Filed under EU Deforestation Regulation Explained: Scope, Requirements and Compliance
Plot record: legal status and review details
- Jurisdiction
- European Union
- Status
- In force; main obligations apply according to Article 38
- Application
- 30 December 2026 generally; 30 June 2027 only where Article 38(3) applies; specified Annex I additions from 30 December 2027
- Relevant provisions
- Articles 1 to 3, 8 to 11, 37 to 38; Regulation (EU) No 995/2010
Review this page when:
- EUDR amendments
- Commission guidance or FAQ revision
- Article 38 application dates
- Annex I amendments
A broader regime with a timber transition
EUDR replaces the EU Timber Regulation framework with rules covering listed products associated with seven commodities and combining legality with deforestation-free requirements. The EU Timber Regulation, Regulation (EU) No 995/2010, addresses illegally harvested timber and timber products. The two regimes therefore share an interest in lawful timber sourcing but do not have identical scope or compliance tests.
The transition also matters. Article 37 of the current EUDR repeals EUTR from 30 December 2026 while preserving its application for specified older timber during a transitional period. A business cannot decide which rules govern a timber batch by comparing the two regulations in the abstract; it needs the product, production date and market-placement date.
Product coverage is different
EUTR concerns timber and timber products within its Annex. EUDR begins with cattle, cocoa, coffee, oil palm, rubber, soya and wood, with relevant products listed in Annex I. Even within wood supply chains, businesses should compare the actual entries instead of assuming every EUTR scope conclusion can be copied into an EUDR register.
The product description and customs classification remain important. A manufacturer handling a range of articles may have different conclusions for different stock lines. September 2026 changes to the EUDR product list are another reason to record the legal version used. A static list prepared for EUTR several years ago is not a dependable current EUDR scope tool.
Legality remains necessary but is insufficient alone
EUTR prohibits placement of illegally harvested timber and requires operator due diligence. EUDR separately requires compliance with relevant legislation in the country of production and deforestation-free status. For wood, the deforestation-free definition includes both the cut-off-related deforestation condition and the specified forest-degradation condition.
A timber harvest can therefore satisfy national permission requirements while still raising a separate EUDR question about post-cut-off forest conditions. Conversely, land-history evidence cannot replace the applicable legality assessment. The three EUDR conditions explain why historical environmental evidence, legal production evidence and regulatory coverage must all be considered.
Production locations become central
EUDR Article 9 requires production-location information and the production date or time range, alongside the product, quantity and country information. Ordinary geolocation requirements include points or polygons as specified by Article 2. Wood product descriptions also identify the common and full scientific species names.
The operational task is to connect the actual timber products to the relevant harvest origins, including through processing and aggregation. A supplier's office address cannot substitute for that connection. Existing EUTR supplier and legality files can contribute useful evidence, but businesses should test them against each EUDR information requirement rather than simply renaming the folder.
Statements and actor roles have changed
EUDR uses an Information System for due diligence statements and the distinct simplified declaration regime for qualifying micro or small primary operators. Ordinary operators submit the required statement before placement or export. Under the current amended model, downstream operators and traders have Article 5 duties instead of a universal requirement to submit another statement at every stage.
An EUTR role assessment therefore needs updating for EUDR. Importers, processors and distributors should map each flow using the current definitions. A group-wide assumption that every timber company is the same kind of operator can lead to both missing duties and unnecessary duplicate administrative work.
Older timber receives specific transitional treatment
Article 37(2) continues EUTR until 31 December 2029 for timber and timber products within EUTR's definition that were produced before 29 June 2023 and placed on the market from 30 December 2026. Article 37(3) then requires such older timber placed on the market from 31 December 2029 to comply with EUDR Article 3.
The exact dates and wording should be used for boundary cases. Retain evidence establishing the production date and the relevant market event. “Old stock” is not a sufficient legal category by itself, especially when a warehouse contains different production vintages or when material has passed through subsequent manufacturing stages.
Small businesses should not assume the later date
Current Article 38(3) provides the June 2027 date for qualifying operators but expressly excepts products covered by the EUTR Annex. A micro or small timber business therefore needs to check that exception rather than relying on a general statement about additional preparation time for small enterprises.
The EUDR Article 4a primary-operator regime and the Article 38 timing provision are separate questions. Eligibility for a simplified declaration does not automatically establish a later application date. Keep the role, regime, product coverage and deadline conclusions in separate fields so the reasons remain clear to a reviewer.
Upgrade the existing evidence system deliberately
Compare the current timber file against EUDR requirements: location evidence, historical land assessment, legality, product-to-origin traceability, current actor role and statement or declaration coverage. Identify which existing controls remain useful and which gaps require new supplier work. Test the revised system on a real product flow with documented production dates.
The EUDR overview places the timber comparison within the wider regime. Consult Articles 37 and 38 and the substantive EUDR provisions alongside the EU Timber Regulation. Preserve the evidence supporting the transition decision rather than treating repeal as an instruction to discard older timber records.
Primary sources on the record
Articles 1 to 3, 8 to 11, 37 to 38; Regulation (EU) No 995/2010. This entry was checked against the consolidated text dated 18 September 2026. Consolidated texts are documentation tools; the authentic acts are those published in the Official Journal.
Check the current sources and the guidance of the relevant competent authority for your situation. This page is not legal advice or a compliance determination.