This guide reflects the EUDR text as amended by the 2025/2026 Simplification Package (Regulation (EU) 2025/2650 and Commission Implementing Regulation (EU) 2026/1565). Delegated acts and country benchmarking updates may adjust specific thresholds.

Wood makes furniture an EUDR product, and the EUDR furniture duty is the same for a frame, a board or a veneer: trace the timber to the plot it grew on, and prove the plot was not deforested after 31 December 2020. Large and medium companies from 30 December 2026, micro and small from 30 June 2027.

This guide follows the EUDR text as amended by the simplification package, Regulation (EU) 2025/2650 and Commission Implementing Regulation (EU) 2026/1565. Delegated acts and country benchmarking may still move specific thresholds.

Key takeaways

EUDR, Regulation (EU) 2023/1115, covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, and the products made from them. For furniture that means the wood: solid, board, veneer and plywood.

The simplification package of late 2025 and mid-2026 moved the due diligence burden to the operator who first places the product on the market and made the downstream role passive. The Commission puts the saving at 75% of compliance cost.

For brands

Compliance is a Hard Prerequisite for Sales

No product in scope is sold in or exported from the EU without a registered due diligence statement or a simplified declaration in the information system.

75% Cost Reduction

The May 2026 review puts recurring industry compliance cost at EUR 2.0 billion a year, down from EUR 8.1 billion before the package.

Passive Downstream Model

Downstream operators and traders no longer submit their own statements. They collect and keep the reference numbers from their direct suppliers.

Simplified Regime for Micro & Small Operators

Micro and small primary operators in low-risk countries submit a one-time simplified declaration and skip the standard risk assessment.

Substantiated Concerns Trigger Verification

A non-SME downstream operator still has to act on a substantiated concern, and check that due diligence was done before placing the product on the market.

“The combined simplification efforts introduced between April 2025 and July 2026 represent a monumental shift. By moving the primary burden of due diligence to first-entry operators and introducing a passive model for downstream actors, the EU has removed critical trade bottlenecks while reinforcing forest protection.”

Jessika Roswall, EU Environment Commissioner

EUDR requirements: what due diligence asks for

Three conditions, all at once, for every shipment placed on the EU market:

Geolocation

Exact coordinates of all plots of land where commodities were grown or harvested, with polygons for plots exceeding 4 hectares.

Deforestation-Free

Products must be verified as produced on land not subject to deforestation or forest degradation after the cut-off date of 31 December 2020.

Legality

Commodities must be produced in accordance with the relevant legislation of the country of production, covering eight distinct areas of law.

EUDR timber traceability: how far back you must trace

For every plot the wood came from, the operator holds its coordinates, latitude and longitude to at least six decimal places, and the time range of the harvest.

A plot above 4 hectares is a polygon, not a point. The Union space programme, EGNOS, Galileo and Copernicus, is the reference for checking it.

Point Coordinates

A single lat/long pair with 6 decimal places. Acceptable for plots ≤ 4 hectares.

Polygon Boundaries

A set of lat/long pairs defining the perimeter (GeoJSON standard). Required for plots > 4 hectares.

A micro or small primary operator may give the postal address of the plot instead of a polygon.

What evidence satisfies it

The wood must come from land not deforested or degraded after 31 December 2020. The evidence is the plot coordinates set against the satellite record for that date.

Deforestation means forest converted to agricultural use, by people or not, on the FAO definition: more than 0.5 hectares, trees above 5 meters, canopy above 10%. Any deforestation on a plot after 2020 disqualifies everything sourced from it.

Legality: the harvest must be lawful where it happened

The wood must have been produced legally in its country of origin, across eight areas of law:

  • Land use rights and legal status of the production area (tenure, lease arrangements)
  • Environmental protection laws (protected areas, biodiversity conservation)
  • Forest-related rules, including forest management and wood harvesting boundaries
  • Third-parties' rights and customary tenure rights
  • Labour rights, including the prohibition of child labour and national work codes
  • Human rights protected under international law
  • Free, Prior, and Informed Consent (FPIC) as set out in the UN Declaration on the Rights of Indigenous Peoples
  • Tax, anti-corruption, trade, and customs regulations

“Sourcing from low-risk countries significantly reduces administrative effort. Operators sourcing exclusively from low-risk countries are exempt from risk assessment and risk mitigation under Articles 10 and 11, unless new information or substantiated concerns indicate a risk of non-compliance.”

Article 13, Simplified Due Diligence Provision

Composite materials: MDF, plywood, veneers

A solid oak table is one plot. A flat-pack wardrobe is particleboard, MDF, a veneer and a plywood back, and each of them is a wood product with its own origin. That is where furniture brands lose the chain.

Fashion, footwear and luxury retail

The fashion industry received major relief under the 2026 Simplification Review, which deleted several heavy-burden categories from the EUDR product scope:

Removed from Scope
  • Cattle Hides and Leather: Raw hides, skins, tanned crusts, and finished leather (HS 4101, 4104, 4107) are completely removed
  • Retreaded Tyres & Rubber: Used tyre casings, carcasses, solid tyres, and specific vulcanised rubber items are removed
  • Printed Books (HS 49): Removed to prevent regulatory bottlenecks in publishing
Remains in Scope
  • Virgin Natural Rubber: Hevea brasiliensis remains fully subject to EUDR due diligence
  • Wood & Timber: Furniture of wood, veneers, plywood, and articles of wood (HS Chapter 94 selections)
  • Rubber Components: Natural rubber in all forms (latex, smoked sheets, crepe)

Packaging and pallets are exempt

Paper boxes, cartons, bags, and wooden pallets (HS 4819 and 4415) are subject to the regulation only if placed, made available, or exported as products in their own right. Packaging used exclusively to support, protect, or carry another product is completely exempt from the EUDR.

EUDR timeline: what applies when

One date is fixed for a furniture brand: 30 December 2026, or 30 June 2027 for a micro or small company. The rest of the table is what leads up to it.

29 June 2023

Entry into Force

Regulation (EU) 2023/1115 formally entered into force, establishing the core framework, definitions, and the 31 December 2020 deforestation cut-off date.

May 2025

Country Benchmarking Adopted

Commission adopted Implementing Regulation (EU) 2025/1093, establishing a three-tier benchmarking system. Low-risk countries trigger simplified due diligence; high-risk countries require enhanced scrutiny (9% inspection rate vs. 3% for standard and 1% for low-risk).

June 2026

Information System Reopened

The EUDR Information System relaunched in stages with technical specifications for machine-to-machine APIs and registration flows for downstream operators and micro/small primary operators.

30 December 2026

General Application Date

The regulation becomes fully binding for all large and medium-sized operators and traders. The EUTR is repealed, though EUTR-produced timber continues under transitional rules until 31 December 2029.

30 June 2027

Deferred Application (SMEs)

Application date for micro-undertakings and small operators established by 31 December 2024, giving smaller brands an extra six months to prepare.

30 December 2027

Extended Product Scope

Newly added downstream products: soluble coffee, specific palm oil derivatives, and frozen cattle tongues: become subject to EUDR obligations.

1 December 2029

Single Window Customs Interface

The electronic interface linking customs declaration systems with the EUDR Information System via the EU Single Window Environment goes live, enabling automatic cross-checks of Reference Numbers.

Timeline in one look

Milestone Date Affected Actors Obligations Legal Reference
Entry into force 29 Jun 2023 All actors Core framework; 2020 cut-off date set Art. 38(1) EUDR
Benchmarking May 2025 Importers / Authorities Low/high risk country lists published Reg 2025/1093
General application 30 Dec 2026 Large & medium operators Full DDS; EUTR repealed Reg 2025/2650
SME application 30 Jun 2027 Micro & small operators DDS / Simplified declarations apply Reg 2025/2650
Extended scope 30 Dec 2027 Derived product importers Soluble coffee, palm soap, cattle tongues in scope Delegated Act 2026
Customs interface 1 Dec 2029 All importers & customs EU Single Window integration Art. 28(1) EUDR

What to have in place before 30 December 2026

Ten things an authority can ask a furniture operator for from 30 December 2026.

1

SKU and Commodity Mapping

Verify which of your products contain, are fed with, or are made using cattle, cocoa, coffee, palm oil, rubber, soya, or wood, using their exact Combined Nomenclature (CN) codes.

2

Role and Liability Identification

Determine whether you are an Operator (importing raw/derived commodities directly), a Downstream Operator (processing previously cleared EUDR-compliant components), or a Trader.

3

Country Risk Profiling

Identify which countries your commodities originate from and verify their benchmarking status (Low Risk, Standard Risk, or High Risk) under Implementing Act (EU) 2025/1093.

4

Geolocation Collection and Mapping

For operators, require your suppliers to provide latitude/longitude coordinates (with 6 decimal places) and polygons for plots larger than 4 hectares.

5

Legality Assessment

Establish a formal legality checklist covering local land rights, environmental laws, labour standards, international human rights, and Free, Prior, and Informed Consent (FPIC) protocols.

6

Certification Scheme Audit

Review the standards, auditing frequency, and chain of custody models of your third-party certification schemes (e.g., FSC, PEFC, RSPO) to ensure they exclude mass balance mixing.

7

Due Diligence System (DDS) Setup

Create your corporate Due Diligence System as required by Article 12, establish an internal review workflow, and appoint a Compliance Officer at the management level.

8

Information System Registration

Set up your EU Login, obtain an EORI number from customs, and register your corporate profile in the EUDR Information System.

9

Downstream Tracking and Logging

For downstream operators, keep one central record to collect, log, and store Reference Numbers and declaration identifiers from direct suppliers.

10

System Integration Testing

Test your supply chain data flow and run dry runs using the ACCEPTANCE training server to validate data structures and API integrations before the application deadline.

Tappr Compliance Advisory

Test the data flow on the ACCEPTANCE server before December 2026, with real supplier data. A pipeline that fails in the dry run fails at customs.

What EUDR means for your furniture team from 30 December 2026

The hard part of EUDR for furniture is not the forest. It is the sixty suppliers, the polygons, the permits and the Latin names, for every board and every veneer, every season. Chased by email, that does not hold for one season.

What has to run on its own:

  • Suppliers answer from a link: plot coordinates as points or polygons, harvest permits and legality evidence, uploaded once per order and checked on arrival.
  • Plots checked against the 2020 forest layer: every polygon set against the satellite record for 31 December 2020 before the goods are placed on the market.
  • The statement built from the record: bill of materials, geolocations and legality evidence compiled into the Annex II statement and filed through the information system's API, reference number back.
  • Reference numbers kept for the downstream role: collected from direct suppliers, matched to the customs EORI profile, kept five years.

In Tappr that is what Trace does, so your team approves instead of chases. What it looks like on a piece of furniture is on the furniture page. The first date is 30 December 2026.

EUDR for furniture questions, answered

Does the EUDR apply to products already sitting in our warehouses?
No. Under the transitional rules, products placed on the EU market before the general application date (30 December 2026, or 30 June 2027 for micro/small enterprises) are exempt from EUDR obligations. The trigger is the date of "placing on the market", not the date of production. However, any stock placed on the market after these dates must be fully compliant.
Are small businesses completely exempt from the regulation?
No. If you qualify as a micro or small enterprise (under Directive 2013/34/EU), you benefit from a deferred application date (30 June 2027) and are exempt from standard risk assessment and risk mitigation if sourcing from low-risk countries. However, you must still register and submit a one-time simplified declaration in the Information System.
Are products made from 100% recycled paper or wood in scope?
Products made entirely from recycled or recovered materials that have completed their lifecycle and would otherwise be discarded as waste are completely exempt from the EUDR. However, if a product contains any portion of virgin pulp or non-recycled wood, that virgin portion is fully subject to due diligence.
Does using FSC or PEFC certified paper grant a "green lane" to the EU market?
No. While voluntary third-party certifications (e.g., FSC, PEFC, RSPO) provide valuable evidence for risk assessment (Article 10(2)(n)), the European Commission has clarified that they do not substitute the operator's legal responsibility and do not grant a "green lane". Operators must still exercise due diligence and remain fully liable.

Official sources