EUDR furniture rules: what to ask your supplier before 30 December 2026

Where the EUDR stands in October 2026

The EU Deforestation Regulation, Regulation (EU) 2023/1115, has been postponed once already, and many furniture buyers are still waiting to see whether it will move again. The signs say it will not. On 4 May 2026 the European Commission published its simplification review with updated guidance, and according to Hogan Lovells it confirmed that the application date would not be postponed. When we reviewed this article, we found no published proposal to change the dates.

The middle row matters for our sector. The EU Timber Regulation already covered wooden furniture under heading 9403. A small company that imports wooden bedroom or children's furniture should therefore plan for December 2026, not June 2027.

Is furniture in scope?

Yes. Annex I of the regulation, as updated by Delegated Regulation (EU) 2026/2102, lists wooden furniture and parts under codes ex 9403 30, 9403 40, 9403 50, 9403 60 and 9403 91. The panels most furniture is made from are listed as well: particleboard (4410), fibreboard including MDF (4411) and plywood (4412). Wooden-framed seats are covered under a set of specific 9401 codes.

Two exclusions are worth knowing:

• Used and second-hand furniture is not covered.
• Recycled wood is outside the rules only if the product is made entirely from material that has completed its life cycle. The Commission's FAQ says that if a product contains any non-recycled material, it is subject to the requirements. By-products such as sawmill residues stay in scope.

Who is the operator: the importer, not the factory

Under the EUDR, the operator is the company that places the product on the EU market. For furniture made outside the EU, that is normally the EU importer. The Commission's FAQ states that the regulation does not impose direct obligations on producers in third countries. A non-EU company that itself places the goods on the EU market, acting as the importer, becomes the operator and must file the statement.

In practice the importer must:

1. collect the required information from its supplier;
2. carry out due diligence on that information;
3. submit a due diligence statement in the EU Information System before lodging the customs declaration;
4. make the reference number of that statement available to customs;
5. communicate the reference number to its customers further down the supply chain.

EU companies further down the chain have lighter duties. A 2025 amendment created the category of downstream operator for companies that sell on products already covered by a statement. They do not file their own statement. They keep records of their suppliers and customers, the first downstream operator keeps the reference numbers it receives from the operator, and larger ones must register in the Information System.

The data to obtain from your supplier

Article 9 of the regulation lists the information the operator needs. For a furniture shipment, this is what a complete supplier file contains:

• a description of the product and the quantity;
• the common name and full scientific name of every wood species;
• the country of production of the wood;
• the geolocation of all plots of land where the wood was harvested;
• the date or time range of harvest;
• the names and contact details of the suppliers in the chain;
• evidence that the wood is deforestation-free: the land was not deforested, and the forest was not degraded by the harvest, after 31 December 2020;
• evidence that it was produced in line with the laws of the country of production.

The operator keeps this information for five years.

The hard part for panel furniture

Most bedroom and children's furniture is made from particleboard and MDF, not from single logs. A panel mill can draw wood from many forests in the same week. The Commission's FAQ is clear that for imported furniture with different wood components, the operator needs to geolocate all the plots of land, and that mass balance accounting is not allowed.

This is why the first question to a furniture supplier is about its board mills. A furniture factory can only pass on the plot data its panel suppliers are able to give it.

What Türkiye's low-risk status changes

The Commission classifies countries as low, standard or high risk. Türkiye is on the low-risk list. For wood produced in low-risk countries, importers may use simplified due diligence, which drops the risk assessment and risk mitigation steps.

Two limits apply. First, the FAQ states that there is no exception for the traceability requirement via geolocation. Second, the classification follows the country where the wood was grown, not the country where the furniture was made. If a factory in a low-risk country uses boards made partly from wood harvested elsewhere, the importer needs to know where, and whether that origin is low risk too.

Certification, penalties and the old Timber Regulation

Certification. FSC and PEFC certificates help, but the regulation says they should not substitute the operator's responsibility for due diligence. Treat a certificate as supporting evidence in the file.

Penalties. Member states set their own penalties within a common framework. The regulation requires that the maximum fine be at least 4% of the operator's total annual EU turnover. Other penalties include confiscation of the products and temporary exclusion from public procurement for up to 12 months.

Timber Regulation. The EU Timber Regulation is repealed with effect from 30 December 2026. It continues to apply until 31 December 2029 for timber produced before 29 June 2023.

A supplier questionnaire you can copy

Send these questions to each furniture supplier now, while there is still time to fix gaps before the first shipment under the new rules.

1. Which wood-based materials are in each product: particleboard, MDF, plywood, solid wood, veneer?
2. Which mills supply each material, and in which countries are they located?
3. For each material, which species are used, with scientific names?
4. In which countries was the wood harvested?
5. Can the mill provide geolocation data for all plots, linked to the production batch used for our order?
6. What is the harvest date range for that batch?
7. Does any material contain recycled wood, and is it documented as post-consumer?
8. Which certificates or legality documents can you provide, and for which materials?
9. In what format and how long before shipment will we receive the data?
10. Who is your contact person for traceability questions?

Suppliers that already export to large European retail chains have usually been asked these questions and can answer them. If the answers are slow or vague, raise it early. A shipment that arrives without the data cannot be covered by a due diligence statement.

Where to start

Start with your highest-volume product groups and work back to the board mills. Agree the data format with your customs broker, then run one shipment as a dry run before 30 December 2026.

If you are reviewing where you buy, our guide to sourcing furniture from Türkiye covers duties, transit times and documents.

Frequently asked questions

When does the EUDR apply to furniture importers?

From 30 December 2026 for large and medium operators, and from 30 June 2027 for micro and small operators. There is an exception that matters for furniture: micro and small operators that were already covered by the EU Timber Regulation also start on 30 December 2026, and the Timber Regulation covered wooden furniture under heading 9403.

Does a furniture manufacturer outside the EU have to file a due diligence statement?

Not when an EU importer places the goods on the market. The regulation does not impose direct obligations on producers in third countries, and the EU importer files the due diligence statement in the EU Information System. A non-EU company that itself places the goods on the EU market, acting as the importer, is the operator and must file.

Is Türkiye a low-risk country under the EUDR?

Yes. Türkiye appears in the low-risk list published in Implementing Regulation (EU) 2025/1093. For wood produced in low-risk countries the importer can use simplified due diligence, without the risk assessment and risk mitigation steps. The traceability requirement, including geolocation of the plots, still applies.

Does FSC or PEFC certification make furniture EUDR compliant?

Not on its own. The regulation says certification schemes can support the risk assessment, but they do not replace the operator's own responsibility for due diligence. A certificate is useful supporting evidence, and the plot-level data is still required.