Live Webinar - Nov 3, 2026 @ 4PM CET - What's Still Missing From Your EUDR File
Micro and small operators get until 30 June 2027 to apply EUDR, except for wood products that were already covered by the EU's previous timber rules. Those products start on 30 December 2026 for every operator, whatever its size. Wood products that are new to EU rules, such as wooden chairs, kitchenware and charcoal, do get the later date.
A table and a chair from the same factory have two EUDR deadlines.
A furniture importer in Portugal employs 18 people. Every quarter it brings in a container of solid teak dining sets from a workshop in Central Java: tables, chairs, a few sideboards. Same wood, same supplier, same container, same customs entry.
Under the EU Deforestation Regulation, the tables and sideboards need a due diligence statement from 30 December 2026. The chairs can wait until 30 June 2027.
That isn't a drafting accident. It's how the small-company deferral was written, and most summaries of it miss the detail entirely.
Short answer: Micro and small operators get until 30 June 2027 to apply EUDR, except for wood products that were already covered by the EU's previous timber rules. Those products start on 30 December 2026 for every operator, whatever its size. Wood products that are new to EU rules, such as wooden chairs, kitchenware and charcoal, do get the later date.
Because part of the timber trade has been regulated since March 2013. The EU's previous timber rules already required importers of logs, sawn wood, panels, paper and most furniture to run due diligence on legality. Those supply chains were expected to have systems in place, so the December 2025 amendment gave them no extra time.
The rule sits in one sentence of Article 38(3), as amended by Regulation (EU) 2025/2650. It defers the regulation to 30 June 2027 for operators that are natural persons, micro or small undertakings, established as such by 31 December 2024. It opens with an exception for products covered by the annex of the previous timber regulation.
That annex was written in 2010 against a product list of its time. EUDR's wood scope is wider. It added things the old rules never touched: chairs, charcoal, tools, kitchenware, small wooden articles. The deferral follows the old list exactly, product code by product code, so the line between "December" and "June" runs through the middle of chapter 44 and through the furniture chapter.
Two conditions sit around it. The deferral only helps operators, meaning the company that first places the product on the EU market or exports it. And only micro and small ones, measured on the EU Accounting Directive's limits. The Porto importer qualifies on every count: it is the operator, it is small, and it has traded since 2011. Many readers of this page won't. [internal link: /content-library/eudr-company-size-obligations]
Everything on the previous timber rules' product list. In practice: fuel wood and chips, logs, sawn wood, veneer, panels, flooring, frames, crates and pallets, barrels, doors and windows, pulp and paper, most wooden furniture and prefabricated wooden buildings. For all of these, micro and small operators start on 30 December 2026.
By HS heading:
Two edges worth knowing. Bamboo-based paper and recovered paper (waste and scrap) were never on the old list. And wooden packaging used only to support, protect or carry another product was excluded from the old rules, as it is from EUDR. A pallet you sell is in. A pallet that arrives under someone else's goods usually isn't.
The wood products EUDR added that the old rules never covered. Wooden seats are the one most companies trip on, because tables and chairs feel like the same product to everyone except the tariff schedule.
These get the later date only on the same conditions as everything else in the deferral: the company is the operator, it is micro or small, and it was established as such by 31 December 2024. If any condition fails, these products also start in December.
For most of the wood trade, the chair-versus-table question never comes up, because the company falls out of the deferral before product codes matter.
In practice, the product split mostly bites one group: small importers of finished wooden goods from outside the EU. Furniture importers, homeware brands, garden furniture suppliers, gift wholesalers. That group is large, and it is exactly the group most likely to assume it has until 2027.
In most cases, run one process for everything from 30 December 2026. Splitting product lines across two dates saves six months on part of the range and doubles the work of tracking which line is on which clock.
The Porto importer could, legally, file statements for its tables and sideboards in January and hold off on the chairs until July. Look at what that means in practice. The same supplier. The same plots of teak in Central Java. The same container, now carrying goods with and without a due diligence statement. The same customs entry, with some lines declaring a statement reference and some declaring nothing yet.
The hard part of EUDR for wood is collecting plot geolocation from the supplier and checking it against satellite records for clearance after 31 December 2020. Once that data exists for the tables, it exists for the chairs. The marginal cost of covering both is close to zero. The cost of running two regimes side by side is not.
There is a narrower case where the split is worth keeping: a company whose range is mostly deferred products, with a small share of old-list items from a separate supplier. A homeware brand selling chopping boards, utensils and ornaments, with one line of picture frames, can reasonably start with the frames in December and roll the rest in by June. The test is whether the two groups share suppliers. If they do, treat them as one.
- Does the June 2027 EUDR deadline apply to timber?
Only to some wood products. Micro and small operators handling products covered by the EU's previous timber rules, such as logs, sawn wood, panels, paper and most furniture, start on 30 December 2026. Wood products new to EU rules, such as wooden chairs and kitchenware, can use 30 June 2027.
- Is wooden furniture covered by the June 2027 extension? Mostly not. Wooden furniture under HS heading 9403, including tables, cabinets, beds and wooden furniture parts, was on the old list and starts on 30 December 2026. Wooden seats under heading 9401 were not, so small operators can apply EUDR to them from 30 June 2027.
- Why is a wooden chair treated differently from a wooden table?
Because the deferral follows the product list of the EU's previous timber rules, code by code. That list included furniture under heading 9403 but not seats under 9401. EUDR covers both, but only the products new to EU rules get extra time.
- Does the timber exception apply to paper and packaging?
Yes. Pulp, paper and paperboard in chapters 47 and 48 were on the old list, so paper packaging, cartons, envelopes and tissue start on 30 December 2026. Bamboo-based and recovered paper were not on that list. Wooden packaging used only to carry other goods is outside both regimes.
- Does a small sawmill get until June 2027?
No. Sawn wood is on the old list, so a micro or small sawmill acting as operator starts on 30 December 2026. If it sells its own harvested wood from a low-risk country, it may use the one-time simplified declaration, but the date doesn't change.
- Do small timber traders get extra time?
No. The deferral only covers operators. Traders and downstream operators of every size start on 30 December 2026, though their obligations are lighter: keeping supplier and customer records and, for the first company after the operator, statement reference numbers.
- What about timber produced before June 2023?
Timber products under the previous rules that were produced before 29 June 2023 and placed on the market from 30 December 2026 stay under the previous rules until 31 December 2029. From then on, they must meet EUDR's requirements.
Read the headline version of the December 2025 amendment and you'd think small companies have until mid-2027. In the wood trade, that's true for a short list of products and a narrow set of companies. Logs, boards, paper, doors, pallets and tables are on December for everyone.
The companies most exposed are the ones least likely to check: small importers of finished goods, who think of themselves as furniture or homeware businesses rather than timber businesses. Their tariff codes say otherwise.
The practical move is the boring one. Pull your CN codes this week, sort them against the two lists, and plan for December unless every line, every supplier and your company size all point to June. For most, they won't. And the supplier data you need for the tables is the same data you need for the chairs.
If you'd like a second check on where your product lines land, our free EUDR assessment works through your products, role and suppliers in one call.
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