Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
The EUDR has no rolling grace period for older wood. Whether a wood product falls under the EU Deforestation Regulation depends on two fixed dates: when the wood was harvested, and when the product is placed on the EU market.
One question comes up again and again from importers of furniture, paper, packaging and other wood products: “If the wood was harvested years ago, do we still need plot geolocations and a due diligence statement?” It is a fair question. For older stock, tracing the forest plots back through the supply chain can be difficult or impossible.
The answer is not “anything older than X years is exempt”. Wood harvested in August 2023 is already more than three years old, yet it is fully in scope. Wood harvested in 2022 is outside the EUDR for now, and for some products permanently. This guide explains the dates, which rules apply to which products, and what you need to prepare.
The four dates that matter for wood
Four dates define how the EUDR applies to wood, following the amendment of December 2025 (Regulation (EU) 2025/2650).
Date | What it means for wood |
|---|---|
31 December 2020 | Deforestation cut-off. The land the wood comes from must not have been deforested or degraded after this date. This concerns the forest plot, not the harvest date. |
29 June 2023 | Harvest cut-off. The EUDR entered into force on this date. Wood harvested before it is outside the EUDR, either for a transition period or permanently (see below). |
30 December 2026 | The EUDR applies to wood products placed on the EU market. For products already covered by the old EU Timber Regulation (EUTR), this applies to all companies, including micro and small ones. |
31 December 2029 | End of the transition period. From this date, older wood in EUTR-listed products also falls under the EUDR, regardless of harvest date. |
Micro and small operators (micro or small undertakings on 31 December 2024) that place on the market only wood products outside the old EUTR list have until 30 June 2027 to apply the EUDR.
30 December 2026
Get your EUDR due diligence in place before the deadline. EUDR Passport collects your suppliers’ plot data, runs the risk assessment and files your due diligence statements.
Which rules apply to your wood products
What applies depends on the harvest date of the wood, on when the product enters the EU market, and on whether the product was already on the old EUTR list.
Products on the old EUTR list include, for example, sawn wood and logs, wood-based panels and plywood, wooden frames, packing cases and pallets, builders’ joinery, wooden furniture, pulp, and paper and paperboard.
Wood products that were not on the EUTR list but are covered by the EUDR include, for example, wooden kitchenware and tableware, decorative wooden articles, other articles of wood, wooden seats and charcoal.
Harvest date of the wood | Placed on the EU market before 30 Dec 2026 | Placed on the EU market 30 Dec 2026 to 30 Dec 2029 | Placed on the EU market from 31 Dec 2029 |
|---|---|---|---|
Before 29 June 2023, product on the old EUTR list | EUTR | EUTR | Full EUDR |
Before 29 June 2023, product not on the EUTR list | Not covered | Not covered | Not covered |
On or after 29 June 2023 | EUTR, where the product is on the EUTR list | Full EUDR | Full EUDR |
“Full EUDR” means geolocation of every harvest plot, the harvest date or period, a risk assessment and a due diligence statement (DDS) before the goods enter the EU market. “EUTR” means the old Timber Regulation’s legality due diligence, without geolocation and without a DDS.
Whether a product is on the old EUTR list is decided by its customs code (CN code), not by how it looks. Check each code individually.
Four examples
1. A dining table made in 2026 from oak harvested in 2022, imported in March 2027. Wooden furniture is on the old EUTR list and the oak was harvested before 29 June 2023. The EUTR applies, not the EUDR. From 31 December 2029, the same table would need full EUDR compliance.
2. Wooden salad bowls made from wood harvested in 2021, imported in 2027. Kitchenware was never on the EUTR list and the wood predates 29 June 2023. Neither regulation applies, now or later.
3. Plywood made from logs harvested in September 2023, imported in January 2027. The wood is more than three years old, but it was harvested after 29 June 2023. Full EUDR applies, including plot geolocations and a DDS.
4. Paper produced in 2025 from wood harvested in 2024, already sold into the EU in 2025. The paper was placed on the EU market before 30 December 2026. The EUTR governed it then, and it needs no DDS when it is resold later.
EUDR role
Operator, trader or downstream operator? The EUDR Obligations Checker identifies your role and whether you must file a due diligence statement, in under two minutes and without sign-up.
What to prepare
- Proof of the harvest date. If you rely on wood being harvested before 29 June 2023, you must be able to show it. Ask suppliers for harvest or felling records, production records and invoices that tie your products to that wood.
- The harvest date counts, not the manufacturing date. A product made recently from older wood is assessed on when the wood was harvested.
- Mixed wood needs care. If a product combines wood harvested before and after 29 June 2023 and your supplier cannot clearly separate the two, treat the whole product as in scope.
- Stock already on the EU market stays outside the EUDR. Goods placed on the EU market before 30 December 2026 need no DDS, even when they are resold later. Keep the import documents as evidence.
- Start collecting geolocations now. For wood harvested from 29 June 2023, you will need plot geolocations from your suppliers for anything imported from 30 December 2026. The further back the harvest, the longer this can take.
- The EUDR covers the EU market only. This includes Northern Ireland. Goods imported into Great Britain fall under the UK Timber Regulations instead.
How Trusty EUDR Passport helps
Trusty EUDR Passport is EUDR software built for the people who manage supply chains, not only for compliance teams. You set up a product profile for each supply chain: the supplier, the product and the plots where the wood was harvested. You invite your suppliers to share their geolocation data directly in the platform, free of charge for them.
EUDR Passport then runs a risk assessment covering deforestation, indigenous peoples’ rights, supply chain complexity and country of origin. From the profile, you generate your due diligence statements and submit them to the EU Information System. The risk assessment costs €90 per product profile and is valid for one year. Every DDS is included, and setting up your account and inviting suppliers costs nothing.
Not sure which of your wood products are in scope? Check your EUDR obligations or book a walkthrough with our team.
This article reflects the rules as of November 2026 and is for general information only. It does not constitute legal advice. EUDR dates and guidance may change, so check the latest Commission guidance before acting.
Sources
- Regulation (EU) 2023/1115 on deforestation-free products (EUDR), as amended by Regulation (EU) 2025/2650 of December 2025
- European Commission, simplification package COM(2026) 191 (4 May 2026)
- EUSTAFOR: what the Commission’s 4 May 2026 simplification package means for wood
- Burges Salmon: EUDR amended on 23 December 2025
Frequently asked questions
It depends on the product. If the product was never on the old EUTR list, the EUDR does not apply to it, now or later. If it was on the EUTR list, the EUTR applies until 30 December 2029, and full EUDR rules apply from 31 December 2029.
The harvest date. A product made recently from older wood is assessed on when the wood was harvested.
If your supplier cannot clearly separate the two, treat the whole product as in scope of the EUDR.
No. Goods placed on the EU market before 30 December 2026 need no DDS, even when they are resold later. Keep the import documents as evidence.
It applies in Northern Ireland. Goods imported into Great Britain fall under the UK Timber Regulations instead.
30 DECEMBER 2026
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