EUDR for furniture importers: what importers and online retailers must settle for wooden furniture by 30 December 2026

Why furniture is a special case

Regulation (EU) 2023/1115 covers seven commodities. In hardly any product is the commodity as far removed from the finished article as in furniture. A wardrobe from Vietnam consists of particleboard, veneer, solid wood strips and a back panel, plus fittings, lacquer and packaging. The Regulation is interested only in the wood, but in every single piece of it: Which country does it come from, which plot, which tree species? And was forest cleared or degraded on that plot after 31 December 2020?

Then there is the way the sector works. Furniture importers and online furniture retailers have goods made to order, often in Asia, with lead times of six weeks and more. The article number stays the same on reorder, but the wood may well come from a different forest. Finished furniture and individual components are imported side by side, goods are sold to retailers and to consumers, returns come back, and part of the range goes to Switzerland. The Regulation has a separate answer for each of these situations. The guide for the timber industry describes the chain from the forest to the sawmill. This article adds the perspective of those who import and sell at the end of that chain.

The examples come from conversations we have had with furniture importers and furniture retailers over the past months. They are anonymised and generalised far enough that no company can be identified.

Which furniture falls under the EUDR

Since 18 September 2026, Annex I applies as amended by Delegated Regulation (EU) 2026/2102. For furniture, the new version has sharpened the entries and added three exemptions.

What the "ex" before the heading means

The "ex" before a heading means that only the part of the goods made of wood is covered. The Commission explains this in its FAQ using heading 9401 as the example. Seats of other materials run under the same code but do not fall under the Regulation. For seats, the new version goes one step further and lists only six subheadings, namely seats of wood or with a wooden frame. A chair with a metal frame and a plastic seat is classified under 9401 71 00 or 9401 79 00 and is therefore not in Annex I at all. No EUDR code is needed at customs for it. The customs declarant enters Y129 only when the code of the goods is listed in Annex I but the goods themselves contain no wood, for instance a plastic seat under 9401 80 00 or a rattan item under ex 9403 60. An upholstered armchair with a beech frame, by contrast, is covered. It has its own entry in Annex I.

What is not covered

There is no quantity or value threshold. The Commission's FAQ says expressly that the Regulation applies regardless of quantity and value. Only samples and specimens of negligible value are exempt.

Used and second-hand furniture is exempt under all furniture headings. The annex says so expressly, but it does not define what counts as used. Returns that go back into stock as new goods cannot rely on the exemption.

Bamboo, rattan, reed, rushes and willow do not count as wood within the meaning of the Regulation. A rattan chair is therefore not covered. If it has a wooden frame, only the frame counts.

Aircraft and vehicle seats have been removed in the new version because, according to the Commission's reasoning, they contain only small amounts of wood. Manufacturers of such seats are out with these products.

Packaging wood that only protects the goods does not fall under the Regulation. Cattle hides and leather are likewise no longer listed in Annex I since the new version. For a wooden piece of furniture with a leather cover, only the wood counts.

The deadline: for wooden furniture of heading 9403, 30 December 2026 applies to everyone

The Regulation applies from 30 December 2026. Anyone who was a natural person, a micro-enterprise or a small enterprise on 31 December 2024 gets six more months as an operator under Article 38(3), until 30 June 2027. This deferral does not apply, however, to products listed in the annex to Regulation (EU) No 995/2010, the old EU Timber Regulation (EUTR). And that annex lists wooden furniture of headings 9403 30 to 9403 60 and 9403 91. A small importer with a handful of employees who imports wooden cabinets and tables therefore has the same date as a corporate group.

For seats, ornaments and other wooden articles outside that annex, such a small operator has until June 2027. When importing these goods they enter code Y141 at customs. That works even if they import wooden furniture of heading 9403 alongside, for which the December date stands. The deferral is tied to the product, not to the company.

Downstream operators and traders get no deferral, whatever their size. That applies to the online retailer buying from a Polish manufacturer just as much as to the furniture store reselling goods from German manufacturers. If the same furniture store imports own brands from Indonesia, it is the operator for those goods and likewise has the December date for wooden furniture of heading 9403.

What happens to the goods in stock

For goods in the warehouse or on the ship at the turn of the year, the date of the first placing on the market is decisive. Wooden furniture of heading 9403 imported before 30 December 2026 remains subject to the Timber Regulation according to the Commission's guidelines of July 2026. Seats and other goods outside the EUTR annex from that period likewise do not fall under the EUDR according to the Commission's FAQ. In both cases no due diligence statement is needed. Anyone who documents their stock with the import date can sell it in 2027 without a statement. For wood harvested before 29 June 2023, the Timber Regulation even continues to apply until the end of 2029. The guide for the timber industry describes this distinction in detail.

Which role you have: per sourcing route, not per company

Amending Regulation (EU) 2025/2650 simplified the role model. The operator is whoever first places a relevant product on the market or exports it. For furniture, that is the importer. The downstream operator is whoever makes and sells something new from products already declared. The trader is whoever passes declared goods on unchanged. The duties follow the role, and the role follows the sourcing route. That is why a company often has several roles at once.

Importer and manufacturer in one

The Commission addresses the case in the second row expressly in version 5 of its FAQ. Anyone who imports a product and processes it in their own company into another relevant product is operator and first downstream operator at the same time. A manufacturer who imports wooden components from Asia and builds furniture from them submits the due diligence statement for the components at import. No further statement is needed. If the same company also trades in imported finished chairs that it resells unchanged, the first customer for those chairs receives the reference number. Both side by side is the normal case in furniture businesses.

A different idea comes up regularly in the conversations: a separate statement for every chair produced, a number with every sale, and on top of that batch tracking from the container to the finished piece. The Regulation does not ask for that. It asks only for documentation of the incoming goods, in other words which components were imported with which statement.

Drop-shipping from a third country

Another case concerns online retail. Any EU company that first makes goods of a third-country seller available on the Union market is deemed the operator under Article 7. That is true even if the company never had the goods in its hands. Direct deliveries from the manufacturer in the third country to the consumer are therefore no way around the duty for the selling EU company. Only a pure marketplace that neither sells nor delivers itself stays outside. Consumers have no obligations.

What the due diligence statement contains for furniture

The statement in the Information System is, in the end, just a form with a few fields. The effort lies in the information under Article 9 behind it.

Wood species and quantity

Alongside the customs tariff code, a description of the product has to be given, with the trade name and the scientific name of the wood. For products containing wood, Article 9 requires "the common name of the species and their full scientific name". A piece of furniture of rubberwood with a plywood back of poplar has two species, a solid wood piece with an oak front and a pine carcass likewise. "Hardwood" or "teak" is not enough. The Information System uses the names from the EPPO database, so for instance Tectona grandis or Hevea brasiliensis. According to the Commission's FAQ, the scientific name is mandatory for all products that contain wood. The quantity is stated in kilograms of net mass, so without packaging. If the Combined Nomenclature provides a supplementary unit for the code, that is added.

Country of production and plots

The country of production is the country in which the wood was harvested. A wardrobe from a Vietnamese factory made with wood from Brazil has Brazil as its country of production, with all the consequences for the country risk.

Then come the harvest period and the coordinates of all plots on which the wood was harvested, with at least six decimal places and as a polygon for plots above four hectares. For a composite piece of furniture these are the plots of all wood components. The Commission's FAQ names "imported wooden furniture with different wood components" expressly. Referring to someone else's statement instead of stating your own geodata is no longer provided for since the amendment of December 2025. Whoever submits a statement as an operator names all plots themselves. If a piece of furniture contains wood from a plot deforested after the cut-off date, the whole piece cannot be sold.

Suppliers, customers, evidence

Finally, the records must include the name, address and email address of all suppliers, the downstream operators and traders supplied, the legality evidence from the country of production and the evidence that the products are deforestation-free. All records have to be kept for five years.

For particleboard and MDF with recycled chips there is no clear answer from the Commission. Only products made entirely of material at the end of its life cycle are exempt. For recycled paper the FAQ says that the non-recycled share has to be traced back to the plot. By the same logic the same applies to boards with mixed chips. Anyone importing such boards from third countries should be able to document the virgin wood share with plots.

Geodata from Asia: what suppliers can deliver

For importers, geolocation is the part that takes the most preparation. That has less to do with the technology than with the supply chain. From the conversations we know three starting positions above all.

Plantation wood with data per shipment

A manufacturer sources wooden components from plantations in Asia, with a framework order for the year and call-offs per load. The supplier keeps a wood book showing which timber went into which product. The coordinates of the harvest plots, however, are only available once the load has been put together. So the supplier cannot report "all plots" in advance. The importer therefore checks each delivery, and the statement has to be in the Information System before the customs declaration, in other words during the weeks the container is at sea.

Made to order with an unchanged article number

An online retailer has own brands made in Asia. The order triggers production, and on reorder the wood may come from a different forest. Under the Timber Regulation the retailer carried out one assessment per article per year. Under the EUDR they must renew it as soon as there are indications of a different origin, and review the risk assessment at least once a year. In practice that means: they check each order and use the order number to keep the deliveries apart towards the supplier.

Smallholders without coordinates

From some countries of origin the documents arrive handwritten, and some suppliers do not know exactly where their wood comes from. There only one thing helps: the supplier draws their plots on a map and documents legality with the papers of the country of production. The guide for the timber industry reckons with eight to twelve weeks for overseas suppliers until polygons, species names and documents are in.

The typical errors

The errors in the data are always the same: polygons that show the whole concession instead of the harvest plot. Trade names instead of botanical species names. Harvest periods that do not match the delivery date. Coordinates in the wrong country. Anyone who compares the data with satellite imagery and checks it for plausibility before submission finds these errors before they end up in the statement.

A large retailer has built in an organisational safeguard: its import forwarder only books the container once the reference number is available. The suppliers know it. That way no goods are supposed to get stuck at customs from 30 December 2026.

Country risk: the country of production of the wood decides

Implementing Regulation (EU) 2025/1093 of 22 May 2025 classifies the countries. For furniture importers the picture looks like this:

If the veneer of a piece of furniture made in Vietnam comes from Indonesia, full due diligence applies to that piece. And even simplified due diligence does not release you from geolocation. Geodata, species names and legality evidence remain mandatory, only the assessment is dropped.

Certificates help to demonstrate legality. Freedom from deforestation is checked at the plot. FSC and PEFC show that individual legal requirements have been met and are an aid for the risk assessment, no more. FLEGT licences, currently only from Indonesia, count as evidence of legality under Article 10(3).

One statement for many deliveries

Nobody has to submit a separate statement for every container. According to the Commission's FAQ, a due diligence statement can cover several shipments and batches of different products as long as the declared quantity lasts. Once it has been used up by imports, the operator needs a new statement. Because the due diligence system has to be reviewed annually, a statement should only cover deliveries within one year of its submission. The trees must already have been harvested at submission, the furniture need not yet have been made. The FAQ gives exactly this example for wooden furniture. The same product may not appear in several statements of the same operator, and the quantities must match the actual imports.

For an importer with fixed suppliers and a framework order this means one statement per supplier with the annual quantity, the same reference number in every customs declaration of the year, and an eye on the remaining quantity before the next load is shipped. For the retailer who has goods made to order and whose wood comes from changing forests, the annual statement only works if the supplier's plots stay the same. Otherwise it remains one statement per order.

Customs: reference number, codes and the condition that stops the container

From 30 December 2026 the customs declarant must make the reference number of the due diligence statement available before release for free circulation. That is what Article 26(4) requires. In practice the import declaration carries document code C716 with the reference number. If both are missing and no exemption applies, import is not permitted under TARIC condition B090. Declarations use ten-digit TARIC codes. Anyone who has compared their range with Annex I using only the four-digit heading gets wrong results for seats, because there the eight-digit subheading decides.

Which code belongs to which role and how it is entered in the German customs system ATLAS is explained in the glossary of EUDR TARIC codes. What to watch out for with DHL, UPS and FedEx shipments is in our guide to the reference number for courier shipments.

When the importer delivers to retailers and processors in Germany or the EU, it passes the reference number on: on the invoice, on the delivery note or by email, the form is free. No reference number has to be passed on to consumers.

Controls: what the BLE wants to see from furniture importers

In Germany the Federal Office for Agriculture and Food, the BLE for short, is responsible for importers, manufacturers and traders and works together with customs. Anyone who was checked as a furniture importer under the Timber Regulation knows the method: the document chain is traced step by step, the quantities must be plausible from one stage to the next, the botanical name must be consistent throughout. Where the origin is suspicious, a laboratory identification of the wood species is added, through wood anatomy, DNA and isotopes, for instance when oak is delivered via China and might really originate from Russia.

Under the EUDR the focus shifts. At the centre is no longer the invoice chain back to the origin but the plot: Where was the wood harvested, and was forest converted or degraded there after 2020? The authority compares the declared plots with satellite imagery. The risk of mixing and the complexity of the supply chain remain risk factors, and the legality evidence from the country of production is still required. Anyone who has set their suppliers up for a complete document chain under the Timber Regulation does not have to give any of that up. They additionally obtain the geodata and the evidence of freedom from deforestation.

The Regulation itself sets the control rates. For low risk, at least one per cent of operators are checked each year, plus one per cent of the downstream operators and traders that are not SMEs. For standard risk it is three per cent, for high risk nine per cent, and there additionally nine per cent of the quantity. The draft of the German implementing act (Bundestag printed paper 21/8278) provides for fines of up to 100,000 euros, for legal persons above a turnover threshold up to four per cent of total turnover. Confiscation of the goods and sales bans of up to one year come on top. The Regulation itself requires Member States to set a fine range that reaches at least four per cent of EU-wide annual turnover. What the act regulates in detail and how the controls run is in the article on enforcement and penalties.

Roadmap to 30 December 2026 for furniture importers

Now: classify the range. Compare every article with the new Annex I using its ten-digit customs tariff code, the eight-digit code for seats. Then mark what is listed in the annex to the Timber Regulation and what is not. Cabinets, tables, beds and kitchens of heading 9403: 30 December 2026 for everyone. Seats: deferral possible for small operators.

Now: set the roles per sourcing route. Import of finished goods, import of components with own production, purchase in the EU, own use, returns, export. For each of these routes, take the duty from the table above.

October: write to suppliers. Per supplier and article: country of production of the wood, scientific species names, polygons of the harvest plots, harvest period, legality documents. Overseas suppliers need eight to twelve weeks. Ask EU suppliers about their role and agree how the reference numbers will be passed on.

October: apply for access to the Information System. Non-SMEs register even if they are only downstream operators or traders.

November: country risk and processes. Classify the country of production per supplier and, for standard risk, document the risk assessment. Put the due diligence system under Article 12 in writing. Record stock with the import date so that existing stock and new goods can be kept apart. Submit test statements.

December: first statements with lead time. For the containers arriving after 30 December, submit the statement as soon as the load has been put together. Brief the customs broker on C716 and the reference number and agree the rule "no container without a number" with the forwarder. Add the reference numbers for retailers and processors to invoices and delivery notes.

Seven misconceptions from the furniture sector

"We buy in Poland, so we have to submit a due diligence statement." No. Anyone who buys in the EU from a manufacturer or importer is downstream and keeps that supplier's reference numbers.

"We need a separate statement for every chair we produce." No. Anyone who processes imported parts themselves submits the due diligence statement for the parts at import. For the finished furniture, no statement is needed and no number has to be passed on to the customer.

"As a small importer we have until June 2027." Only for seats and for wooden articles that are not listed in the annex to the Timber Regulation. For cabinets, tables, beds and kitchens of heading 9403, 30 December 2026 applies.

"Our manufacturer is in Vietnam, a low-risk country." What counts is the country in which the wood was harvested. If the piece contains veneer from Indonesia, full due diligence as for standard risk applies to the whole piece.

"Teak is enough as the wood species." No. What is required is the full scientific name of every species, for teak Tectona grandis, and that for every wood component.

"We are FSC certified, so the EUDR is dealt with." Certificates only show that certain legal requirements have been met. Freedom from deforestation is checked at the plots, and statement and responsibility remain with the importer.

"The goods in the warehouse need a statement from January." Whatever was imported before 30 December 2026 does not fall under the EUDR. Documenting the import date is enough.

How Polygon One supports furniture importers

For wood and furniture, Polygon One records the customs tariff codes of chapters 44, 47, 48 and 94, the species information, the geodata of the harvest plots and the reference numbers of upstream statements. Suppliers enter their plots through a portal without a login of their own, as coordinates, polygons or GeoJSON, or they draw them directly on the map. Every plot is checked using satellite imagery for deforestation after 31 December 2020, and the country risk follows Implementing Regulation (EU) 2025/1093 on country benchmarking. The role is kept per article and supplier. So for every sourcing route it is visible whether a statement of your own is needed or only the supplier's reference number has to be recorded. Due diligence statements are transmitted to the Information System through the interface, on request as one statement for a year's deliveries with the remaining quantity updated per order. The reference number is then assigned to the order. For downstream operators and traders, Polygon One stores the reference and verification numbers per delivery and exports the information when the authorities ask for it. A compliance report per supplier and product documents the geo analysis, the risk assessment and the risk mitigation under Articles 9 to 11 in case of a control.

What the software does not do: determine your role legally, judge the legality of a harvest or sign the assurance in the statement. If you would like to see how your range with its sourcing routes looks in this structure, book a demo or read on at the product page for the EUDR module.

Download: EUDR checklist for furniture importers

Two pages for purchasing, customs and management: the headings with their deadline, the role table per sourcing route, the entries of the statement for furniture, the customs codes and the roadmap.

• Download: EUDR checklist for furniture importers (PDF)

Frequently asked questions

From when does the EUDR apply to furniture importers?

From 30 December 2026. For wooden furniture of heading 9403, that is cabinets, tables, beds, kitchens and furniture parts of wood, the date applies to every company size, because these headings are listed in the annex to the old Timber Regulation. Only for seats and wooden articles outside that annex do operators that were micro or small enterprises on 31 December 2024 have until 30 June 2027.

Which furniture falls under the EUDR?

Furniture of wood of headings 9403 30 to 9403 60 and furniture parts of wood (9403 91), prefabricated buildings of wood (9406 10) and wooden articles of headings 4418, 4420 and 4421. For seats, only six subheadings are listed: 9401 31 00, 9401 41 00, 9401 61 00, 9401 69 00, 9401 80 00 and 9401 91 90. All entries apply only insofar as the goods consist of wood. Used and second-hand furniture, furniture of bamboo and rattan and aircraft and vehicle seats are exempt.

Are seats with metal frames covered?

No. For seats, Annex I lists only six subheadings of wood or with wooden frames. A chair with a metal frame is classified under 9401 71 00 or 9401 79 00 and is not listed in Annex I. No EUDR code is needed at customs for it.

Do I have to submit a due diligence statement if I buy furniture from a manufacturer in the EU?

No. The statement has already been submitted by the manufacturer or importer who first placed the product on the market. You are a downstream operator or trader and record your suppliers, your customers in the supply chain and the reference numbers your supplier gives you. You keep these records for five years. If you are not an SME, you also register in the Information System.

I import components and make furniture from them. Do I have to give my customers a reference number?

No. For the components you are the operator and submit the due diligence statement at import. For the finished furniture you are at the same time the first downstream operator. The Commission makes clear in its FAQ that the reference number does not have to be passed on to customers in this case. You keep the reference numbers of your imports for five years.

Which wood species do I have to state?

The common name and the full scientific name of every wood species in the piece of furniture, for instance Tectona grandis for teak or Hevea brasiliensis for rubberwood. The Information System uses the EPPO database. For plywood, veneer and furniture made of several woods there are several names.

Can one due diligence statement cover a whole year?

Yes. A statement can cover several shipments of different products until the declared quantity is used up, and should not cover a period of more than a year from submission. The trees must already have been harvested at submission. The furniture need not yet have been made. The same reference number may appear in several customs declarations.

Can my customs broker submit the due diligence statement for me?

Yes, as an authorised representative under Article 6. Operators may mandate an authorised representative to submit the due diligence statement on their behalf. Responsibility for the furniture being deforestation-free and legally produced remains with the importer. The authorised representative must provide the authority with a copy of the mandate on request.

What country risk do China, Vietnam and Indonesia have?

China, Vietnam, India and Thailand are low-risk countries. Indonesia, Malaysia and Brazil have standard risk. What matters is the country in which the wood was harvested, not the country in which the furniture was made.

What applies to returns from Switzerland?

Anyone who re-imports a piece of furniture exported earlier and can document the earlier placing on the market counts as a downstream operator and needs no new statement. The customs declaration carries code C720 or C725 and the reference number of the original statement. Without evidence the goods count as a first import.

Are used furniture and B-grade goods covered?

Used and second-hand furniture is exempt under all furniture headings, at customs with code Y133. B-grade goods, that is new goods with defects or from returns, remain new goods and are covered. What counts as used the Regulation does not define. Anyone selling as-new returns again as new goods should not rely on the exemption.

How do furniture importers automate EUDR due diligence?

First compare the customs tariff codes of the range with the new Annex I, then set the role per sourcing route. Then collect geodata, species names and legality evidence per supplier and submit the statements with lead time before the customs declaration. With stable suppliers one statement for the whole year is enough. Software such as Polygon One maps these steps. Suppliers enter their plots without a login of their own, the plots are checked using satellite imagery for deforestation after the cut-off date of 31 December 2020, and the country risk follows the benchmarking regulation. The statements go to the Information System, and the reference numbers are ready per delivery for customs and controls.

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Articles 1, 2, 4 to 7, 9 to 13, 26, 29, 37 and 38, Annex I as amended by Delegated Regulation (EU) 2026/2102 and Annex II. Regulation (EU) No 995/2010, Annex. Implementing Regulation (EU) 2025/1093 (country benchmarking). Commission guidelines, OJ C/2026/3896 of 20 July 2026. Commission FAQ on the EUDR, version 5 (April 2026, revised 21 August 2026), questions 1.3, 2.2, 2.3, 2.8, 2.10, 2.12, 3.6.1, 3.8, 3.9, 3.18, 3.19, 5.4, 5.6.1, 5.19, 5.20, 7.21, 7.22, 7.27, 9.2. Commission TARIC document on the EUDR, revision 1 of 23 September 2026. Draft act of the German Federal Government, Bundestag printed paper 21/8278 of 30 September 2026. As at 14 October 2026. This article is not legal advice.

Photos: Salah Ait Mokhtar, Spencer Plouzek, Julian Hochgesang, Khang Nguyen, CHUTTERSNAP, all via Unsplash.