EUDR for furniture: cabinets by 30 December, chairs can wait

A micro-enterprise that makes particleboard wardrobes has to comply with the EU Deforestation Regulation (EUDR) from 30 December 2026. A micro-enterprise that makes upholstered chairs with wooden frames may have until 30 June 2027. The difference comes from the Combined Nomenclature (CN) code, not from company size or material.

The Commission lists three dates, while most summaries give two: 30 December 2026 for large and medium-sized companies and 30 June 2027 for small and micro companies. The third is 30 December 2026 again, this time for micro and small companies with products that have so far been covered by the old EU Timber Regulation. That is the one that affects furniture makers. As of 5 November 2026, it is 55 days away.

When does the EUDR start to apply to wooden cabinet furniture?

For wooden cabinet furniture, the EUDR applies from 30 December 2026, regardless of company size. This follows from Article 38(3) of Regulation (EU) 2023/1115, as amended by Regulation (EU) 2025/2650. Paragraph 3 defers the date to 30 June 2027 for micro and small undertakings, but it opens with a carve-out: “Except as regards the products covered by the Annex to Regulation (EU) No 995/2010”. That is the old EU Timber Regulation (EUTR).

Furniture under codes 9403 30, 9403 40, 9403 50 and 9403 60 is in that Annex, so the deferral does not extend to it. The Commission says so on its EUDR page too: the 30 December 2026 date also applies to micro and small operators already covered by the EUTR.

Which EUDR deadline applies to which CN code?

The EUDR splits furniture by code, so the first step is to sort your range by code. The list below follows Annex I as amended by Delegated Regulation (EU) 2026/2102, in force since 18 September 2026.

• ex 9403 30, 40, 50 and 60 (wooden furniture for offices, kitchens, bedrooms and other uses): 30 December 2026 for all companies.
• ex 9403 91 (parts for this furniture): 30 December 2026 on our reading, subject to the note below.
• ex 9401 31 00, 41 00, 61 00, 69 00, 80 00 and 91 90 (seats of wood and parts of seats): 30 June 2027 for micro and small companies if they are operators, 30 December 2026 for everyone else.
• 9404 (mattresses and bedding): not in Annex I.
• Used products and second-hand products: out of scope for all these codes since 18 September 2026.

Metal and plastic furniture (9403 10, 9403 20, 9403 70) is not in Annex I either. If you make both cabinets and chairs, part of your range falls under the earlier date.

Note on parts: the EUTR Annex names the old code 9403 90 30, while the EUDR uses 9403 91. The goods are the same, so we assume the earlier date applies, but the codes do not match exactly and the point is arguable. If you make only parts, take legal advice.

Why do wardrobes and chairs have different EUDR deadlines?

The split between wardrobes and chairs goes back to the history of two regulations. The 2010 EUTR covers wooden furniture under 9403 but leaves out seats under 9401. The 2023 EUDR added them, and the deferral for small companies does not apply to products the EUTR already covered.

So material is not the deciding factor. For micro and small companies, a solid wood armchair has a 2027 date and a laminated particleboard wardrobe a 2026 one.

Who qualifies for the deferral to 30 June 2027?

The deferral under Article 38(3) of the EUDR has three conditions besides the code. The company must be an operator, must be a micro or small undertaking under Directive 2013/34/EU, and must have been established as such by 31 December 2024. An undertaking that was medium-sized then and has since shrunk does not meet the third condition.

Paragraph 3 refers only to operators, and according to the Commission's guidance the obligations of downstream operators apply from 30 December 2026. The guidance adds that timber from the EUTR Annex placed on the market from that date, and its derived products, must comply with the EUDR. For such timber there is no deferral, whatever the size of the supplier. On our reading, a chair manufacturer that buys such boards may have obligations under Article 5 before June 2027, even if it is a micro-enterprise. Take legal advice on your own case.

Operator or downstream operator: what decides how much EUDR work you have?

For a furniture maker, the biggest EUDR question is which role it plays, and that is decided separately for each product. Article 2(15b) defines a downstream operator as 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”.

A downstream operator does not exercise due diligence and does not submit a statement. It collects details of its suppliers and of the downstream operators and traders it sells to and, where the supplier is an operator, the reference number of the statement. It keeps this information for at least five years (Article 5). If a wood input is not covered by a statement, however, as with a board imported directly from a third country, you are the operator for that input, which means due diligence, a statement and geolocation of the plots of land.

Low-risk status helps less than it might seem. All Member States are classified as low risk (Implementing Regulation (EU) 2025/1093). Under Article 13 of the EUDR, an operator that has established that all its raw material comes from such countries does not carry out risk assessment or risk mitigation, unless it receives information pointing to a risk of non-compliance. The statement and geolocation still apply.

Does the EUDR apply to boards and furniture placed on the market before 30 December 2026?

For products in the EUTR Annex, such as furniture under 9403, the Commission's guidance of 20 July 2026 sets separate rules. Timber harvested before 29 June 2023 stays under the EUTR if it is placed on the market up to and including 30 December 2029. Timber harvested from that date onwards and placed on the market before 30 December 2026 also stays under the EUTR, together with its derived products. Derived products outside the EUTR Annex, such as chairs under 9401, fall outside both regulations.

The Commission's example is about paper: a product placed on the market from 30 December 2026 onwards, but made from timber harvested and placed on the market between 29 June 2023 and 30 December 2026, complies with the EUTR and needs no due diligence statement. The same logic holds for a cabinet made from panels placed on the market before 30 December. Guidance is not law, though, and the example is not about furniture, so keep supplier documents showing when each batch was placed on the market.

According to the same guidance, furniture made entirely from material that has completed its lifecycle and would otherwise have been discarded as waste, such as timber from a demolished house, is not subject to the EUDR. This does not apply to by-products such as sawdust and wood chips.

What should furniture manufacturers do before 30 December 2026?

Preparing for the EUDR is mostly a matter of documents and suppliers. A sensible order:

1. Sort your range by CN code and mark which products fall under 9403 and which under 9401.
2. Check whether you were a micro, small or medium-sized undertaking on 31 December 2024.
3. Ask every supplier of panels, veneer and wooden components whether it is an operator and whether its goods will be covered by a due diligence statement. A supplier that is an operator must also give you the reference number.
4. If a supplier's goods will not be covered by a statement, prepare for the operator role: registration in the EU information system, geolocation data and a statement.
5. Set aside the batches placed on the market before 30 December 2026 and collect the documents for them.

Does the EUDR help with the digital product passport for furniture?

The EUDR only partly helps with the digital product passport for furniture. Data on the origin of the timber (country, geolocation, supplier) will probably be needed in the passport too, and the ESPR delegated act for that passport is tentatively expected in 2028.

The EUDR covers origin only, though. Durability, repair, recycling and the substances in materials remain separate work. You can see what this kind of data looks like in the sample sofa passport, and what lies ahead for the sector on the DPP for the furniture industry page. For supply chain records, see also the traceability page.