What the EU Deforestation Regulation Means for Dealers of Timber Buildings
Regulation (EU) 2023/1115, the EU Deforestation Regulation (EUDR), repeals the EU Timber Regulation (Regulation (EU) No 995/2010). It covers wood and the wood products listed in its Annex I, and that list includes prefabricated buildings of wood (CN code 9406 10). For dealers of log cabins, glulam houses and garden buildings it decides which records travel with a product through the supply chain.
This guide follows the consolidated text of the Regulation of 26 December 2025, which includes the amendments made by Regulation (EU) 2024/3234 and Regulation (EU) 2025/2650. It was read on EUR-Lex in September 2026. It is an overview for orientation, not legal advice.
The Rule in One Paragraph
Under Article 3, relevant products may be placed or made available on the EU market, or exported from it, only when three conditions are met: they are deforestation-free, they were produced in accordance with the relevant legislation of the country of production, and they are covered by a due diligence statement or a simplified declaration. For wood, deforestation-free means that the wood was harvested without inducing forest degradation after 31 December 2020, on land that was not deforested after that date.
When It Applies
Article 38, as amended in December 2025, sets the date of application at 30 December 2026. For micro and small undertakings established by 31 December 2024 the date is 30 June 2027, except for the products that the annex to the EU Timber Regulation already covered. Prefabricated buildings were in that annex, so the later date is not available for them.
Operator, Downstream Operator or Trader
The obligations depend on the role that a company has in the supply chain. Article 2 defines three roles:
- Operator: a person who, in the course of a commercial activity, places relevant products on the market or exports them, and who is not a downstream operator. Placing on the market is the first making available of a product on the EU market.
- Downstream operator: a person who places on the market or exports relevant products made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration.
- Trader: any other person in the supply chain who makes relevant products available on the market in the course of a commercial activity.
A dealer that resells, inside the EU, timber buildings which a manufacturer in the EU has placed on the market fits the definition of a trader. A dealer that brings timber products into the EU from a third country is the one who places them on the market. Which role applies is decided on the facts of each supply chain.
What Each Role Has to Do
Operators
- Exercise due diligence before placing products on the market or exporting them: collect the information listed in Article 9, assess the risk (Article 10) and, where the risk is not negligible, mitigate it (Article 11)
- Make a due diligence statement available to the competent authorities through the information system of Article 33 before the products are placed on the market or exported
- Keep a record of the due diligence statements for five years, and keep the information collected under Article 9 for five years
- Pass the reference numbers of the due diligence statements, or the declaration identifiers, to downstream operators and traders further down the supply chain
Downstream Operators and Traders
- Place or make products available only when they hold the information required by Article 5(3): name, registered trade name or trade mark, postal address, email address and, if available, web address of the supplier and of the business customer, and, where the supplier is an operator, the reference numbers of the due diligence statements or the declaration identifiers
- Keep that information for at least five years and give it to the competent authorities on request
- Register in the information system before placing or making products available, when the company is not an SME
- Inform the competent authorities at once when new information, including a substantiated concern, indicates that a product is at risk of not complying
Country Risk and Simplified Due Diligence
Article 29 sorts countries into three levels of risk: low, standard and high. Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025 lists the countries of low and of high risk; Lithuania, Latvia, Estonia, Finland and Sweden are on the list of low risk. The list is reviewed as often as necessary in the light of new evidence.
When all relevant commodities and products were produced in low-risk countries, an operator may use the simplified due diligence of Article 13: after assessing the complexity of the supply chain and the risk of circumvention or of mixing with products of unknown origin, the operator does not have to carry out the risk assessment and the risk mitigation of Articles 10 and 11. The information requirements of Article 9 stay in place.
Certification Does Not Replace Due Diligence
Article 10(2)(n) lets an operator take into account information supplied by certification or by other third-party verified schemes, as complementary information in the risk assessment. It does not replace the due diligence of the operator. Eurodita holds no FSC or PEFC chain-of-custody certificate of its own; see certifications.
Penalties
Penalties are laid down by each member state. Article 25 requires that they include fines proportionate to the environmental damage and to the value of the products; for a legal person the maximum amount of the fine has to be at least 4% of the total annual Union-wide turnover of the operator or trader in the financial year before the fining decision. The penalties also include confiscation of the products and of the revenues gained from them, temporary exclusion from public procurement and from public funding for up to 12 months, and, for serious or repeated infringements, a temporary prohibition on placing the products on the market or exporting them.
What to Ask Your Supplier
Under Article 5(3) a downstream operator or a trader keeps on file:
- The name, registered trade name or trade mark, postal address, email address and, if available, web address of the supplier
- The reference numbers of the due diligence statements or the declaration identifiers, where the supplier is an operator
- The same contact details of the business customers to whom the products were supplied
Ask your supplier which of these it provides with an order, and in which form. Eurodita manufactures its timber buildings in Lithuania from Nordic and Northern European spruce and pine and processes approximately 150,000 m³ of timber per year on average. The documentation that accompanies an order, including the references required under this Regulation, is confirmed in the written quotation.
Frequently Asked Questions
Does FSC or PEFC certification satisfy the EUDR?
Certification can be used as complementary information in the risk assessment of an operator (Article 10(2)(n)). The due diligence itself, and the due diligence statement, remain the duty of the operator.
Is a dealer an operator or a trader?
It depends on what the dealer does. A dealer that is the first to make a relevant product available on the EU market, for example by bringing it in from a third country, places it on the market. A dealer that resells products which are already on the EU market fits the definition of a trader. Since December 2025 the Regulation also knows the downstream operator, who places on the market products made from products that are already covered by a due diligence statement.
Does the EUDR apply to timber buildings made in the EU?
Yes. The Regulation applies to relevant products placed or made available on the EU market, and to exports from it, wherever they were manufactured. Prefabricated buildings of wood are in Annex I.
From which date does the EUDR apply?
From 30 December 2026. The later date of 30 June 2027 for micro and small undertakings does not cover the products of the annex to the EU Timber Regulation, in which prefabricated buildings were listed.
How high can a fine be?
Each member state sets its own penalties. For a legal person the maximum amount of the fine has to be at least 4% of the total annual Union-wide turnover in the financial year before the fining decision (Article 25).
Related reading: Glulam vs Solid Log Construction: Technical Comparison | Certifications | Quality Assurance at Eurodita | About Eurodita