EUDR for wood: scope, obligations, and how forest plots are screened
Thirty headings from fuel wood to office furniture, two limbs instead of one, and the question that decides most plots: what kind of forest stood there in 2020.
Updated 15 September 2026, 7 min read
Wood is one of the seven commodities of Regulation (EU) 2023/1115 (Art. 2(1)), and the one with the longest history: it replaces the EU Timber Regulation. Annex I covers the whole of Chapter 44, pulp (Chapter 47) and paper (Chapter 48), wooden furniture under 9403 and 9406 10, and seats under ex 9401. Products already covered by the Timber Regulation get no extension to 30 June 2027, whatever the operator's size.
In scope: Annex I codes for wood
| HS code | Product | Status |
|---|---|---|
| 4401 | Fuel wood, in logs, in billets, in twigs; wood in chips or particles | In force |
| 4402 | Wood charcoal (including shell or nut charcoal), whether or not agglomerated | In force |
| 4403 | Wood in the rough, whether or not stripped of bark or sapwood | In force |
| 4404 | Hoopwood; split poles; piles, pickets and stakes of wood, pointed but not sawn lengthwise; wooden sticks; chipwood and the like | In force |
| 4405 | Wood wool; wood flour | In force |
| 4406 | Railway or tramway sleepers (cross-ties) of wood | In force |
| 4407 | Wood sawn or chipped lengthwise, sliced or peeled | In force |
| 4408 | Sheets for veneering, plywood | In force |
| 4409 | Wood (including strips and friezes for parquet flooring, not assembled) continuously shaped | In force |
| 4410 | Particle board, oriented strand board (OSB) and similar board of wood or other ligneous materials | In force |
| 4411 | Fibreboard of wood or other ligneous materials | In force |
| 4412 | Plywood, veneered panels and similar laminated wood | In force |
| 4413 | Densified wood, in blocks, plates, strips or profile shapes | In force |
| 4414 | Wooden frames for paintings, photographs, mirrors or similar objects | In force |
| 4415 | Packing cases, boxes, crates, drums and similar packings, of wood; pallets, box pallets and other load boards, of wood; pallet collars of wood | In force |
| 4416 | Casks, barrels, vats, tubs and other coopers products and parts thereof, of wood, including staves | In force |
| 4417 | Tools, tool bodies, tool handles, broom or brush bodies and handles, of wood; boot or shoe lasts and trees, of wood | In force |
| 4418 | Builders' joinery and carpentry of wood | In force |
| 4419 | Tableware and kitchenware, of wood | In force |
| 4420 | Wood marquetry and inlaid wood; caskets and cases for jewellery or cutlery, of wood; statuettes and other ornaments, of wood | In force |
| 4421 | Other articles of wood | In force |
| 47 | Pulp of wood (Chapter 47), with the exception of bamboo-based and recovered (waste and scrap) products | In force |
| 48 | Paper and paperboard (Chapter 48), with the exception of bamboo-based and recovered (waste and scrap) products | In force |
| 9403 30 | Wooden furniture of a kind used in offices | In force |
| 9403 40 | Wooden furniture of a kind used in the kitchen | In force |
| 9403 50 | Wooden furniture of a kind used in the bedroom | In force |
| 9403 60 | Other wooden furniture | In force |
| 9403 91 | Parts of furniture, of wood | In force |
| 9406 10 | Prefabricated buildings of wood | In force |
| ex 9401 31 00 | Swivel seats with variable height adjustment, of wood | In force |
| ex 9401 41 00 | Seats convertible into beds, of wood (other than garden seats or camping equipment) | In force |
| ex 9401 61 00 | Other seats with wooden frames, upholstered | In force |
| ex 9401 69 00 | Other seats with wooden frames, not upholstered | In force |
| ex 9401 80 00 | Other seats, of wood | In force |
| ex 9401 91 90 | Other parts of seats, of wood | In force |
The same regulation took one entry for this commodity out of Annex I on 18 September 2026. Products under these codes are no longer relevant products.
| HS code | Product | Status |
|---|---|---|
| ex 9401 | Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof, of wood | Removed 18 September 2026 |
Since 18 September 2026, Delegated Regulation (EU) 2026/2102 lists six wooden-seat codes in place of ex 9401, so aircraft and motor vehicle seats are out, and it takes bamboo, rattan and other materials of a woody nature out of the wood entries by a table note. Used and second-hand products, and single-use packing presented with another product, are excluded across the wood entries. Timber produced before 29 June 2023 stays under the Timber Regulation for the transition period in Art. 37.
What the regulation asks of a wood importer
The obligations apply from 30 December 2026. An operator that is a micro or small undertaking, established as such by 31 December 2024, has until 30 June 2027, except for products that were already covered by the EU Timber Regulation. The amendment is Regulation (EU) 2025/2650.
For every consignment the operator must hold, and the statement must rest on:
- The geolocation of every plot of production, as a polygon where the plot is above four hectares, with the production period (Art. 9(1)(d)).
- Evidence that the products are deforestation-free against the 31 December 2020 cutoff (Art. 9(1)(g)) and were produced in accordance with the country's laws in the eight areas of Art. 2(40) (Art. 9(1)(h)).
- The product description with its HS code, the quantity, the country of production, and who supplied and who bought (Art. 9(1)(a) to (f)).
- A risk assessment on that information (Art. 10), and before placing, a due-diligence statement filed in the Information System, whose reference number goes into the customs declaration (Arts. 4, 26 and 33). Everything is kept for five years (Art. 12).
What is specific about wood
For every other commodity, deforestation-free means one thing: the land was not converted from forest to agricultural use after 31 December 2020 (Art. 2(13)(a)). Wood carries a second limb. The wood must have been harvested without inducing forest degradation after that date (Art. 2(13)(b)), and degradation is defined as a change of forest type: primary or naturally regenerating forest converted into plantation forest or other wooded land, or primary forest into planted forest (Art. 2(7)). A plantation established before 2020 and harvested after it is neither deforestation nor degradation; a natural forest cleared and replanted with eucalyptus after 2020 is degradation even though trees stand on it again.
So the question for a wood plot is not whether trees were cut. Harvest is what forestry is. The question is what kind of forest stood on the plot on 31 December 2020, and whether the harvest changed it into another kind.
Wood also has its own evidence base. A harvest permit, an approved forest management plan and a forest management certificate name the stand, the species and the period, and a legality record under Art. 9(1)(h) for wood leans on them; the eight categories of Art. 2(40) map onto forestry law, tenure and environmental licensing in the country of harvest.
How Konstata screens forest plots
Every plot is screened in more than one pass. The first runs the plot through WHISP, the open analysis developed under FAO's Open Foris, against the EU's own 2020 forest map, the global loss datasets and the alert layers, joined by national records where a country publishes them. Where that finds loss after the cutoff, a second pass locates it on the ground against the forest map, so a reading on land that was not forest in 2020 is not mistaken for the conversion of forest. Where the plot is still unclear, a third pass reads ten years of monthly satellite greenness for the pattern of an established crop. Each plot ends with a verdict and a written reason, never milder than WHISP's own headline, and a plot the data cannot settle is held for a person, with what to check written next to it.
Under Konstata's wood rules the shortcut that clears an agricultural plot never applies: a loss reading on a wood plot is never set aside on the argument that the land was farmland, and a degradation reading holds the plot for a person instead of being ignored. The reading that settles most plots, the forest type at the cutoff under the loss, is being added to the screening now, so that a plantation harvested on schedule is separated from a natural forest that was converted, per plot and on the map. The plot page shows the loss on the 2020 forest map and the imagery before and after.
Where to start
- Check your own product codes in the HS code lookup and the Annex I browser under /eudr/tools.
- Settle which date binds you with the company size test, and read the benchmark for each country of production in the country risk tool.
- Open a free Konstata workspace with room for three plots, import them, and read the screening on your own data. No card and no sales call.
Questions
- Is paper in scope of the EUDR?
- Yes. Chapter 48, paper and paperboard, is in Annex I, as is pulp under Chapter 47, with an exception for bamboo-based and recovered material. A paper importer is an operator, and its plots of production are the forest stands the pulp came from.
- Is harvesting a plantation deforestation?
- No. Deforestation is the conversion of forest to agricultural use (Art. 2(3)), and harvesting a plantation established before 31 December 2020 is neither that nor forest degradation, which Art. 2(7) defines as converting primary or naturally regenerating forest into plantation or other wooded land. Converting natural forest into a plantation after the cutoff is degradation.
- Does the EUDR replace the EU Timber Regulation?
- Yes, from 30 December 2026. Products that were under the Timber Regulation get no extension to June 2027, and timber produced before 29 June 2023 stays under the old regulation for the transition period in Art. 37.
- What documents does a wood plot need?
- Its geolocation with the harvest period (Art. 9(1)(d)), and the legality evidence of Art. 9(1)(h): typically the harvest permit, the approved management plan, tenure or concession documents, and any forest management certificate, each recorded against the eight categories of Art. 2(40).
Sources
Every claim on this page is drawn from Regulation (EU) 2023/1115 as amended, the Commission’s guidance and FAQ, and the implementing and delegated acts. Read the consolidated text on EUR-Lex.
Konstata is compliance software, not legal advice. Verify obligations against the consolidated EUDR text on EUR-Lex.
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