GEROM / Inside GEROM / Market Watch
Inside GEROM · Market Watch
EUDR and school furniture: what to ask your supplier before 30 December 2026
Key facts
- EUDR applies from 30 December 2026 to large and medium-sized companies, and from 30 June 2027 to most micro and small ones; small companies that already handled timber under the EU Timber Regulation keep the December date.
- Scope follows customs codes: wooden furniture (CN 9403), wooden seats (CN 9401), particleboard (4410), fibreboard (4411) and plywood (4412).
- Since Regulation (EU) 2025/2650, the due diligence statement is filed once, by the operator that first places the goods on the EU market; the first buyer after it keeps the reference number for five years.
- Ukraine is classified as a low-risk country, so due diligence for wood harvested there is simplified.
From 30 December 2026 the EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) applies to large and medium-sized companies, and from 30 June 2027 to most micro and small ones. Small companies that already dealt with timber products under the old EU Timber Regulation keep the December date. If you buy wooden furniture for schools, kindergartens or offices in the EU, there is one thing worth settling early: what will be in the delivery folder when the first pallet arrives.
A regulation that reads your invoice
EUDR does not care what a product is called. It reads the customs code. Annex I covers wooden furniture and its parts under CN 9403, wooden seats under CN 9401, and the boards that furniture is made from: particleboard (4410), fibreboard (4411) and plywood (4412). So a steel-frame desk with a board top and a wooden cabinet can end up on different sides of the line, depending on how each one is classified. The CN code on the invoice is the first line worth reading, and it is easiest to ask about before the contract is signed, when the answer is one email away.
One statement, one number
Until the December 2025 amendment, many distributors expected to file their own paperwork for every shipment. Regulation (EU) 2025/2650 took that away. The full due diligence statement is filed once, by the operator that first places the goods on the EU market, and it produces a reference number. The first buyer after that operator keeps the number for five years. Larger companies further down the chain also register in the EU information system and look twice if they have a reason to doubt a supplier, but they do not redo the work.
What is inside that number
Every number is a small folder of facts: the coordinates of the plots where the trees grew, proof that the wood was harvested legally, proof that the land was not cleared of forest after 31 December 2020, and an assessment of the remaining risks. In furniture that folder reaches back into boards and veneer, so the documents for boards and veneer weigh as much as the documents for the finished furniture.
Where the tree grew
How much of this work has to be done depends on the country where the wood was harvested. The European Commission sorts countries into low, standard and high risk. For low-risk countries the due diligence is simplified: supply chain information is still collected and the statement is still filed, but the full risk assessment and mitigation steps fall away, and authorities check around 1% of operators. Ukraine is on the low-risk list, and in August 2026 FSC brought in a revised risk assessment for the country that builds on its electronic timber accounting and electronic certificates of origin.
A chain-of-custody system such as FSC follows wood from the forest to the finished product, and our furniture is made under FSC chain-of-custody certification. Whether a particular shipment needs anything beyond it depends on who places the goods on the market, which is a fair question to ask any supplier, us included.
A Tuesday in January
Picture a Tuesday in January 2027. A shipment of student desks has cleared customs. Somebody in procurement pours a coffee, opens the delivery folder and finds the invoice with its CN code and the packing list with packaging mass split by material. Next to them sits the reference number of the due diligence statement. Nobody has to write to the supplier or explain to the school board why a page is missing, and the coffee is still hot.
Four questions for any supplier
Ask for the CN code of each product and which parts of it are made of wood. Ask who files the due diligence statement. Ask whether the reference number travels with the shipment documents. Ask how long the records are kept. A supplier whose paperwork is in order usually answers these without much searching, and the answers let you compare offers on equal terms.
If you buy school, kindergarten or office furniture for the EU market and want to compare how your current supplier answers these questions, request the catalogue below.
Questions buyers ask
When does EUDR apply to furniture?
From 30 December 2026 for large and medium-sized companies, and from 30 June 2027 for most micro and small ones. Small companies that already placed timber products on the market under the EU Timber Regulation keep the 30 December 2026 date.
Which furniture is covered by EUDR?
Scope follows the CN codes in Annex I of Regulation (EU) 2023/1115: wooden furniture and its parts under CN 9403, wooden seats under CN 9401, and boards such as particleboard (4410), fibreboard (4411) and plywood (4412). Whether a specific product is covered depends on how it is classified.
Who files the EUDR due diligence statement?
Since Regulation (EU) 2025/2650, the full statement is filed once, by the operator that first places the goods on the EU market. The first buyer after that operator keeps the statement's reference number for five years and does not repeat the due diligence.
What does EUDR mean for wood from Ukraine?
Ukraine is classified as a low-risk country. Supply chain information is still collected and the statement is still filed, but the full risk assessment and mitigation steps are not required.