The regulation fundamentally questions which products fall under EUDR requirements. While the seven key commodities are widely known, the answer remains complex. The regulation relies on customs product codes. Harmonised System (HS) codes , that determine whether your products require due diligence.
What Is In Scope
At EUDR's core are timber and wood-based products, governed by specific HS codes outlined in Annex I. Key covered products include:
- Logs and Sawn Wood (HS 4407) , the raw backbone of timber trade
- Plywood (HS 4412) , layered, glued, and clearly in-scope
- Pulp and Paper (HS 4707, 4802, etc.) , certain packaging and printing papers depending on classification
- Wooden Furniture (HS 9403 30, 9403 40, 9403 50, 9403 60, 9403 91) , chairs, tables, and shelves
Understanding HS Codes
The Harmonised System represents a global classification developed by the World Customs Organization (WCO). It assigns six-digit codes to every traded product, ensuring consistent language among customs authorities worldwide. Companies can locate product codes through customs declarations, supplier invoices, or directly via WCO databases.
Do not guess , check. Your product's HS code determines EUDR applicability. An incorrect classification can mean non-compliance even if your sourcing is clean.
The Grey Areas
Not every product classification proves straightforward. EUDR permits interpretative flexibility, creating potential stumbling blocks.
Mixed Materials
Consider a wooden chair with metal legs. Classification depends on "essential character" , if wood defines function or value, it is classified as wooden. If metal dominates, it may not be covered.
Packaging Wood
Wooden crates, pallets, or boxes sometimes fall under EUDR when sold as independent products. However, incidental packaging materials accompanying goods typically do not qualify. Classification depends on customs rulings and product declarations.
Recycled Content
The regulation explicitly excludes entirely recycled products. However, this requires proof. Companies must be able to document and verify that the materials are 100% recycled.
Practical Steps: How to Stay Safe
Step 1: Map Your Products
List every catalogue item with its HS code, creating clear visibility into EUDR scope applicability.
Step 2: Double-Check with Customs
For grey-zone products, contact national customs authorities or trade consultants for confirmation. Many offer binding tariff information rulings , official, reliable classifications.
Step 3: Update Your Paperwork
Supplier declarations, catalogues, and contracts should reflect correct HS codes. Consistent documentation facilitates compliance verification during inspections.
Why It Matters
Correct classification is not merely bureaucratic. It reduces compliance risks, prevents shipment delays, and builds buyer trust. The EUDR remains permanent, with HS codes serving as its gatekeepers.