026 for all companies except most micro and small operators (30 June 2027), and 30 December 2026 for micro and small operators already covered by the EUTR.8
Products newly added by the scope act, such as soluble coffee, certain palm-oil derivatives and frozen cattle tongues, apply from 30 December 2027. Nothing was added for wood.2,5
How we handle sourcing at SARAL
Checklist: what to ask a supplier of Romanian hardwood
- Who is the operator? Ask which company first places the wood on the EU market and files the due diligence statement, or whether the wood comes from a micro or small primary operator with a simplified declaration.
- Reference numbers on every delivery. If you are the first downstream operator or trader, you must keep the DDS reference numbers or declaration identifiers. Make them a line on the invoice or delivery note.
- Species at species level. "Oak" is not enough. Ask for Quercus robur, Q. petraea or both, and Fagus sylvatica for beech, for every component.
- HS code per product. Agree the code with your supplier and customs broker, especially for chairs (9401), furniture parts (9403) and glued panels.
- Mixing controls. Ask how the supplier keeps low-risk Romanian wood separate from wood of other origins. This is what simplified due diligence depends on.
- Contract clauses. Add an obligation to tell you about any substantiated concern, and a right to see supporting documents on request.
For prices, lead times and how the EUDR fits into the wider market, see our European hardwood market report.
Frequently asked questions
What is the new EUDR deadline for timber?
As of October 2026, 30 December 2026 for large and medium companies and for all operators of products that were covered by the EU Timber Regulation, whatever their size. Micro and small operators established by 31 December 2024 get until 30 June 2027 only for products outside the EUTR Annex, such as wooden seats.1,2,3
Does the June 2027 SME deadline apply to wood?
Mostly not. It excludes "products covered by the Annex to Regulation (EU) No 995/2010", which include logs, sawn wood, panels, joinery and wooden furniture under 9403. Wooden seats (9401) and a few other articles of wood were not in that Annex.1,3
Is wood from Romania exempt from EUDR because it is low risk?
No. Low risk allows simplified due diligence without a risk assessment, but the operator still collects the information, including geolocation, and files a due diligence statement.4,6
Do I need my own due diligence statement if I make furniture from EUDR-covered wood?
Not if all the wood you use is already covered by a due diligence statement or simplified declaration. You are then a downstream operator. You keep supplier and customer records and, if your supplier is the operator, the reference numbers. You register in the system only if you are not an SME.1
What is SUMAL 2.0?
Romania's national system for tracking timber from the harvest permit through transport. As of May 2026 it had more than 92,000 users and issued about 20,000 transport documents a day. A SUMAL 3.0 version was put out for public consultation in May 2026.12
