EUDR & parquet: deforestation-free timber in practice

What does the EU Deforestation Regulation mean for manufacturers, importers and traders of wooden flooring — and how do you build a compliant due diligence system?


Regulation at a glance
NameEU Deforestation Regulation (EUDR)
ReferenceRegulation (EU) 2023/1115
In force29 June 2023
Deadline large companies30 December 2025*
Deadline SMEs30 June 2026*
Supervisory authorityNational authorities + Commission
Legal basisArt. 192 TFEU (environment)
Maximum fine≥4% of annual turnover in the EU
* Deadlines were shifted by Regulation (EU) 2024/3234 (Dec. 2024). Always verify the current implementation date on EUR-Lex.

1. What is the EUDR?

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De EU Deforestation Regulation (Regulation (EU) 2023/1115) obliges companies placing certain products on the EU market to demonstrate that those products do not originate from deforested or degraded land after the reference date of 31 December 2020. The regulation is the successor to the EUTR (EU Timber Regulation) and goes considerably further: it covers seven commodity categories (soy, palm oil, cattle, cocoa, coffee, timber and rubber) including a lengthy list of derived products.

For the flooring industry, timber is the central raw material. Parquet floors — solid or engineered — are explicitly included in the product annexes of the regulation.

Definition: deforestation (Art. 2) Conversion of forest to agricultural use after 31 December 2020, regardless of whether this is legal or illegal under the national legislation of the country of production.

2. Why does the EUDR specifically affect the parquet sector?

Parquet is by definition a timber product. Both solid parquet and engineered wood engineered wood fall under HS codes included in Annex I of the EUDR (including HS 4409, 4418). This means that every link in the supply chain — from forest operator to European retailer — has obligations.

What makes parquet particularly notable is that the timber species often originate from tropical source countries (teak, merbau, jatoba, cumaru) or from Eastern European and Russian forests. It is precisely with these origins that the risk of deforestation is statistically higher and traceability has historically been weak.

3. Who exactly falls within scope?

The EUDR distinguishes between operators and traders (traders):

CategoryDefinitionObligation
Large operator Places product on the EU market for the first time; ≥250 employees or >€50M turnover Full DDS
SME operator Same first placement, but smaller enterprise Simplified DDS
Large trader Trades product within the EU without first placement Declaration + archive
SME trader Small trader further down the supply chain DDS reference number
Export to third countries EU company exports product outside the EU No EUDR obligation

4. The due diligence system (DDS)

The core of the EUDR is the mandatory due diligence statement (DDS) that must be submitted via the EU information system prior to placing products on the market. A DDS consists of three steps:

4.1 Data collection

Product description HS code, timber species (scientific name), country of harvest, region/province, plots (geolocations in polygon or point coordinates).
Supplier documentation Name, address and registration number of all suppliers; declarations of conformity; FSC/PEFC certificates (optional but reinforcing).
Legal origin Evidence that the timber harvest complies with the national legislation of the country of production (property rights, environmental regulations, taxes, labour law).

4.2 Risk assessment

Each consignment of timber is assessed for both deforestation and legality risk. Relevant factors include the country of production (Commission benchmark classification: low/standard/high risk), the presence of indigenous land rights, satellite data on deforestation changes and the reliability of the supply chain.

Note The European Commission publishes a country classification (benchmark). At the publication date of this article, the definitive benchmarks had not yet been published. Countries without an explicit classification fall under the standard category with full DDS obligations.

4.3 Risk mitigation

If the risk is not negligible, the operator must take adequate measures: request additional information from suppliers, commission independent audits, or — as a last resort — refuse the purchase. All steps and decisions must be documented and retained for a minimum of five years .

5. Timeline & deadlines

✓
29 June 2023
EUDR (Regulation 2023/1115) enters into force. Reference date for deforestation: 31 December 2020.
✓
December 2024
Delegated Regulation 2024/3234 postpones the original deadline of 30 December 2024 by one year.
→
30 December 2025
Deadline for large operators and large traders. Full DDS required for all in-scope products.
→
30 June 2026
Deadline for SME operators and SME traders.
?
Ongoing
EU information system (TRACES NT successor) for DDS submission under development. Publication of country benchmarks expected before the deadline.

6. EUDR vs FSC and PEFC: what is the difference?

A frequently asked question in the industry is whether an FSC or PEFC certificate is sufficient as proof of EUDR compliance. The answer is nuanced:

AspectFSC / PEFCEUDR
Legal basisVoluntary labelEU legislation (mandatory)
Deforestation after 2020Indirect assurance via audit cycleExplicit requirement + geolocation
LegalityIncluded in standardExplicit requirement
Geolocations of plotsNot required in certificateMandatory in DDS
Penalties for non-complianceWithdrawal of labelFines + market ban EU

FSC and PEFC can reduce the risk level and serve as supporting evidence, but do not replace the DDS. An EUDR-compliant company with FSC-certified suppliers will, however, have a considerably simpler path through the risk assessment.

7. Countries of origin and risk classification

Below is a non-exhaustive overview of wood species commonly used in parquet flooring, with their typical country of production and the expected risk level under the EUDR benchmark:

Wood speciesTypical country of originExpected risk level
European oak (Quercus robur)FR, DE, PL, ROLow
Maple (Acer saccharum)Canada, USLow
Ash (Fraxinus)Ukraine, RUStandard–high
Teak (Tectona grandis)Myanmar, Indonesia, IndiaHigh
Merbau (Intsia bijuga)Indonesia, PNGHigh
Jatoba (Hymenaea courbaril)BrazilHigh
BambooChina, VietnamStandard
Please note Bamboo (Bambusoideae) falls within the scope of EUDR when processed into products classified as "wood". The exact HS code and categorisation requires legal verification per product type.

8. Penalties

The EUDR requires member states to introduce effective, proportionate and dissuasive sanctions. The regulation specifies minimum requirements:

  • Fines of at least 4% of annual EU turnover
  • Confiscation of the products and revenues concerned
  • Temporary prohibition on placing products on the EU market
  • Exclusion from public procurement for up to five years

9. Getting started in practice: minimum action plan

Map your product portfolio List all wooden flooring products with HS code and determine which are in scope. Note: semi-finished products (veneer layers, HDF core) also count.
Inventorise timber species and origin Request from each supplier the scientific name of the timber species + country + region + plot coordinates. Use a standardised data template.
Carry out a risk assessment Use the country benchmark (once published), satellite imagery (Global Forest Watch, Hansen dataset) and supplier certificates to determine the risk level.
Draw up a due diligence statement Complete the DDS template with all mandatory fields and submit it via the EU information system. Retain a copy for 5 years.
Adapt internal procedures and supplier contracts Embed in purchasing contracts (contractual EUDR clause), annual update of risk assessments and audit trail for accountants and inspectors.
Tip for SMEs Chain DDS: if your direct supplier has already submitted an approved DDS, you as an SME trader may suffice with the reference number of that DDS. Ensure you have a contractual right to that number.

Sources & further reading

  1. Regulation (EU) 2023/1115 — EUR-Lex
  2. Regulation (EU) 2024/3234 (postponement) — EUR-Lex
  3. EC EUDR information portal — environment.ec.europa.eu
  4. Global Forest Watch — Hansen/UMD Tree Cover Loss dataset (v1.11)
  5. FSC — EUDR and FSC: key facts, 2024
  6. PEFC — EUDR Guidance for PEFC Certificate Holders, 2024
  7. European Flooring Manufacturers Association (EFMC) — EUDR position paper, 2023