Forest Degradation Rules for Wood Products

Wood has an extra deforestation-free condition

For relevant products containing or made using wood, EUDR requires that the wood was harvested without inducing the defined forest degradation after 31 December 2020. This Article 2(13)(b) condition sits alongside the absence of post-cut-off forest conversion to agricultural use. Both need attention in a wood sourcing assessment.

Forest degradation is the specific Article 2(7) set of structural transitions. It includes primary or naturally regenerating forest becoming plantation forest or other wooded land, and primary forest becoming planted forest. Do not replace those transitions with a general statement that every harvest or clear-cut is automatically EUDR degradation.

The deforestation-free framework explains the additional condition. Check the current forest definitions before deciding what evidence the actual wood sources require.

Start with the wood in the relevant product

Identify whether the finished product is within Annex I and which wood sources contributed to it. A product may combine several species, harvest areas or suppliers. The source assessment must relate to the wood actually used, not simply the most recent approved supplier or a representative forest near the mill.

Keep species and origin information consistent with production and purchasing records. Processing can transform the form of the wood without removing the need to understand its source. For composite products, preserve the links between input materials, production runs and finished lots.

Product-scope exclusions and special timing rules should be checked separately. An assessment of forest degradation does not itself establish that the goods are covered, and a scope conclusion does not establish that their wood meets the forest condition. Keep these decisions linked but distinct.

Ask the supplier a forest-transition question

A useful evidence request asks about the source forest before harvest, the harvesting operation and the resulting forest structure or land category. Request suitable inventory, management and regeneration information rather than only a declaration that the wood is legally harvested.

The distinctions among primary, naturally regenerating, planted and plantation forest matter. A document using the word plantation without defining it may not establish the Article 2(11) category. Likewise, a national forest type can differ from the Regulation's terms and needs an explained mapping.

The assessment should also identify the relevant dates and spatial boundaries. A management plan for a large concession may provide context, but the operator needs enough detail to connect the actual harvest source to the evidence about forest type and transition.

Use imagery and documents for complementary purposes

A time series can show harvest openings and subsequent regrowth. It can help detect a change needing investigation or compare the supplied harvest boundary with observed activity. It may not establish all structural or ecological characteristics needed to classify the starting forest and resulting stand.

Forest inventories, management records, planting records and other reliable evidence can complement imagery. Assess their dates, authorship, coverage and consistency. Where a document predicts natural regeneration but later evidence shows intensive plantation establishment, resolve the inconsistency rather than retaining the original low-risk conclusion unchanged.

The 2026 guidance explains why actual land characteristics and appropriate evidence matter. A public forest map or supplier certificate should be interpreted for the facts it supports, not treated as an automatic regulatory approval.

Keep legality separate from the forest condition

A harvesting licence can contribute to the lawful-production assessment, but it does not by itself establish absence of EUDR degradation. A permitted operation could still induce a transition covered by Article 2(7). Conversely, absence of that transition does not establish that all applicable harvesting laws were followed.

Article 3 requires the relevant conditions together. The operator's due diligence should therefore contain separately reasoned conclusions on the applicable forest conditions and relevant production-country legislation, with the required statement or declaration route addressed as well.

For supplier management, avoid a single checkbox labelled legal and sustainable that hides those distinct questions. A better record identifies the evidence supporting each conclusion, any gaps and the action needed before goods can proceed. This also makes later alerts easier to route to the right issue.

For a panel manufacturer buying fibre from several mills, the relevant question is not whether one mill has a reassuring forest policy. Identify the wood origins contributing to the material actually received and which source assessments support them. Where a mill introduces another harvesting area, review its forest history before assuming the existing conclusion remains adequate. Production and purchase links should allow the reviewer to distinguish an unchanged repeat supply from a changed source behind the same commercial product name.

Review mixed sources and new harvesting information

When a product contains wood from multiple origins, review each relevant source and preserve input-to-output links. A new timber source, changed harvest compartment or substitute material can require a fresh assessment. Do not assume a mill's previous approval covers every forest it later purchases from.

The forest-degradation definition helps reviewers identify the precise transition at issue. Record the conclusion, evidence, uncertainty and approval owner. If new information undermines the source assessment, apply the relevant operator or downstream concern duties rather than treating the existing identifier as conclusive.

A defensible wood file explains why the actual harvested material meets the specific condition. It should not make broader environmental claims than the evidence supports or confuse a general policy preference with a transition expressly defined by the Regulation.