The EUDR is shaking up global trade. One of the biggest questions out there is: 'Does this product even fall under the EUDR?'

Everybody knows the 7 key commodities, but the answer is not always straightforward. The regulation relies on customs product codes — little numbers deciding whether your table is a table, or a compliance headache.

So, let's take a walk through the forest of codes, commodities, and grey areas. By the end of this post, we should understand what's in scope, what's out, and what's somewhere in between.

What's In

At the heart of the EUDR are timber and wood-based products, but the rules are more precise than just wood. The regulation points us to Annex I, where specific Harmonised System (HS) codes are listed. These codes determine which products must go through due diligence.

For example:

• Logs & Sawn Wood (HS 4407) – the raw backbone of the timber trade.
• Plywood (HS 4412) – layered, glued, and very much in.
• Pulp & Paper (HS 4707, HS 4802, etc.) – covering certain types of packaging and printing paper, but not everything made of paper — meaning that from the magazine you could be reading to the packaging around your online order, compliance still apply depending on product classification.
• Wooden Furniture (HS 9403 30, 9403 40, 9403 50, 9403 60 and 9403 91) – your chairs, tables, and shelves may soon come with a compliance label.

If your business touches these, the EUDR applies. But here's the catch: HS codes aren't always intuitive.

So, what exactly are HS codes?

The Harmonised System (HS) is a global classification developed by the World Customs Organization (WCO). It assigns a 6-digit code to every traded product, making sure customs authorities around the world speak the same language.

Companies can find the codes for their products in customs declarations, supplier invoices, or directly through the WCO database or their national customs authority. The key takeaway? Don't guess — check. Your product's HS code is the key to knowing whether it falls under the EUDR.

The Grey Areas

Of course, not every product is as clear-cut as a log of sawn timber. The EUDR leaves space for interpretation, and that's where businesses often stumble.

Take mixed materials: that trendy chair with a wooden seat and metal legs. Is it covered? Customs authorities decide based on what they call the product's essential character. In other words, if the wood defines the product's function or value, it's classified as a wooden product. If the metal dominates, it may not be.

Then there's packaging wood: wooden crates, pallets, or boxes. Sometimes these are covered if they are sold as products in themselves. But if the wood is only incidental — for example, packaging material that accompanies goods and isn't the main product — it may not fall under EUDR. Again, it depends on customs rulings and how the product is declared.

And what about recycled content? The regulation explicitly excludes products made entirely from recycled materials. That sounds simple enough, but it still requires proof. Companies must be able to document and verify that the materials are 100% recycled. Without that evidence, regulators won't just take your word for it.

This is where a bit of strategy comes in. Companies should:

• Proactively classify borderline products with customs or trade experts.
• Collect supporting documentation from suppliers.
• Align their declarations and paperwork to match the HS code applied.

Otherwise, they risk delays at customs — or worse, being accused of non-compliance.

Practical Steps: How to Stay Safe

Navigating HS codes does not need to feel like decoding hieroglyphs. With the right approach, companies can stay compliant and avoid nasty surprises.

Step 1: Map your products. Start by listing every item in your catalogue with its HS code. This creates a clear overview of what falls inside or outside the scope of the EUDR.

Step 2: Double-check with customs. If a product sits in a grey zone, don't assume. Reach out to your national customs authority or a trade consultant to confirm its classification. Many customs offices even offer binding tariff information rulings — official decisions you can rely on.

Step 3: Update your paperwork. Supplier declarations, catalogues, and contracts should all reflect the correct HS codes. The more consistent your documentation, the easier it is to prove compliance during checks.

Think of it like drawing a map before heading into the woods: the clearer your route, the less chance you will get lost in compliance pitfalls.

Why It Matters

Getting the classification right is not just a bureaucratic exercise. It's about reducing compliance risks, avoiding shipment delays, and building trust with buyers.

Put simply: if you know what's in and what's out, you can focus your efforts where they matter most — and avoid wasting time (and money) chasing requirements that do not apply.

The EUDR is here to stay, and HS codes are its gatekeepers. And complying with the EUDR is less about paperwork and more about storytelling — the story of where your products come from, and how they reach the market responsibly.

That's a story worth telling.