Wood and Bamboo Product Regulations in the EU: An Overview

Wood and bamboo products imported and manufactured in the EU are subject to traceability requirements, chemicals and substance restrictions, safety standards, and labeling requirements.

Examples include European Union Timber Regulation (EUTR), the General Product Safety Directive, REACH, and various EN standards. This guide

Are you planning to sell wood or bamboo products in the European Union? In this guide, we cover what importers and Amazon sellers must know about the European Union Timber Regulation (EUTR), the General Product Safety Directive, REACH, and more.

European Union Timber Regulation (EUTR)

The European Union Timber Regulation (EUTR) prohibits the illegal harvesting of certain wood species in the European Union, in order to reduce deforestation and protect specific tree species. The regulation applies to both imported and domestically produced timber products.

Covered products

The EUTR covers a wide range of timber products, including:

• Fibreboard
• Particleboard
• Wooden frames
• Wooden furniture

You can access the full list of covered products in EUTR Annex.

Requirements

The key requirements can be summarized in three parts:

a. Information: Importers and manufacturers must be able to provide information about their timber products, such as country of harvest, species, and more.

b. Risk assessment: Importers and manufacturers must be able to estimate the level of risk concerning the timber they are importing, based on the above information and the criteria mentioned in the regulation.

c. Risk mitigation: Importers and manufacturers should have in place measures such as a traceability system, risk assessment, and other risk management procedures.

How to prove EUTR compliance

There are mainly two ways to comply with the EUTR requirements when importing covered wooden products into the European Union.

Option A: Obtain a valid FLEGT or CITES license for your product

Option B: Get assistance from third-party verified organizations such as the Forest Stewardship Council (FSC), or the Endorsement of Forest Certification (PEFC), which provide certificate systems that are aligned to the EUTR requirements.

Protective Measures Against Pests of Plants Regulation ((EU) 2016/2031)

The Protective Measures Against Pests of Plants Regulation is based on the International Standard for Phytosanitary Measures 15 (ISPM 15). It sets out requirements for the import of wooden packaging materials, dunnages, and other wooden products aiming at reducing the phytosanitary risks due to plants’ pests.

Covered products must comply with the following requirements before being imported to the EU:

a. Must be either heat-treated or fumigated according to ISPM15 procedures

b. Must be marked with the IPPC (International Plant Protection Convention) Mark, which includes the certificate symbol, country code, producer code, and measure applied code.

c. Must be debarked

ISPM 15: Heat Treatment and Fumigation for wooden packaging products

ISPM 15 is a standard that was developed by the IPPC (International Plant Protection Convention) in order to control the pests problem in wooden packaging materials during the international trading process.

Currently, there are more than 180 countries that recognize and adopt the ISPM 15 standard, including all the member states in the European Union.

Most of the wooden packaging materials that are commonly used during the transportation of commodities are covered by the ISPM 15 standard. Examples include:

• Pallets
• Skids
• Crates
• Boxes
• Cases
• Bins
• Dunnages

ISPM 15: IPPC Mark

ISPM 15 standard specifies the marking requirements for covered products. Wooden packaging materials that are covered under the ISPM 15 standard should be labeled with the IPPC Mark, which demonstrates that the products have been treated with the approved phytosanitary measures.

The IPPC Mark should include the following information:

a. The IPPC certification symbol

b. The ISO country code where the fumigation or heat treatment procedure take place (e.g. “CN” for China, “HN” for Honduras, “NO” for Norway)

c. A unique code particularly for the treatment providers for traceability

d. The treatment code to describe the type of treatment that was conducted (“HT” for conventional steam heating, “DH” for dry kiln heating, “MB” for Methyl bromide treatment, or “SF” Sulfuryl fluoride fumigation)

National Plant Protection Organizations (NPPO)

The IPPC describes the obligations of the contracting parties regarding the establishment and responsibilities of a National Plant Protection Organization (NPPO).

It requires that each national legislation (that recognizes and adopts the ISPM 15) of the contracting party should establish an NPPO as the official institution to perform the functions specified by the IPPC, which include supervising the phytosanitary treatment and the application of the IPPC Mark.

NPPO’s role in phytosanitary control includes the following responsibilities:

a. Authorize phytosanitary treatment providers

b. Supervise the treatment procedure that is properly carried out by authorized treatment providers

c. Authorize the use of the IPPC Mark

d. Establish inspection and auditing procedures

General Product Safety Directive (GPSD)

The General Product Safety Directive (GPSD) sets out general safety requirements concerning consumer product safety in the EU. It covers most of the consumer products manufactured, imported, or sold in the EU, which includes wood and bamboo products.

Product Scope

Examples of products that are covered by the GPSD include:

• Wooden chairs
• Wooden tables
• Wooden cribs
• Wooden cradles

Harmonised Standards

Here we list some examples of EN standards relating to furniture, including wooden furniture, that are harmonised under the General Product Safety Directive:

a. EN 581 – Outdoor Furniture – Seating and Tables for Camping, Domestic and Contract Use

b. EN 1130-1 – Furniture – Cribs and cradles for domestic use – Part 1: Safety requirements

c. EN 1130-2 – Furniture – Cribs and cradles for domestic use – Part 2: Test methods

Requirements

In this section, we list the main GPSD requirements and guidelines for importers and manufacturers:

a. Create and maintain a technical file, which should include a risk assessment report that records the risks associated with the product

b. Create user instructions for the product

c. Conduct necessary tests and obtain valid test reports

d. Create a product traceability label and affix it to the product or product packaging

Construction Products Regulation

The Construction Products Regulation (CPR) covers general safety, quality, and performance requirements for construction materials and products including wooden doors, panels, floorings, and other building products in the European Union.

Product Scope

These are examples of construction materials that can be made of wood:

• Mortise and tenon structure
• Beams
• Purlins
• Floor strips
• Doors and windows
• Stringers
• Rafters

Harmonised Standards

Here are some standards relating to wooden construction products harmonised under the Construction Products Regulation:

a. EN 13986 – Wood-based Panels for Use in Construction – characteristics, Evaluation of Conformity and Marking

b. EN 14229 – Structural Timber – Wood Poles for Overhead Lines

c. EN 14342- Wood Flooring and Parquet – Characteristics, Evaluation of Conformity and Marking

d. EN 14915 – Solid Wood Panelling and Cladding – Characteristics, Evaluation of Conformity and Marking

Requirements

Importers and manufacturers of construction products or materials must prepare the required documents to ensure the technical and regulatory compliance of their products. This includes:

a. Declaration of Performance

b. User instructions for the product

c. Technical documentation

d. Affix the CE mark to their products or packaging

e. Create a product traceability label

f. Conduct applicable lab tests and obtain valid test reports

Food Contact Material Regulation Framework

The Food Contact Material Regulation Framework covers food contact products, including wooden kitchenware and other wooden food contact products. The regulation restricts heavy metals and other toxic substances and sets labeling and documentation requirements.

Paints and coatings

Such substances may not occur naturally in wood and bamboo products. However, paints and coatings can contain excessive amounts of banned substances, such as lead, cadmium, and phthalates.

Composites

Note that the use of wood and bamboo composite materials (i.e., mixed with melamine or other plastics) is not authorized under “Article 5 – Union list of authorised substances” of Regulation (EU) 10/2011 on Plastic materials and articles intended to come into contact with food.

You can learn more about this topic in this article.

REACH

REACH sets limits on chemicals, heavy metals, and pollutants for consumer products sold in the European Union. Importers must comply with REACH before importing wooden and bamboo products to the European Union.

For example, preservatives such as mercury and creosotes are sometimes used to prevent rot and improve the durability of timber in wooden products. Also, certain restricted chemicals and heavy metals may be found in coatings, paints, treatment substances, and print inks.

Restricted Substances

The European Chemicals Agency (ECHA) provides lists of restricted substances known as the SVHC Candidate List and Annex XVII.

New substances can be added to the lists. However, importers and manufacturers do not need to keep track of the list, instead, testing services companies can provide REACH services with the most updated requirements.

Here are a few examples of restricted substances that are commonly found in wooden products or coatings:

• Lead
• Cadmium
• Acetic acid
• Hydrazine
• Mercury

Lab testing

It is not practical for importers to verify every substance in their wooden and bamboo products. As such, third-party lab testing is often the only way to verify REACH compliance. Reputable test companies such as SGS, TÜV SÜD, and QIMA provide comprehensive REACH services for wooden and bamboo products.

It is also important to instruct your supplier on REACH compliance before shipping the product to the European Union. Ideally, the supplier should be able to provide the REACH test report before mass production.

Here are some companies offering REACH testing services:

• QIMA
• SGS
• TÜV SÜD
• Intertek

Risks

Natural materials, such as wood and bamboo, should not contain restricted chemicals and heavy metals. However, coatings, paints, print inks, and treatment chemicals may contain substances exceeding the set limits – resulting in non-compliance with the REACH regulation.

Here are some methods that can help you reduce the compliance risk when importing wood and bamboo products from outside the EU:

a. Avoid using coatings, treatment chemicals, paints, and print inks altogether

b. Procure coatings and paints from suppliers that can provide REACH test reports

c. Inform your supplier that all wood and bamboo products will be subject to third-party lab testing

Packaging & Packaging Waste Directive (94/62/EC)

The Packaging & Packaging Waste Directive restricts heavy metals, such as mercury, and cadmium in packaging materials, printing inks, and dyes. This also includes wooden packaging.

Additionally, packaging materials should be built to simplify material recycling, reuse, and collection.

The directive states that, by the end of 2025, at least 65% by weight of packaging waste should be recycled, including:

• 25% of wood
• 50% of plastic
• 70% of ferrous metals