Filed under EUDR Timeline: Application Dates, Amendments and What Happens Next
Plot record: legal status and review details
- Jurisdiction
- European Union
- Status
- In force; substantive obligations apply on the dates and conditions specified in current law.
- Application
- 30 December 2026 generally; 30 June 2027 for qualifying operators under Article 38(3); 30 December 2027 for expressly deferred Annex I entries.
- Relevant provisions
- Articles 1(2), 3 and 37
Review this page when:
- Amendment to Articles 37 or 38
- Annex I amendment
- Updated Commission guidance or FAQs
Older timber has a specific transitional route
EUDR Article 37 sets special rules for timber and timber products within the EUTR definition produced before 29 June 2023. Where those products are placed on the market from 30 December 2026, EUTR continues to apply until 31 December 2029. Paragraph 3 separately requires the described older products placed from 31 December 2029 to comply with EUDR Article 3.
This is a product-specific route, not a general exemption for a timber business or all inventory purchased before EUDR application. Use the main implementation timeline for the surrounding dates. The task for legacy stock is to establish product identity, production history and the legally relevant placement, then connect those facts to the correct paragraph.
First confirm that the product qualifies
Article 37 refers to timber and timber products as defined in Article 2(a) of Regulation (EU) No 995/2010. Check that definition and the EUTR Annex rather than assuming the transition applies to everything made partly from wood. Product classification and the description of the actual goods are the starting point.
Create a decision for each meaningful stock category. Retain specifications, CN classification and any evidence needed to distinguish covered goods from other products. Where the product has changed through manufacturing or processing, examine the resulting product and its history. A purchase record for an input may be relevant, but it is not automatically conclusive evidence about when a different finished product was produced.
Establish production before 29 June 2023
The historical condition is production before 29 June 2023. A delivery date, invoice date or date of entry into the seller's warehouse can help corroborate the history but does not necessarily identify production. Ask what each document actually proves. A record dated in 2022 may relate to a contract for goods produced later.
Useful evidence may include dated production records, lot references, inventory movements and transaction documents that consistently identify the same goods. The regulation does not create one universal certificate proving older-stock status for all countries and products. The evidence needs to be credible, sufficiently detailed and connected to the physical stock for which the transition is claimed.
Identify the market event separately
The transition also uses placement on the market. Do not assume that storage outside the EU or a transaction between non-EU parties proves prior EU placement. Follow the relevant definition and the facts of the product's commercial movement. The shipment, customs and sales records may each describe a different stage.
For goods planned for a future import, record the expected event and review it when the actual transaction occurs. If the commercial arrangement changes, the original timing assumption may no longer hold. A decision based on a draft purchase order should not survive unchanged after goods are diverted, split, transformed or supplied through a different entity.
Keep old and new stock distinguishable
A legacy-stock route works only if the business can identify the goods relying on it. Mixing older and newer timber without reliable records can undermine the production-date claim. Physical separation, lot control and quantity reconciliation may support the evidence, particularly where similar goods share a warehouse location or product code.
Check whether recorded older-stock quantities remain plausible after repeated dispatches. A transitional batch should not effectively replenish itself through purchases of newer products. Investigate discrepancies and document corrections. If the business cannot establish that a consignment belongs to the qualifying older stock, it should resolve the uncertainty instead of relying on a broad supplier statement about the age of its inventory.
The preserved EUTR period still has obligations
Article 37(2) continues EUTR application for qualifying products; it does not suspend timber due diligence altogether. Keep the EUTR records required for the relevant activity and ensure staff understand that a transitional classification is a route into an existing legal regime. It is not a declaration that the product requires no further review.
The EUTR repeal explanation distinguishes formal repeal from continued application. This distinction matters when maintaining policies: deleting every EUTR procedure on 30 December 2026 could remove controls still needed for qualifying older goods. Retire a procedure only after the business has identified which stock and activities continue to depend on it.
Apply the exact 2029 boundary
Article 37(2) says EUTR continues until 31 December 2029; paragraph 3 says the described older products placed from 31 December 2029 must comply with Article 3. Preserve both statements in the timetable. Replacing them with EUDR starts in 2030 would obscure the date expressly specified by paragraph 3.
For boundary-date transactions, obtain a focused review of current law and official guidance before release. Record the actual date and evidence rather than shifting the transaction in internal paperwork to fit a preferred regime. The commercial plan should allow time to resolve the legal and factual position without last-minute pressure on staff to approve unsupported treatment.
Article 3 becomes relevant for the described later placements
Paragraph 3 is an express derogation from the general older-product exclusion in Article 1(2). For the timber it describes, old production does not remain a permanent shield from EUDR Article 3. The Article 3 conditions must therefore be considered when qualifying older timber is placed from the specified boundary.
The authoritative source is current Article 37. Maintain a legacy-stock register with the classification, production evidence, placement decision, applicable regime and review date. That record should let an independent reviewer follow the reasoning from physical goods to legal conclusion without relying on the memory of the person who originally bought the stock.
Primary sources on the record
Articles 1(2), 3 and 37. 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.