Introduction

The EU Deforestation Regulation, known as EUDR, is designed to make sure that products linked to key commodities are not connected to deforestation or forest degradation. For companies working with wood, furniture, paper, rubber, leather, cocoa, coffee, palm oil or soy, this regulation can directly affect supplier data, customs readiness, product traceability and customer expectations.

This guide explains what EUDR is, the current laws and dates, who is affected, what evidence is needed, what a DDS reference number means, and how a business can prepare step by step.

What is EUDR?

EUDR stands for the EU Deforestation Regulation. The main law is Regulation EU 2023 1115 on deforestation free products.

The regulation requires relevant products placed on the EU market, made available on the EU market, or exported from the EU to meet three core conditions.

  1. The product must be deforestation free.
  2. The product must be produced in line with the relevant laws of the country of production.
  3. The product must be covered by a Due Diligence Statement or, where applicable, a simplified declaration.

You can read the official European Commission EUDR page here: European Commission EUDR page

You can also read the official legal text here: Regulation EU 2023 1115 on EUR Lex

Which commodities are covered by EUDR?

EUDR covers seven main commodity groups.

  1. Cattle
  2. Cocoa
  3. Coffee
  4. Palm oil
  5. Rubber
  6. Soy
  7. Wood

It also covers certain products made from these commodities. For example, wood products can include timber, paper, panels and some furniture products. For a furniture business, the main EUDR risk is usually wood and wood based materials.

The product scope is linked to Annex I of the regulation and the relevant HS codes. This is why HS code checking is one of the first steps in EUDR compliance.

You can check the official EUDR implementation resources here: European Commission EUDR implementation resources

Current EUDR dates

The EUDR entered into force on 29 June 2023. However, the main application dates have been postponed.

The current dates are:

Business categoryCurrent EUDR application dateLarge and medium operators30 December 2026Micro and small operators30 June 2027Micro and small operators already covered by the EU Timber Regulation30 December 2026

The European Commission states that the regulation was amended in December 2024 and December 2025 to introduce simplification measures and reduce administrative burden.

You can read the official date update here: European Commission EUDR legislation and dates

The EU Access2Markets update also explains the further postponement to December 2026 and the changes introduced by Regulation EU 2025 2650: Access2Markets EUDR delay and updates

What changed with the recent simplifications?

The simplification changes do not remove EUDR. They mainly reduce repeated administrative work across the supply chain.

The key point is that the first operator who places the relevant product on the EU market or exports it from the EU is normally responsible for the full Due Diligence Statement.

Downstream operators and traders may not always need to submit a new DDS again for the same product, provided the product is already covered by an upstream DDS or simplified declaration. Instead, they may need to collect, keep and share the DDS reference number or declaration identifier where relevant.

In simple terms:

  1. The first operator completes the full due diligence.
  2. The first operator submits the DDS in the EUDR Information System.
  3. A DDS reference number is generated.
  4. That DDS reference number can be passed through the supply chain.
  5. Downstream businesses must keep traceability records and confirm the DDS applies to the product or shipment.

This is important because businesses should not assume every supplier or reseller needs to submit a new DDS every time. The correct process depends on the business role in the supply chain.

What is a DDS?

DDS means Due Diligence Statement.

A DDS is the formal EUDR statement submitted through the EU Information System, also known as TRACES NT. It shows that the operator has collected the required information, assessed the risk, and confirmed that the product is deforestation free and legally produced.

For imports, the DDS reference number or simplified declaration identifier must be available before the customs declaration is lodged.

You can read the European Commission due diligence guidance here: Understand EUDR due diligence

What is a DDS reference number?

A DDS reference number is the number generated when a Due Diligence Statement is submitted in the EUDR Information System.

This number is important because it links the product or shipment to the due diligence record. It can be used for customs, downstream buyers, internal records and audit evidence.

If an upstream supplier has already submitted the DDS, a downstream buyer may need to collect and retain the DDS reference number and evidence showing that the reference number applies to the exact product, batch or shipment.

You can read more about the EUDR Information System here: EUDR Information System

Who needs to comply with EUDR?

The main responsibility sits with operators and traders involved in placing covered products on the EU market or exporting them from the EU.

A non EU supplier may not have a direct EUDR legal obligation unless it places products on the EU market. However, it may still be asked to provide data to help an EU based customer comply.

For example, a furniture supplier outside the EU may be asked to provide:

  1. Wood species
  2. Scientific name
  3. Country of harvest
  4. Geolocation of the harvest plot
  5. Legal harvest documents
  6. Chain of custody evidence
  7. Supplier declarations
  8. Existing DDS reference number if available

This means EUDR can affect businesses outside the EU through customer and supply chain requests.

Mandatory EUDR evidence

There is no single fixed document that works for every country and every supplier. The evidence must be clear, verifiable and strong enough to prove compliance.

For wood and furniture supply chains, the core evidence normally includes the following.

Product evidence

  1. Product name
  2. Product description
  3. SKU or product code
  4. HS code
  5. Wood product type
  6. Material composition
  7. Virgin wood, recycled wood or mixed wood status

Wood species evidence

  1. Common wood species name
  2. Full scientific name
  3. Trade name if used
  4. Confirmation whether the material is solid wood, veneer, plywood, MDF, particle board or another wood based material

Origin evidence

  1. Country of harvest
  2. Region of harvest
  3. Forest or plantation source
  4. Harvest area or concession details
  5. Sawmill or timber processor information where available

Geolocation evidence

  1. GPS coordinates
  2. Polygon boundaries where required
  3. GeoJSON file if available
  4. Map reference
  5. Evidence that the geolocation links to the supplied wood batch
  6. Evidence that the location is the harvest area and not only the factory address

Legal harvest evidence

  1. Harvest permit
  2. Forest management document
  3. Land use rights evidence
  4. Concession evidence
  5. Transport documents
  6. Export or customs documents where relevant
  7. Supplier legal declaration

Deforestation free evidence

  1. Supplier declaration that wood is deforestation free after 31 December 2020
  2. Map or satellite check if available
  3. Forest management evidence
  4. Confirmation that the harvest location is not linked to deforestation or forest degradation after 31 December 2020

Chain of custody evidence

  1. Purchase order
  2. Invoice
  3. Delivery note
  4. Transport record
  5. Batch record
  6. Processing record
  7. Supplier traceability statement
  8. Evidence linking wood origin to the final product

Certification evidence

FSC or PEFC certification can support the risk assessment. However, certification does not replace EUDR due diligence. It also does not replace geolocation, legal harvest evidence, risk assessment or DDS submission where DDS is required.

EUDR step by step process

The EUDR compliance process should be treated as a complete supply chain evidence process, not only as form filling.

Step 1: Create a product register

Start by listing all relevant products.

For each product, record the product name, SKU, HS code, supplier name, manufacturer name, material composition, country of manufacture and whether the product contains wood or another EUDR relevant commodity.

Step 2: Confirm if the product is in scope

Check whether the product is listed under EUDR Annex I and whether the HS code is covered.

If the product is not in scope, record the reason and keep the evidence.

If the product is in scope, continue to supplier mapping.

Step 3: Confirm your role

Before collecting everything, confirm whether your business is the first operator or a downstream business.

Ask:

  1. Are we importing this product into the EU?
  2. Are we first placing this product on the EU market?
  3. Are we exporting this product from the EU?
  4. Are we only buying a product that is already covered by an upstream DDS?

If your business is the first operator, full due diligence and DDS submission are likely required.

If your business is downstream, check whether the upstream supplier has already provided a valid DDS reference number.

Step 4: Map the supplier chain

For wood products, do not stop at the direct supplier.

Map the chain from product to source.

  1. Direct supplier
  2. Furniture manufacturer
  3. Component supplier if relevant
  4. Sawmill or timber processor
  5. Forest owner or plantation source
  6. Country and region of harvest

The objective is to trace the wood back to the harvest origin.

Step 5: Send a supplier evidence request

Send a structured EUDR questionnaire to the supplier.

Request product details, wood species, scientific name, country of harvest, geolocation, legal harvest evidence, chain of custody documents, quantity, batch reference, supplier declaration and existing DDS reference number if available.

Step 6: Check evidence completeness

Review whether the evidence is complete enough for risk assessment and DDS preparation.

Check if:

  1. The wood species is clear.
  2. The scientific name is provided.
  3. The country of harvest is known.
  4. The geolocation is usable.
  5. The legal harvest evidence is available.
  6. The chain of custody is clear.
  7. The product or shipment links to the evidence.
  8. The supplier declaration is signed.

If evidence is missing, request corrections before moving forward.

Step 7: Validate geolocation

Geolocation is one of the most important parts of EUDR.

Check that the coordinates or polygon refer to the actual harvest location. The geolocation should not only be the furniture factory address or supplier office address.

If the product includes wood from multiple plots, the relevant geolocation evidence should cover those plots.

Step 8: Validate legal production

Check whether the wood was harvested legally under the laws of the country of production.

This may include forest rights, harvest permits, land use rights, concession records, transport documents, export evidence and supplier declarations.

The level of detail may depend on the country, region, supplier risk and supply chain complexity.

Step 9: Carry out risk assessment

The business must assess whether there is a risk that the product is not compliant.

Risk factors can include:

  1. Country risk
  2. Region risk
  3. Wood species risk
  4. Deforestation risk
  5. Supplier reliability
  6. Document quality
  7. Supply chain complexity
  8. Risk of mixing with unknown origin wood
  9. Legal compliance risk
  10. Previous supplier issues

If the risk is not negligible, mitigation is needed.

Step 10: Apply mitigation where needed

Risk mitigation can include asking for extra documents, corrected geolocation, stronger legal evidence, additional supplier declarations, external checks, independent audits or management approval.

If the risk cannot be reduced to an acceptable level, the product should not be placed on the EU market or exported.

Step 11: Prepare DDS data

Once the evidence is complete and the risk conclusion is acceptable, prepare the DDS information.

This usually includes:

  1. Operator details
  2. Product description
  3. HS code
  4. Wood species
  5. Scientific name
  6. Country of harvest
  7. Quantity, weight or volume
  8. Supplier details
  9. Geolocation data
  10. Legal production confirmation
  11. Deforestation free confirmation
  12. Risk assessment conclusion
  13. Mitigation actions where used

Step 12: Submit through TRACES NT

The DDS is submitted through the EUDR Information System.

The operator creates the statement, enters product information, uploads or enters geolocation data, reviews the submission and submits it.

After submission, the system generates the DDS reference number.

Step 13: Store records for 5 years

EUDR records should be kept for at least 5 years.

The audit file should include product data, supplier questionnaires, declarations, geolocation files, legal harvest documents, chain of custody records, risk assessment, mitigation evidence, DDS reference number, TRACES submission record and supplier communications.

Step 14: Monitor suppliers continuously

EUDR compliance is not a one time task.

Repeat checks when there is a new supplier, new product, new wood species, changed source, expired certificate, new shipment, changed country of harvest, new risk information or regulatory update.

Practical process for wood furniture suppliers

For a wood furniture supplier, the practical workflow is:

  1. Identify the wood product.
  2. Check the HS code.
  3. Confirm whether the product is in EUDR scope.
  4. Confirm if you are the first operator or downstream buyer.
  5. If downstream, collect the upstream DDS reference number.
  6. If first operator, collect full supplier evidence.
  7. Trace the wood back to harvest origin.
  8. Collect geolocation and legal harvest evidence.
  9. Review FSC or PEFC as supporting evidence only.
  10. Carry out risk assessment.
  11. Apply mitigation if risk is not negligible.
  12. Prepare DDS data.
  13. Submit DDS through TRACES NT.
  14. Receive DDS reference number.
  15. Store the full audit file for 5 years.

Common EUDR mistakes to avoid

Mistake 1: Thinking certification alone is enough

FSC or PEFC can help, but it does not replace EUDR due diligence.

Mistake 2: Collecting only the factory address

EUDR requires the harvest location, not only the supplier or factory address.

Mistake 3: Forgetting the HS code

The HS code helps confirm whether the product is in scope.

Mistake 4: Treating EUDR as only a customs issue

EUDR is a supply chain evidence issue. Customs readiness is only one part of the process.

Mistake 5: Not checking the DDS link

If a supplier provides a DDS reference number, the buyer should still confirm that the number applies to the correct product, batch or shipment.

Conclusion

EUDR compliance is about proving that covered products are traceable, legally produced and deforestation free.

For wood and furniture supply chains, the most important work is supplier mapping, wood species identification, geolocation collection, legal harvest evidence, risk assessment and DDS readiness.

The current dates give businesses more time, but the process can take months because supplier evidence is often incomplete. Companies that start early will be in a stronger position with EU customers, customs processes and audit readiness.

For businesses working with wood products, the best starting point is simple:

Create a product register, identify in scope products, map suppliers, collect evidence, assess risk and prepare for DDS submission.

Frequently asked questions

What does EUDR mean?

EUDR means EU Deforestation Regulation. It is the EU law that requires covered products to be deforestation free, legally produced and covered by a Due Diligence Statement or simplified declaration.

When does EUDR apply?

The current application date is 30 December 2026 for large and medium operators and 30 June 2027 for micro and small operators. Micro and small operators already covered by the EU Timber Regulation have a 30 December 2026 date.

What products are covered by EUDR?

EUDR covers cattle, cocoa, coffee, palm oil, rubber, soy, wood and certain products made from them.

What is a DDS reference number?

A DDS reference number is generated when a Due Diligence Statement is submitted in the EUDR Information System. It links the product or shipment to the due diligence record.

Does FSC or PEFC certification make a product EUDR compliant?

No. FSC or PEFC can support the risk assessment, but it does not replace EUDR due diligence, geolocation evidence, legal harvest evidence or DDS submission where required.

Do non EU suppliers need to provide EUDR data?

Non EU suppliers may not have direct EUDR obligations unless they place products on the EU market. However, EU customers may ask them for origin, geolocation, legality and traceability data to support EUDR compliance.

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EUDR compliance workflow for wood and furniture supply chains

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EUDR compliance support

Carbon reporting services

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Suggested external source links

European Commission EUDR page
https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en

EUDR implementation resources
https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation_en

EUDR due diligence guidance
https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/understand-due-diligence_en

EUDR Information System
https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/information-system-deforestation-regulation_en

Regulation EU 2023 1115
https://eur-lex.europa.eu/eli/reg/2023/1115/oj/eng

Access2Markets EUDR delay update
https://trade.ec.europa.eu/access-to-markets/en/news/delay-until-december-2026-and-other-developments-implementation-eudr-regulation

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