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EUDR and Hardwood Lumber: What Importers Must File Under the New Rules

January 3, 2027

The EU deforestation regulation (EUDR) applies to large and medium operators from 30 December 2026, and sawn hardwood lumber is inside its scope. An importer who places lumber on the EU market must have a due diligence statement submitted first, and that statement needs the species, quantity, country of production, harvest plot geolocation and harvest date for the lumber in the shipment. A mill outside the EU does not file the statement, but it has to supply that data in time. This guide explains who does what, what data the order must carry and how to write it into the RFQ.

This is general information as of October 2026, not legal advice. The regulation has been amended twice since it was adopted and the Commission’s simplification review was due in April 2026, so confirm the current text and your own deadline with a customs broker or counsel before you rely on it.

What the regulation requires

Regulation (EU) 2023/1115, as amended in December 2025 by Regulation (EU) 2025/2650, bars relevant products from the EU market or from export unless three conditions are met. The product must be deforestation-free, must be produced in line with the laws of the country of production, and must be covered by a due diligence statement.

For wood, “deforestation-free” means the wood was harvested without inducing forest degradation after 31 December 2020. The regulation covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, plus products made from them. Annex I lists wood in chapter 44, for example sawn wood in heading 4407, and furniture in chapter 94. Pulp and paper in chapters 47 and 48 are also listed.

The 2025 amendment moved the main date to 30 December 2026 and also repeals the old EU Timber Regulation from that day. Under Article 37 of the amended text, the old rules keep applying until 31 December 2029 to timber produced before 29 June 2023 that is placed on the market from 30 December 2026. The Commission was also required to run a simplification review by 30 April 2026. Check the Commission’s EUDR pages for what came out of it, because the rules for your shipments may have moved since this article was written.

Who files: operator, downstream operator, trader

The amended regulation splits the supply chain into roles, and the role decides the workload:

Role	Who it is	What it must do
Operator	Places the product on the EU market or exports it from the EU	Collect the data, assess risk, submit the due diligence statement before placing the product, keep records for 5 years
Downstream operator or trader	Buys from an operator and resells or processes in the EU	Hold the supplier information and the reference numbers it received, and register if it is not an SME
Non-EU mill or exporter	Ships the lumber	Not a filer, but supplies the data the operator needs

In a typical import, the EU buyer who clears the lumber is the operator. A distributor who buys from that importer is a downstream operator or trader. If you buy from an EU distributor, you are usually in that second group and your supplier gives you the reference number to carry forward. The 2025 amendment also lets micro and small primary operators file a one-time simplified declaration instead of a statement per shipment, but that route is for primary producers and not for importers of foreign lumber.

If you sell finished furniture, flooring or millwork into the EU, the same logic applies to the wood inside it, because many chapter 94 and chapter 44 products are on the list.

The data a mill must supply

Article 9 sets the information that goes with each product. For hardwood lumber it means:

• The trade name and type of product, with the common name of the species and its full scientific name. “Oak” is not enough, since the statement needs the genus and species.
• The quantity in kilograms of net mass, not board feet or cubic meters, so a conversion step belongs in the order paperwork.
• The country of production, and parts of it where relevant.
• The geolocation of all plots of land where the wood was harvested, and the date or time range of harvest.

Geolocation means latitude and longitude with at least six decimal digits. For plots over four hectares, the regulation requires a polygon that outlines the plot perimeter, not a single point.

This is where hardwood differs from many other commodities. A sawmill may buy logs from dozens of small landowners and mix them in one kiln charge. To give you plot-level data, the mill must keep intake records that tie each log lot to a harvest site, and must keep that link through sawing, drying and bundling. Ask how the mill does it. A mill with log-yard tickets and bundle tags tied to lots is better placed to answer. A mill that tracks only species and grade may not be able to. Our guide to bundles and tally on hardwood loads shows where lot and bundle identifiers already sit on the paperwork.

Country risk and what low risk changes

The Commission has classified countries into low, standard and high risk. Implementing Regulation (EU) 2025/1093 lists four high-risk countries (Belarus, North Korea, Myanmar and Russia) and 140 low-risk countries, including the United States, Canada and the EU member states. Any country not listed is standard risk.

Article 13 allows simplified due diligence when all the wood comes from low-risk countries. The operator then does not have to carry out the risk assessment and risk mitigation steps in Articles 10 and 11, but must document that the risk of circumvention or mixing is negligible. It still has to collect the Article 9 data and submit the statement. So a mill in a low-risk country saves you analysis work, not the data request.

Mixing is the real exposure. If a shipment blends lumber from a low-risk country with lumber from a source outside that group, the simplified route is gone, because Article 13 needs all the wood to come from low-risk countries. Segregation by lot should be written into the contract.

How to put EUDR into the RFQ and the contract

A workable RFQ line has six parts:

1. Species by scientific name for every line item.
2. Net weight in kilograms per bundle or per shipment, with the conversion basis stated.
3. Harvest geolocation for every lot in the shipment, in a stated file format such as a spreadsheet with polygons or coordinates, delivered before shipment so the statement can be filed before the lumber is placed on the market.
4. Harvest date or range per lot.
5. Segregation: no mixing of lots from different harvest sites within a bundle unless the data covers every site.
6. A right to ask for supporting records, such as log intake tickets, and a duty to correct data that proves wrong.

Add the legal-timber paper that the destination also expects. Our guide on phytosanitary and fumigation rules covers the plant-health papers, which are a separate set of documents from EUDR data.

Ask each supplier early, in the same message as the price request. A mill that has a data sheet ready is a different supplier from one that needs three months to assemble plot data. Our nine checks for choosing a hardwood supplier is a good place to add traceability to your list. If you want mills that can answer on traceability, send your lumber RFQ with the species, grade and EUDR data you need, and we pass it to up to 3 mills or yards that say they can supply it. They reply to you directly.

What to do now

• Confirm your role in the chain and which date applies to your company.
• Register in the EU information system if you are an operator or a non-SME downstream operator or trader.
• List your lumber lines by species and HS code and mark which ones have lot-level origin data today.
• Send your suppliers the data list above and ask for a sample data file for one real past shipment.
• Add a clause that makes shipment release depend on receiving the data, and decide who bears the cost if a statement cannot be filed.
• Keep records for five years.

Suppliers who read this and want buyers who ask these questions can register as a supplier.

See also: importing hardwood lumber into the EU, which adds plant health, CITES and grading to the EUDR steps.

Sources

• Regulation (EU) 2023/1115, consolidated text on EUR-Lex
• Regulation (EU) 2025/2650 amending the EUDR, EUR-Lex
• Implementing Regulation (EU) 2025/1093, country benchmarking, EUR-Lex
• European Commission, Regulation on deforestation-free products
• EU Green Forum, deforestation regulation implementation

Frequently asked questions

Keep reading

• Buying Hardwood Lumber as a Plant QA Manager: Spec, Supplier Checks, Incoming Inspection and Records
• Forced Labor Due Diligence on a Hardwood Lumber Supplier: What to Ask Before the EU Ban Applies on 14 December 2027