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
- Article 37; Article 38(3)
Review this page when:
- Amendment to Articles 37 or 38
- Annex I amendment
- Updated Commission guidance or FAQs
Repeal begins on 30 December 2026, with a defined exception
The EU Timber Regulation, Regulation (EU) No 995/2010, is repealed with effect from 30 December 2026 under EUDR Article 37(1). However, Article 37(2) preserves its application to defined older timber and timber products until 31 December 2029. Repeal therefore does not mean that every timber consignment stops requiring an EUTR assessment on the same day.
The exception concerns timber and timber products within the EUTR definition that were produced before 29 June 2023 and placed on the market from 30 December 2026. The EUDR implementation timetable explains how this fits the wider application dates. This article distinguishes the repeal itself from the continuing transitional treatment of particular older goods.
What Article 37 preserves
The preserved rule is not an optional choice between EUTR and EUDR whenever one seems easier. The regulation defines the product class, historical production boundary and placement period. A business relying on continued EUTR application must demonstrate why the goods fall within those conditions, rather than choosing the regime according to the available supplier documents.
An inventory record should identify the actual product, its EUTR classification, production evidence and intended placement. Link the evidence to batches or other reliable product identifiers. A general supplier letter saying all timber is old does not establish the position of each consignment. Physical segregation may help, but it must be supported by records explaining what is being segregated and why.
Production date and market placement answer different questions
A product may have been produced well before it is first placed on the EU market. Article 37 uses both facts, so the same date should not be copied into both fields automatically. Production evidence concerns the goods' history. Placement evidence concerns the relevant commercial activity within the market framework.
For example, stock held outside the EU since 2022 may require assessment when it is later imported and placed. Its earlier existence does not prove an earlier EU placement. Conversely, a recent warehouse transfer does not necessarily establish first placement. Review the actual supply-chain events and applicable definitions rather than inferring legal status from the most convenient invoice.
The 2029 wording must be kept precise
Article 37(2) states continued EUTR application until 31 December 2029. Paragraph 3 separately requires the described older timber placed on the market from 31 December 2029 to comply with EUDR Article 3. Those words should be preserved in an operational note, especially for consignments planned near the boundary.
Do not summarise the provision as EUTR until the end of 2029 and EUDR from January 2030. That loses the express starting date in paragraph 3. For a transaction on the boundary itself, assess the precise wording and current official interpretation rather than inventing an extra day. Keep the review and relevant evidence with the consignment's release decision.
Newer timber is not covered by this older-stock route
The production cut-off in Article 37(2) is before 29 June 2023. Goods produced after that boundary do not become transitional older timber simply because they were purchased before December 2026. The commercial lead time and the date of a purchase order are different from the historical production condition set by the regulation.
A business holding a mixture of older and newer stock should prevent evidence from one lot being applied to another. Reconciliation between receipts, production records and dispatch quantities can help identify when a claimed older lot has been exhausted. Where processing changes product identity or combines materials, assess the resulting relevant product instead of assuming that an old raw-material invoice settles the issue.
Small operators still need this analysis
The later application date for qualifying micro or small operators expressly excludes EUTR Annex products. A small timber importer should therefore avoid treating June 2027 as a universal transition date. Size, product scope and old-stock treatment are distinct questions that can lead to different legal consequences.
The small-operator December date guide explains the timing exception. A practical file can contain separate conclusions for the operator's application route and the product's Article 37 position. Keeping these decisions separate helps prevent an accounting classification from incorrectly overriding a product-specific transition or an EUTR scope assessment.
What continues to be required during the preserved period
Where EUTR continues to apply under Article 37(2), the business must follow that regime's applicable duties rather than treating the period as an unregulated gap. The fact that EUDR is replacing EUTR does not make legacy timber automatically compliant. Illegal harvesting concerns and inadequate due diligence remain relevant under the preserved rules.
Retain the EUTR due diligence file and associated transaction records in a form that can be retrieved. Keep the reason the product falls within Article 37 beside that file. This allows a reviewer to distinguish a deliberate transitional assessment from a business that simply continued using an outdated procedure without checking whether it still applied.
Build the repeal into procurement and inventory controls
Update procurement forms to capture production history when it affects the legal route. Mark stock with the relevant assessment, and require review where a delivery cannot be connected to its evidence. Inform sales and logistics teams of the precise boundary language so they do not promise a customer a deadline based on a simplified year-end assumption.
The authoritative starting point is Article 37 of the current EUDR. Recheck it when amendments or official guidance change. A controlled transition register should make clear which goods still follow EUTR, which follow EUDR and which remain unresolved pending evidence, with an accountable reviewer for each decision.
Primary sources on the record
Article 37; Article 38(3). 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.