Timber Industry and Customs in 2026: What the EUDR Changes for Your Imports

Between 1990 and 2020, the world lost 420 million hectares of forests, an area larger than the European Union itself. In response to this reality, the EU adopted Regulation (EU) 2023/1115 on deforestation and forest degradation, better known as the EUDR. For players in the timber sector - freight forwarders, carriers and industrialists - this text marks a turning point. The December 30, 2026 deadline is approaching and with it, new customs obligations that will fundamentally change your import-export operations.

The EUDR, a European regulation that redefines the rules of the game

The EUDR is part of the European Green Deal and goes well beyond the former EU Timber Regulation (EUTR). Where the EUTR was limited to combating illegal logging, the new regulation aims at the eradication of deforestation linked to European trade.

The principle is clear: it is now forbidden to place on the EU market or export from it products that have contributed to deforestation or forest degradation after December 31, 2020. This reference date is the cornerstone of the system.

The regulation imposes a dual requirement for each concerned product. On one hand, it must be "deforestation-free", meaning that no area of forest was cleared to produce it after the cut-off date. On the other hand, it must have been produced in compliance with the legislation in force in the country of production. These two conditions are cumulative: one without the other is not sufficient to guarantee compliance.

Which timber sector products are covered?

The EUDR targets seven raw materials responsible for a significant share of global deforestation:

• Beef
• Cocoa
• Coffee
• Palm oil
• Rubber
• Soy
• Timber

For professionals in the timber sector, attention must be paid not only to timber itself but also, and above all, to all derivative products listed in Annex I of the regulation.

Timber derivative products subject to the regulation

Annex I of the EUDR casts a wide net. Beyond raw timber, it includes products that many operators do not yet suspect: wooden furniture, printed paper, brochures, plywood, charcoal, wood pulp, wood packaging and pallets. Each product is identified by its combined nomenclature code (NC code), which allows precise verification of whether a product is subject to the EUDR during customs declaration.

If you import notebooks, printed catalogs or furniture containing wood, you are concerned in the same way as a log trader. This extended scope to derivative products is one of the most underestimated aspects of the regulation.

Who must comply with the EUDR in the logistics chain?

The regulation distinguishes between two categories of operators, and this distinction is decisive for the level of responsibility.

The operator is any natural or legal person who, for the first time, places a concerned product on the EU market or exports it. They bear the initial and heaviest burden in terms of due diligence. The trader, for their part, refers to any player in the supply chain who makes concerned products available on the market, downstream of the operator.

A point not to be overlooked: traders who are not SMEs bear due diligence obligations similar to those of operators. For large companies, whether freight forwarders, industrialists or distributors, the responsibility is therefore almost systematically full and complete, regardless of their position in the chain.

On the timeline front, large and medium-sized companies must be compliant by December 30, 2026. Micro and small enterprises benefit from an additional deadline until June 30, 2027, in accordance with Regulation (EU) 2025/2650.

Due diligence at the heart of new customs obligations

The due diligence system is the central mechanism of the EUDR. It transforms the political objective of combating deforestation into operational actions for each company. This process is broken down into three mandatory steps.

The first consists of collecting exhaustive information about the product, the supplier and the country of production. The most critical requirement is obtaining geolocation coordinates of all production plots. For plots larger than four hectares, it is not just a GPS point but polygons delimiting the precise perimeter of each plot. In the timber sector, where supply chains sometimes span several continents, this requirement represents a major logistical challenge, especially as forestry operators often consider this data commercially sensitive.

The second step concerns risk assessment. The information collected is analyzed to determine whether the product presents a risk of non-compliance, however minimal. Specific criteria come into play: the prevalence of corruption in the country of origin, the complexity of the supply chain or the presence of indigenous peoples and respect for their rights.

The third step, risk mitigation, is required as soon as the identified risk is not considered zero or negligible. The company must then implement corrective measures before any market placement. If these measures fail to bring the risk to an acceptable level, the product is simply prohibited from accessing the European market.

Records of all due diligence declarations must be kept for five years. The due diligence system must also be reviewed annually by operators and non-SME traders.

The Due Diligence Declaration (DDD) and customs clearance

The link between the EUDR and customs clearance operations is direct. Before any market placement or export of a product listed in Annex I, the company must file a Due Diligence Declaration (DDD) in the European information system TRACES-NT. This declaration generates a reference number that becomes indispensable for customs clearance.

In the customs declaration, this number must be entered with the document code C716, in the following format: C716 followed by the DDD reference number. Without this number, customs clearance is not possible. Compliance with the EUDR thus becomes a non-negotiable condition for access to the European market, just like traditional customs documents.

Sanctions and roadmap to anticipate the deadline

Non-compliance exposes companies to fines representing at least 4% of annual total turnover in the European Union. This threshold is a floor, not a ceiling. Additional sanctions include confiscation of goods and temporary exclusion from public procurement.

To prepare in the best conditions, several priority actions deserve to be undertaken now:

• Map all your supply chains to identify all products and raw materials covered by the EUDR
• Engage in dialogue with your direct and indirect suppliers to prepare the systematic collection of geolocation data
• Assess and implement the necessary systems and technologies (satellite monitoring, traceability tools, permanent digital infrastructure)
• Anticipate your first due diligence declarations via TRACES-NT to run in your processes before the deadline

The EUDR represents a major traceability challenge for the timber sector, but it also constitutes an opportunity to strengthen the resilience and transparency of your value chains. With the DDD reference number becoming a mandatory element of each customs declaration, having a customs clearance platform capable of integrating these new requirements will be a decisive operational advantage. Customeo, Derudder's digital customs clearance platform, already centralizes all your customs operations (import, export, transit) with complete traceability of documents and real-time statuses, across more than 150 customs offices in France and Europe.