EU Deforestation Regulation (EUDR) Requirements for Wood

The EU Deforestation Regulation (EUDR) sets due diligence requirements for products and materials that can contribute to deforestation. In this guide, we take a closer look at the finished wooden products and materials (raw and semi-processed) covered by the EUDR.

Is wood covered by the EUDR?

Products and materials covered by CN codes listed in Annex I of the EU Deforestation Regulation (EUDR) are covered.

As you can see in the image above, the EU Deforestation Regulation (EUDR) covers both finished products made of wood and materials:

1. Consumer products made of wood

2. Paper products

3. Construction products and materials made of wood

4. Raw materials and semiprocessed materials of wood

Finished goods made of wood

The EU Deforestation Regulation (EUDR) covers kitchenware, packaging cases, furniture and parts, painting frames, and other finished goods made of wood. The following CN codes are relevant:

4406 Railway or tramway sleepers (cross-ties) of wood

4414 Wooden frames for paintings, photographs, mirrors or similar objects

4415 Packing cases, boxes, crates, drums and similar packings, of wood; cable-drums of wood; pallets, box pallets and other load boards, of wood; pallet collars of wood

4416 Casks, barrels, vats, tubs and other coopers’ products and parts thereof, of wood, including staves

4417 Tools, tool bodies, tool handles, broom or brush bodies and handles, of wood; boot or shoe lasts and trees, of wood

4418 Builders’ joinery and carpentry of wood, including cellular wood panels, assembled flooring panels, shingles and shakes

4419 Tableware and kitchenware, of wood

4420 Wood marquetry and inlaid wood; caskets and cases for jewellery or cutlery, and similar articles, of wood; statuettes and other ornaments, of wood; wooden articles of furniture not falling in Chapter 94

4421 Other articles of wood

ex 94 01 Seats (other than those of heading 9402 ), whether or not convertible into beds, and parts thereof, of wood

ex 94 01 Seats (other than those of heading 9402 ), whether or not convertible into beds, and parts thereof, of wood

9403 30 , 9403 40 , 9403 50 , 9403 60 and 9403 91 Wooden furniture, and parts thereof

Paper products

The EU Deforestation Regulation (EUDR) is also applicable to packaging, printed books, newspapers, pictures, pulp, and other paper products. The following CN codes are relevant:

4415 Packing cases, boxes, crates, drums and similar packings, of wood; cable-drums of wood; pallets, box pallets and other load boards, of wood;

Pulp and paper of Chapters 47 and 48 of the Combined Nomenclature, with the exception of bamboo-based and recovered (waste and scrap) products

ex 49 Printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper

Construction products and materials

The EU Deforestation Regulation (EUDR) covers various types of wooden construction products and materials:

4407 Wood sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness exceeding 6 mm

4408 Sheets for veneering (including those obtained by slicing laminated wood), for plywood or for other similar laminated wood and other wood, sawn lengthwise, sliced or peeled, whether or not planed, sanded, spliced or end-jointed, of a thickness not exceeding 6 mm

4409 Wood (including strips and friezes for parquet flooring, not assembled) continuously shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, moulded, rounded or the like) along any of its edges, ends or faces, whether or not planed, sanded or end-jointed

4410 Particle board, oriented strand board (OSB) and similar board (for example, waferboard) of wood or other ligneous materials, whether or not agglomerated with resins or other organic binding substances

4411 Fibreboard of wood or other ligneous materials, whether or not bonded with resins or other organic substances

4412 Plywood, veneered panels and similar laminated wood

4413 Densified wood, in blocks, plates, strips or profile shapes

9406 10 Prefabricated buildings of wood

Wood materials

Finally, the following unprocessed or semiprocessed wood materials are listed in Annex I:

4401 Fuel wood, in logs, in billets, in twigs, in faggots or in similar forms; wood in chips or particles; sawdust and wood waste and scrap, whether or not agglomerated in logs, briquettes, pellets or similar forms

4402 Wood charcoal (including shell or nut charcoal), whether or not agglomerated

4403 Wood in the rough, whether or not stripped of bark or sapwood, or roughly squared

4404 Hoopwood; split poles; piles, pickets and stakes of wood, pointed but not sawn lengthwise; wooden sticks, roughly trimmed but not turned, bent or otherwise worked, suitable for the manufacture of walking sticks, umbrellas, tool handles or the like; chipwood and the like

4405 Wood wool; wood flour

How to find wood products covered by the EUDR

The first step is to identify one or more CN codes that your product could potentially be classified as in Annex I of the EUDR.

Once established, you can search the CN codes and chapters in the EU TARIC database to find a more detailed list of products belonging to a certain chapter.

Step 1: Search the CN code and specify the country of origin

Step 2: Find product-specific CN codes

EUDR Requirements for Wood

EUDR requirements are not uniformly applied to all entities in a supply chain. Instead, the EUDR requirements depend on the following factors:

1. Are you the first to introduce (i.e., import) a certain wooden product or raw materials? If yes, then you are likely deemed to be the operator and must implement a strict due diligence procedure.

2. Are you distributing or selling wooden products or raw materials already available in the EU? Then you are likely a trader, which means that you are subject to less strict requirements.

The EUDR requirements also depend on the risk class of the country of origin.

You can learn more about EUDR requirements for operators and traders in this guide.

FAQ

Are all wooden products covered by the EUDR?

The EUDR covers wooden products falling within the scope of CN codes listed in Annex I. Not all products containing wooden materials or components will necessarily fall within the scope of listed CN codes.

Does the EUDR cover imported wooden products and materials?

Yes, imported wooden products and materials are covered by the EUDR. Importers are generally defined as operators.

Does the EUDR cover wooden products and materials exported from the EU?

Yes, the EUDR also covers exports. Exporters are generally also defined as operators.

Does the EUDR apply to construction materials made of wood?

Yes, certain CN codes applicable to plywood panels, fiberboard, and other construction materials are listed under Annex I of the EUDR. The regulation also covers prefabricated buildings of wood.

Does the EUDR cover wooden furniture?

Yes, Annex I of the EUDR lists CN codes applicable to various types of wooden furniture.

Do we need to comply with the EUDR if we import wood that is processed in the EU?

Yes, the EUDR is not only applicable to finished wooden products but also raw and semi-processed wood that is used for production within the European Union.

Is the EUDR applicable to wood products and materials purchased from EU suppliers?

Yes, but the due diligence requirements are less strict when you buy wooden products or materials that are already made available on the EU market, compared to if you are the first company to import or otherwise introduce a product for the first time in the EU.

Is FSC certified wood compliant with the EUDR?

Generally speaking, the traceability systems implemented by the FSC are aligned with the due diligence requirements of the EUDR. That said, I don’t know if all FSC certification and traceability schemes align with EUDR requirements.