Timber and wood products
Importing timber under the EU deforestation regulation
Since the EUDR, it is no longer your customs declaration that decides whether your timber enters Europe: it is your ability to say where every tree came from.
What is covered
Regulation (EU) 2023/1115 does not cover raw timber alone. It covers a wide range of products derived from it:
- raw timber, sawn wood, logs and veneers;
- plywood, particle board and fibreboard;
- wooden furniture of chapter 94;
- paper, board and wood pulp;
- charcoal and fuel wood.
A product being processed does not take it out of scope. The HS code decides, and Annex I to the regulation lists the headings concerned precisely. Many companies prepare for products that are out of scope and miss those that are in.
Why it gets stuck
A flawless customs file is no longer enough. To place timber on the Union market, you must draw up a due diligence statement attesting two things: that the timber was harvested legally under the law of the country of production, and that it does not come from land deforested after 31 December 2020.
That statement requires information the usual supply chain does not produce: the geolocation of the harvest plots, the date or period of harvest, the country of production, and the identity of every intermediate operator.
The difficulty is almost never legal. It is documentary: your Cameroonian, Brazilian or Indonesian supplier has never had to provide those coordinates, and does not always understand why they are being asked for. That is where files get bogged down.
What we do
1. Map your chain
We work back from the importer to the plot. We identify who actually holds the information, and who never will.
2. Qualify your products
We check which of your HS codes actually fall under Annex I, and which do not.
3. Collect the data
We build the required data set and request it from your suppliers in their own language, in a format they can fill in.
4. Check before every departure
Consistency between invoice, packing list, transport documents, due diligence statement and customs declaration, checked before loading.
In practice, a first file starts with the Diagnostic, after which the arrangement is maintained over time by the Control Tower.
A clear scope
What is included
- analysis of the scope against your actual HS codes;
- mapping of the supply chain and identification of the blind spots;
- building and collecting the due diligence data set;
- documentary checks before every shipment;
- coordination of your freight forwarder and your customs declarant.
What is not included
- signing the due diligence statement, which binds the operator and remains theirs;
- lodging the customs declarations;
- forest certification and field audits;
- obtaining harvesting titles and permits in the country of production.
CTB Group steers customs compliance and governance; the lodging of declarations remains with the representatives appointed by the company.
The questions you must be able to answer
- Which country does the timber come from, and which region exactly?
- Do you know the forest, concession or plot of origin?
- Can your supplier provide geographic coordinates, and in what format?
- Do all your products fall under Annex I, or only some of them?
- Who, in your chain, is the operator within the meaning of the regulation: you, or your supplier established in the Union?
If you cannot answer three of these five questions, your next shipment is exposed. See also the catalogue of customs authorisations and statuses, including EUDR operator status.
Frequently asked questions
Is timber covered by CBAM?
No. CBAM targets iron, steel, aluminium, cement, fertilisers, hydrogen and electricity. Timber falls under the EUDR. The two regulations are often confused; they share neither scope, nor obligations, nor timetable.
Is a wooden item of furniture covered?
Yes, wooden furniture of chapter 94 appears in Annex I. A steel item of furniture, by contrast, falls under neither the EUDR nor CBAM.
Do you sign the due diligence statement on our behalf?
No. It binds the operator placing the product on the market. We prepare and check everything it contains; you sign it.
Authorisations concerned
For this sector, these are the statuses and authorisations that come up most often. The applicant is always the company; we prepare the file.
- EUDR operator — status and due diligence statement in the Commission system
- EORI number — a prerequisite for any import or export operation
Let us look at one of your timber imports
Thirty minutes to look at a real operation: what you import, from where, and what could hold it up.