EUDR: the one that changes your paperwork
The EU Deforestation Regulation applies from 30 December 2026 for large and medium operators, and 30 June 2027 for micro and small ones. Most of Chapter 44, including 4409, 4412, 4414, 4418, 4419, 4420 and 4421. Is in scope, and that covers nearly everything we manufacture.
What a due-diligence statement needs: product description and quantity, country of production, the geolocation coordinates of the harvest area, the relevant legality references, and a risk assessment with mitigation where non-negligible risk exists. Operators placing goods on the EU market are responsible for the statement; we supply the supply-chain information and the harvest data, and we keep it in a form you can paste into your own filing.
| Requirement | Who files | What we provide | What you must do |
|---|---|---|---|
| Due-diligence statement (DDS) | EU operator (you or your importer) | Species, harvest country, region, geolocation where applicable | Lodge the DDS in the EU information system before placement |
| Geolocation of harvest | Supply chain | Plot/forest-concession coordinates from our timber suppliers | Verify they are supplied per lot, not per catalogue |
| Legality evidence | Supply chain | Harvest permits / purchase documents, supplier declarations | Keep them for the required retention period |
| Risk assessment & mitigation | EU operator | Supplier audit and traceability records | Document your own assessment |
| UK equivalent (FPOR) | UK operator | Same data pack, UK format | File under the UK Forest Risk Products Regulations |
Structural timber: CPR, CE and UKCA
If a wooden article is a construction product, it needs a Declaration of Performance and CE marking (or UKCA for Great Britain). Decorative garden items usually are not; load-bearing members and kits often are.
- In scope in practice: structural wall panels and framing for sheds and cabins, graded beams and posts sold as building components, wooden doors and window frames, some pergola kits where the roof carries a load.
- Usually out of scope: trellis and lattice panels, planters, insect hotels, fencing sold as garden retail goods, dog houses, frames, boards, giftware.
- Grading standards: EN 14081-1/-2 strength grading; EN 338 strength classes (C16/C24 typical); EN 335 use classes 3 and 4 for decay risk; EN 81-1 fastener guidance.
- Biocides: the preservative must be authorised under the BPR/UK BPR. We name the active substance and the treatment plant's authorisation on request.
- Never CCA: chromated copper arsenate is restricted for consumer and structural use in the EU. We do not use it on any product line, and we will not treat a customer's own specification as a waiver.
Chemicals, coatings and materials
| Rule | Touches which of our products | What we hand you |
|---|---|---|
| REACH (Annex XVII restrictions) | Treated timber preservatives, coatings, azo dyes on textiles in pet cushions | Compliance statement per material |
| Regulation 1935/2004 + 10/2011 | Cutting boards, serving ware, bamboo tableware, liners that touch food | LFGB / EU migration report and number |
| CLP labelling | Any coating or treatment chemical you re-sell | SDS on request |
| EU 528/2012 BPR | The preservative used at the treatment plant | Active substance name + authorisation reference |
| Toy Directive 2009/48/EC | Wooden toys, school kits, anything with play value | EN 71-1/-2/-3 report |
| Packaged-goods weight limits | Retail cartons and sleeves | Artwork compliance check before print |
Packaging EPR: the fee nobody budgets for
Germany (LUCID + dual system), France (CITEO/Triman) and the Benelux countries require producer responsibility registration before your packaging legally enters the market. Registration is normally yours as importer, and we supply the material weights so you can declare accurately.
- Germany: LUCID registration with ZSVR plus a dual-system contract; a missing registration can void your ability to sell, and marketplaces enforce it.
- France: CITEO participation and the Triman sorting mark on household packaging; textiles (pet cushions, planter liners) fall under Refashion.
- Netherlands / Belgium: national F-WCO/Stichting Afvalfonds regimes; again, declaration by material weight.
- PPWR: the Packaging and Packaging Waste Regulation applies from 12 August 2026 and from 1 January 2030 restricts very small cosmetic and hotel amenity packaging in accommodation. Relevant if you sell hospitality wooden goods, and it pushes the market toward larger dispensers and solid formats.
- What we supply: per-SKU carton weights by material (paper, board, plastic film, timber), so your EPR declaration is arithmetic rather than guesswork.
Other EU/UK market requirements worth naming
- GPSR (General Product Safety Regulation): since December 2024, non-food products need an EU-based responsible person and traceable product identification. Put it on your label, not ours.
- Digital Product Passport: phased in by category from 2026–2027; textiles, furniture and electronics first. We will supply the material data when your category enters scope.
- Timber-declaration habits: German and French retail increasingly asks for species and origin at SKU level; we supply both.
- CE/UKCA on electrical add-ons: our LED-lit frames and lighted sheds use an EU/UK-marked driver supplied by a certified component partner; we do not self-declare somebody else's electronics.
- Accessibility of our data: we will supply a compliance summary per SKU in a form you can forward to your notified body or retailer's technical team.
A realistic onboarding timeline
Allow 60–90 days from first contact to a signed spec for an EU programme, mostly for documentation, not machining. EUDR data collection is the long pole, and it is longer for a mixed-species supply chain than for a single-species one.
| Step | Duration | Who moves |
|---|---|---|
| Spec + material choice | 1–2 weeks | Us + you |
| Timber lot traceability & geolocation capture | 2–5 weeks | Us, with our sawmills |
| Sample build and approval | 1–3 weeks | Us, then you |
| Coating / migration testing | 3–4 weeks | Third-party lab |
| DoP / CE assessment where structural | 2–6 weeks | Your notified body or self-declaration |
| EPR registration (LUCID/CITEO) | 1–3 weeks | You |
| First production | 30–45 days | Us |