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), REACH, GPSD, EN standards lab testing and much more.
- Wooden furniture
- Wooden toys
- Wooden handicrafts
- Wooden bowls
- Wooden construction materials
- Bamboo cutlery
- Bamboo decking
- Bamboo toilet paper
European Union Timber Regulation (EUTR)
The EUTR is a mandatory regulation for timber products that prohibits illegally harvesting activities in the European Union and other countries, in order to reduce deforestation and protect specific tree species. The regulation applies to both imported and domestically produced timber products.
Obligations for importers
The key obligations for importers can be summarized in three parts – operators, traceability and due diligence.
1. The obligations of operators – Importers shall not import illegally harvested timber or timber products derived from such timber. As such, imported wooden and bamboo products must come from verifiable legal sources.
2. The obligation of traceability – Importers shall establish a traceability system for all relevant product information such as suppliers’ contact, production place, and other relevant documentation.
3. The due diligence system – Importers shall use a framework of procedures and measures providing access to information such as traceability system, risk assessment, risk mitigation, and other risk management procedures.
How to prove EUTR compliance
There are a couple of ways to comply with the EUTR when importing wooden and bamboo products to the European Union.
Option A: Obtain valid FLEGT or CITES licenses, which are considered to comply with the requirements of the EUTR
Option B: Get assistance from third-party verified organizations such as the Forest Stewardship Council (FSC) and the Endorsement of Forest Certification (PEFC), to comply with the mandatory due diligence system requirement
Option C: Get assistance from EUTR services companies such as Global Traceability, Bureau Veritas, or SGS
EUTR covers a wide range of timber products including most wooden and bamboo products. The regulation applies to plywood, densified wood, paper, bamboo, and many others.
Here are some examples of EUTR covered products:
- Printed matter
- Wooden frames
- Bamboo products
- Wooden furniture
You can access the full list of covered products in EUTR official annex.
Recommendation: You can send an email to [email protected] for help if you are not sure if the EUTR applies to your wooden or bamboo products
Some wooden or bamboo products are exempted from the EUTR. Those exempted products are most likely covered by other regulations and standards. Here are some examples:
- Recycled wooden products
- Printed paper
- non-upholstered seats
- Clothes hangers
- Pencils and pens
- Smoking pipe
Note: EUTR might updates the list on an irregular basis, therefore it’s important to check the EUTR office website for most updated information.
When selling wooden and bamboo products in the European Union, importers must label the product correctly with information such as:
- Product description
- Country of harvest
- Quantity in net weight
- Supplier details
- Compliance information
- Sustainability information
Note: Importer shall add other relevant information on the label to grant consumer access.
On top of the EUTR, value-added bamboo and wooden products might be covered by other regulations such as the following:
Construction Products Directive and CE Marking
If you are planning to import wooden or bamboo products for construction purposes such as decking and flooring. Importers will have to CE-mark their bamboo products and comply with applicable harmonized requirements of the Construction Products Directive, including but not limited, to the following aspects:
- Mechanical resistance
- Fire resistance
- Environmental impact assessment
- Factory hygiene
Click here for CE making service companies for wooden and bamboo products.
Food Contact Material Regulation Framework
It’s also common to import bamboo and wooden products for food contact material (FCM) usages, such as bowls, cutlery, and napkins. FCM importers must ensure that the wooden or bamboo products are compliant with EU FCM framework regulations:
1. Bamboo and wooden products for FCM usage shall not contain excessive migration of formaldehyde and melamine*
2. Non-authorized filler bamboo powder is not recommended
3. Risk assessment for wooden or bamboo products shall be provided
Click here to find more FCM testing companies for your products.
*Wood and bamboo composite materials (i.e., mixed with melamine or other plastics) may contain excessive amounts of restricted chemicals and other substances.
REACH sets limits to chemicals, heavy metal, and pollutants for all consumer products sold in the European Union. Importers must comply with REACH before importing wooden and bamboo products to the European Union.
For wooden and bamboo products, preservatives such as mercury and creosotes are commonly used to prevent rot and improve the durability of timber. Also, certain restricted chemicals and heavy metals may also be found in coatings, paints, treatment substances and print inks.
Here are a few examples of regulated substances:
- Acetic acid
Substances of Very High Concern (SVHC)
The EU provides a list of restricted substances under REACH as known as the SVHC list. New substances can be added to the candidate list anytime, for instance, six new substance has just been added to the list in January 2019.
Importers do not need to keep track of the list, instead, testing services companies such as TUV and QIMA can provide REACH services with the most updated requirements.
It is not practical for importers to verify every substance in their wooden and bamboo products. As such, third-party lab testing is the only way to verify REACH compliance. Reputable test companies such as SGS, Bureau Veritas, and TUV provide comprehensive REACH services for wooden and bamboo products.
It is also important to instruct your supplier with the 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 compliance testing:
- Bureau Veritas
Click here to learn more about REACH testing.
REACH lab testing cost mostly depends on the number of material and color variations. In general, it costs $150 to $200 per color or material.
You can learn more about REACH lab testing in this guide.
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:
- Avoid using coatings, treatment chemicals, paints and print inks altogether
- Procure coatings and paints from suppliers that can provide REACH test reports
- Inform your supplier that all wood and bamboo products will be subject to third-party lab testing
General Product Safety Directive (GPSD)
GPSD requires that all consumer products imported and sold in the European Union must be safe. Moreover, importers shall inform the customer of any associated risks of the products by establishing a safety assessment that covers all the age of potential customers. Importers must comply with the GSPD on top of other applicable regulations.
The risk assessment shall include information such as:
- Hazard identification
- Health and safety issues
- Risk protection
- Risk control
Importers shall add more risk-relevant information based on different usage of wooden or bamboo products.
GPSD lab testing is not mandatory for wooden and bamboo product unless you need help to assess the general product safety. Testing companies can help with risk assessment and other applicable requirements under GPSD.
GPSD does not require CE marking. However, if your wooden and bamboo products contain features that fall under the scope of CE directives (e.g. Construction Products or other), then you shall include the CE marking on the product and its packaging.
Directive 94/62/EC: Packaging Regulations
It is also essential to comply with the packaging requirements in the European Union. For example, packaging material should be built to simplify material recycling, reuse, and collection purposes. A brief summary of packaging requirements are explained as below:
Heavy metals restrictions
For the packaging material, the EU Directive 94/62/EC set limits to substances used in packagings such as lead, cadmium, and nickel. When importing wooden and bamboo products to the European Union, we suggest that you should book a third lab test for packaging compliance.
Labeling requirement on packaging
Importers must include all relevant compliance marks such as CE marking on the product packaging. The label should be visibly and permanently printed on the package.
Wood packaging requirement
It’s also common to use wood packaging for products. If you are planning to use wood packaging, you shall comply with the EU 2016/2031 Regulation, which requires that all wood packaging material must:
1. Either heat-treated or fumigated with ISPM 15 procedures.
2. Officially marked with the ISPM15 stamp.
3. Label with IPPC logo, country of origin, producer, and measurement.
Note: Wood packaging requirement does not apply to wood 6mm thick or less, wood packaging material used in trade within the EU, and wood packaging from processed wood.