What is the EU Deforestation-free Regulation (EUDR)?

The EUDR is a regulation from the European Union aimed at reducing the EU's impact on global deforestation. It requires companies placing commodities like wood, coffee, or soy on the EU market to prove the products did not come from land deforested after December 31, 2020.

When do the EUDR compliance rules take effect?

The main compliance obligations begin on December 30, 2025, for most companies. Qualifying micro and small enterprises have an extended deadline of June 30, 2026.

What information must suppliers provide for EUDR due diligence?

Suppliers are crucial for providing the data needed for a Due Diligence Statement (DDS). This includes a product description, quantity, country of production, harvest date, and, most importantly, the precise geolocation coordinates of all plots of land where the timber was harvested.

What kind of "precise geolocation" data is required by the EUDR?

The regulation requires the geolocation of all plots of land where the timber was harvested. For plots of land under four hectares (approx. 10 acres), a single latitude and longitude point is sufficient. For plots larger than four hectares, the data must be supplied using polygons, which is a series of coordinates that map the plot's entire boundary. GPS Coordinates must be given to the 6th decimal place.

Are wood pallets covered by the EUDR?

Pallets are listed under HS code 4415 and are generally covered by the regulation. However, the EUDR includes a critical exemption for packing material that is used exclusively to support, protect, or carry another product. Pallets used in this way do not require a DDS.

What does "deforestation-free" mean in the context of the EUDR?

"Deforestation-free" means the wood comes from land that was not converted from forest to agricultural use after December 31, 2020. It also means the timber was harvested without inducing "forest degradation," such as converting a primary forest into a plantation forest, after this date.

Understanding the EUDR Impact for US Wood Product Suppliers

Joe H
Apr 4
6 min read

Updated: Aug 11

The European Union has enacted a significant piece of legislation, the EU Deforestation-free Regulation (EUDR), aimed at reducing the EU's impact on global deforestation and forest degradation. For companies involved in the wood products supply chain, understanding this regulation is crucial. While the core compliance obligations begin on December 30, 2025, for most companies (with an extension to June 30, 2026, for qualifying micro/small enterprises), the time to prepare is now.

Recent EUDR Developments (As of August 2025) Since early 2025, there have been significant developments. The European Commission introduced measures to simplify compliance and launched a new online system for submitting due diligence statements. Most notably, a controversial country benchmarking system was introduced and subsequently contested by the EU Parliament, creating uncertainty for suppliers. This post has been updated to reflect these important changes.

The EUDR covers several commodities like coffee, cocoa, soy, rubber, palm oil, cattle, and wood. This post specifically focuses on the implications for wood-based products.

A key aspect of the EUDR is that while the legal responsibility for compliance rests with the 'operator' (the entity placing the product on the EU market or exporting it), the practical requirements ripple down the entire supply chain. Any supplier of wood or wood components, from timber harvest to the final processed item, is directly impacted. Companies unable to provide the necessary proof of compliance risk being cut out of supply chains serving the significant EU market.

Why EUDR Impacts Suppliers: Your Role in Due Diligence

The cornerstone of EUDR compliance is the Due Diligence Statement (DDS). An 'operator' cannot legally place covered products on the EU market unless they are accompanied by a DDS submitted through a new online portal called the EUDR Information System. This system is now live, and a training version is available for businesses to familiarize themselves with the process.

The DDS confirms that the operator has performed due diligence and found no more than a negligible risk that the products violate EUDR requirements. To conduct this due diligence, the operator must collect specific, verifiable information about the product's origin. This is where suppliers become indispensable. The required information includes:

Product description (including wood species).
Quantity.
Country of production.
Precise geolocation (latitude/longitude coordinates, potentially polygons) of all plots of land where the timber was harvested.
The date or time range of the harvest.
Verifiable information proving the product is deforestation-free.
Verifiable information proving the timber was harvested in accordance with the relevant laws of the country of production (legality).

Recognizing the administrative burden, the EU has introduced simplification measures. These allow for the submission of a single DDS to cover multiple shipments over time (e.g., annually) and permit the reuse of a DDS for products that are re-imported into the EU.

The Evolving Situation: Country Risk Levels and Lobbying

A significant point of discussion has been whether some countries could be considered "low risk," thereby simplifying the due diligence process.

Initially, proposals for a "no-risk" country category that could have exempted countries like the US were rejected by EU institutions. Following this, the European Commission introduced a country benchmarking system in May 2025, classifying countries as low, standard, or high risk. In this initial classification, the United States was designated as "low risk."

However, in a subsequent vote in July 2025, the European Parliament rejected this classification system, citing a lack of transparency and a flawed methodology. This vote, while not legally binding, has created significant uncertainty. It is now unclear if or when a risk classification system will be implemented. Therefore, for now, U.S. suppliers should prepare to provide full traceability and due diligence data for all exports to the EU.

Industry groups continue to lobby regarding the regulation, with some hoping for further clarification and simplification of the requirements.

Understanding Deforestation, Degradation, and Forest Types

The EUDR aims to ensure products are "deforestation-free," which has two main components related to a cut-off date of December 31, 2020:

Deforestation: The timber must come from land that was not converted from forest to agricultural use after December 31, 2020.
Forest Degradation (for Wood): The timber must have been harvested without inducing forest degradation after December 31, 2020. This specifically refers to structural changes like converting primary or naturally regenerating forests into plantation forests.

The regulation distinguishes between different forest types:

Primary/Naturally Regenerating Forests: These have the highest ecological value and are strongly protected against degradation under the EUDR definition. Timber harvested from such areas after the cut-off date requires rigorous proof that the harvest did not cause degradation (e.g., conversion to a plantation).
Managed Forests (Planted/Plantation Forests): These are forests established through planting/seeding, often managed for timber production. If land was already operating as a planted/plantation forest before the Dec 31, 2020 cut-off, routine harvesting and replanting within that system generally does not meet the specific definition of forest degradation, provided no conversion from remaining primary/natural elements occurs.

Compliance Proof: Regardless of the forest type, suppliers must help the operator gather proof of:

Legality: Compliance with all relevant laws in the country of production (land use, environment, forest rules, labor, human rights, etc.).
Land Status & Activity: Verifiable evidence (e.g., permits, management plans, geolocation data linked to harvest dates, potentially satellite imagery analysis) confirming the land classification at the cut-off date and demonstrating that harvest activities after that date complied with the deforestation and forest degradation rules.

Impacted Wood Products

The EUDR applies to a wide range of wood products placed on the EU market. If derived from harvested timber, the following categories (identified by their HS codes in Annex I) require compliance:

Annex I Items - Wood Products [Click to see the entire list]

Fuel wood, Chips, Particles, Sawdust, Pellets (4401)
Wood Charcoal (4402)
Wood in the Rough (Logs) (4403)
Hoopwood, Poles, Pickets, Sticks, Chipwood (4404)
Wood Wool, Wood Flour (4405)
Railway Sleepers (4406)
Sawn/Chipped Wood (>6mm thick) (Lumber) (4407)
Veneer Sheets, Plywood Sheets (≤6mm thick) (4408)
Continuously Shaped Wood (Flooring, Moulding) (4409)
Particle Board, OSB (4410)
Fibreboard (MDF, etc.) (4411)
Plywood, Veneered Panels, Laminated Wood (4412)
Densified Wood (4413)
Wooden Frames (4414)
Packing Cases, Boxes, Crates, Cable-Drums, Pallets, Box Pallets, Load Boards, Pallet Collars (4415) - Note: An exemption exists for packing material used exclusively to support, protect or carry another product placed on the market.
Casks, Barrels, Vats, Tubs (Coopers' Products) (4416)
Wooden Tools, Handles, Lasts (4417)
Builders' Joinery & Carpentry (Doors, Windows, Shingles, Assembled Flooring Panels) (4418)
Tableware and Kitchenware of Wood (4419)
Wood Marquetry, Caskets, Statuettes, Ornaments, certain non-Chapter 94 Furniture (4420)
Other Articles of Wood (4421)
Pulp and Paper (Chapters 47 & 48, excluding bamboo/recovered products)
Printed Paper Products (ex Chapter 49)
Wooden Seats/Parts (ex 9401)
Specific Wooden Furniture categories/Parts (parts of 9403)
Prefabricated Buildings of Wood (9406 10)

A Note on Blackberry Pallet and Turman Group

For Blackberry Pallet customers, our pallets when used to protect and support for storage and transportation of customers’ goods into the EU, the exemption noted under HS code 4415 apply and do not require EUDR documentation and DDS. Blackberry Pallet does provide certified ISPM 15 heat treated pallets for international shipping to the EU and elsewhere.

However, as part of the Turman Group, Blackberry Pallet sources its lumber from within this vertical integration, connecting us to a legacy grounded in sustainability. The Turman Group has a long-certified history of commitment to Sustainability and responsible Forestry Practices, reflecting a core value of ensuring the health and abundance of our forest resources for future generations.

Assess Your Supply Chain Connection

The EUDR represents a fundamental shift towards traceable, deforestation-free supply chains. For any company involved in harvesting, processing, or manufacturing wood-based products, it is now critical to evaluate whether your products might ultimately reach the EU.

The key takeaway from the recent developments is that while some processes may be simplified, the core requirement for plot-level geolocation and proof of legality remains. The political uncertainty around the country risk system means that all suppliers, regardless of origin, must focus on robust data collection and traceability. Failing to prepare could jeopardize your company's valuable position within EU-bound supply chains.