Understanding the EUDR Impact for US Wood Product Suppliers
- Joe H
- Apr 4
- 5 min read
The European Union has enacted a significant piece of legislation, the EU Deforestation-free Regulation (EUDR - Regulation (EU) 2023/1115), 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 starting December 30, 2025, for most companies (with an extension to June 30, 2026 for qualifying micro/small enterprises), the time to prepare is now.
Note: The EUDR went into effect as law on 29 June 2023. Compliance enforcement originally was set for December 30, 2024, but was pushed back to 2025. During the process of approving the delay, proposals for more substantive changes, such as adding a "no-risk" country category that could potentially exempt countries like the US, were ultimately rejected by the EU institutions. Industry groups, including some with significant US connections (like members of the European Coffee Federation such as Starbucks), continue to lobby regarding the regulation, with some hoping for further weakening or ways to evade the requirements.
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 effect 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. Therefore, evaluating the impact of EUDR on operations is essential for all involved.
Why EUDR Impacts Suppliers: Your Role in the Due Diligence Statement
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. This 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).
Often, the operator does not have direct access to this origin information. Data like plot geolocation, harvest dates, and primary evidence of legal harvesting rights typically originate with the forest manager or landowner and subsequent processors (like sawmills).
This necessitates an unbroken chain of traceability. Suppliers at every stage must accurately collect, maintain, and transmit this critical origin information to the next company in the chain, ultimately enabling the operator to compile a valid DDS. Without this verifiable data flow from suppliers, compliance is impossible.
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: Means the timber must come from land that was not converted from forest to agricultural use after December 31, 2020.
Forest Degradation (for Wood): Means the timber must have been harvested without inducing forest degradation after December 31, 2020. Forest degradation specifically refers to structural changes like converting primary forests or naturally regenerating forests into plantation forests or other wooded land, or converting primary forests into planted 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:
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 products entering the EU market. For any company involved in harvesting, processing, or manufacturing wood-based products, it is now critical to evaluate whether your products, or products containing your materials, might ultimately reach the EU. Understanding your role in the supply chain and preparing to provide the necessary verifiable data – particularly plot-level geolocation and proof of legality – to your customers is essential. Until the compliance enforcement date of 30 December 2025, modifications and changes can still occur affecting the ultimate form of EUDR and how it impacts wood product suppliers. Failing to prepare and enable compliance could jeopardize your company's valuable position as a link within EU-bound supply chains.
For more information on EUDR:
Official EUDR webpage:
EUDR Regulation:
Questions on Blackberry Pallet and EUDR or for ISPM 15 certified Pallets for shipping your goods to the EU and beyond
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