The dates, and why they matter now
Two consequences for a purchasing calendar: data must be captured per timber lot in 2026 production runs if you want stock on the market after December — you cannot retrofit traceability onto goods already manufactured. And small-importer relief is six months, not a strategy.
Which of our products are in scope
| Our product | CN code | In EUDR scope? | Data we supply |
|---|---|---|---|
| Wooden picture frames | 4414 | Yes | Species, harvest region, supplier legality reference |
| Loose moulding, T&G boards | 4409 | Yes | Lot-level timber provenance |
| Fence, trellis, planter, bed, pet house, insect hotel | 4421 | Yes | As above, per production lot |
| Shed kits, pergola members | 9406 / 4418 | Yes | Grading + provenance pack |
| Cutting boards, tableware | 4419 | Yes (bamboo excluded. It is a grass) | Species; for bamboo, botanical name and source |
| Gift boxes, engraved ornaments | 4420 | Yes | Species + printing-ink declarations separately |
| Plywood crates, pallets | 4415 / 4412 | Packaging is generally not itself a relevant good, but the packaging timber's origin is documented | ISPM-15 records + origin |
The five things a due-diligence statement needs
| Requirement | What it means in practice | Who supplies it |
|---|---|---|
| Product description & quantity | Commercial description, weight or value, HS code | Invoice / packing list, us |
| Country of production | Country, and sub-national region where required | Our timber purchase records |
| Geolocation of the harvest area | Coordinates for the plot or concession where the timber was felled | Sawmill / importer-of-log records — the hard part |
| Legality evidence | Harvest permits, concession rights, payment receipts, third-party certification where used | Supplier declarations we hold |
| Risk assessment + mitigation | Zero-risk assertion, or a documented assessment with mitigation measures | You, with our traceability file |
Geolocation: what we can and cannot provide
This is where buyers should push their supplier, because it is the weakest link in every timber supply chain, Chinese or otherwise. Two practical asks: (1) require the timber purchase documents to name the mill and the origin region per lot, not per catalogue; and (2) require that the lot number on your invoice ties to that record. If a factory cannot do the second thing, it will not be able to do the first one on demand either.
We are honest about our own gap: some mixed-poplar lots bought through county timber markets carry region-level rather than plot-level provenance. Where your programme needs plot-level data, we buy designated timber for that order and price it accordingly, and we say so before the PI, not after an audit.
What penalties look like, and who carries them
Fines are set by Member States but the regulation caps the floor at 4 % of the operator's total EU turnover, with confiscation of the goods and of the proceeds, and exclusion from public procurement for serious or repeated breaches. The burden sits on the operator placing goods on the market, which for most import arrangements is you, not us. That is the reason a factory should be supplying you with data in a form your filing system can ingest, rather than a PDF that says 'our timber is legal'.
The supplier data pack you should demand
- Per-lot timber purchase record: species (botanical name), origin region, mill, volume, date.
- Geolocation field per lot where obtainable, and a written statement where it is not, with the mitigation.
- Chain-of-custody certificate references for FSC/PEFC-claimed lines, matched to the SKUs actually shipped.
- A statement mapping your PO line to the production lot, so a DDS can be assembled without guesswork.
- Retention of records for at least five years, available to you on request.
- Named contact who can answer a customs or retailer query within 24 hours, not a generic inbox.
A 90-day preparation plan
| Week | Action | Owner |
|---|---|---|
| 1–2 | Map every SKU to its HS code and material composition, including composite parts | You + us |
| 2–4 | Request per-lot provenance data from each supplier; identify gaps | You |
| 4–6 | Agree the data format with your DDS filing process (or your compliance provider) | You |
| 6–8 | Designate certified timber for orders shipping after December; re-price those lines | Us |
| 8–10 | Run a mock due-diligence statement on one real order end to end | Both |
| 10–13 | Write the risk assessment; document mitigation or the zero-risk justification | You |
Regulation (EU) 2023/1115 (EUDR) as amended by Regulation (EU) 2025/2650, including the amended application dates and Annex I product scope; European Commission EUDR guidance and competent-authority notices; UK Forest Risk Products Regulations guidance (DEFRA). This article is a compliance summary for planning purposes, not legal advice — your filing obligation is determined by your competent authority and your own size classification.
