What Furniture Manufacturers need to know about EUDR
As part of the European Union’s efforts to make Europe the first climate-neutral continent by 2050, the European Parliament and Council formally adopted the European Union (EU) Deforestation-free Regulation (EUDR) on June 29, 2023. This new regulation, which replaces the EU Timber Regulation (EUTR) established in March 2013, will require all importers of timber or timber products in the EU to apply a due diligence system that follows a prescribed method with transparency and information along the supply chain. The EUDR requires seven commodities and certain specified products made from them to be "deforestation-free" in order to be sold on the EU market or exported from it.
Furniture manufacturers wanting to market such products in the EU (or export them from the EU) must conduct extensive diligence, down to the geolocation of all plots of land where the relevant commodities were produced, as well as the date or time range of production, or face dissuasive penalties.
In July 2019, as part of the EU Green Deal, the European Commission introduced "Stepping up EU Action to Protect and Restore the World’s Forests." This initiative aims to enhance the health of existing forests and expand sustainable, biodiverse forest coverage globally.
Here’s a brief timeline of how the EUDR unfolded:
May 2003: The European Union adopted the Forest Law Enforcement, Governance and Trade (FLEGT) Action Plan, which focused on illegal logging and associated trade but it did not address deforestation. The two main components of the FLEGT Action Plan were the EUTR and Voluntary Partnership Agreements (VPA) between the EU and timber producing countries.
Sep 2014: New York Declaration on Forests publishes a global timeline to slow and end forest lost during the UN Climate Summit 2014.
May 2019: European Commission adopts policy framework for EUDR development
Nov 2021: The European Commission adopted a proposal for a regulation on deforestation-free products.
Dec 2022: The EU agreed on a Regulation for deforestation-free products to guarantee products EU citizens consume do not contribute to deforestation or forest degradation worldwide.
Jun 2023: The European Parliament and Council formally adopted the EUDR on June 29th.
Dec 2024: The EUDR goes into effect on December 30.
Jun 2025: The EUDR becomes effective for micro and small exporters. Definitions for micro and small exporters have not been determined.
Jun 2028: European Commission conducts general reviewof EUDRevery five years, starting June 30th.
How can furniture manufacturers comply with the EUDR?
It’s recommended that exporters begin preparing for the EUDR requirements now.
The EUDR will apply to all wood or leather harvested from June 29, 2023, and placed on the EU market after December 30, 2024. Any wood or leather harvested after June 29, 2023, but delivered to the EU before December 30, 2024, must adhere to the EUTR.
After December 30, 2024, exporters will need to provide the following information and documentation to comply with the EUDR requirements. If the required information and evidence is missing, customs authorities will not release the wood or leather for import into the EU.
Product description, including the common name of the species and full scientific name
Quantity, either by kilograms, volume or number of items, or supplementary unit under the Harmonized System code
Country of production
Geo-coordinates of all plots of land where the wood was harvested or leather was acquired
Date or time range of harvest or acquisition
Conclusive and verifiable information that the wood or leather was legally harvested in accordance with the country’s relevant legislation
Conclusive and verifiable information that the wood or leather is deforestation-free
Why is this a concern?
Among the biggest concerns in the current EUDR language is the geolocation requirement and the definition of “plot of land” as “within a single real-estate property.”
The EUDR, as written now, requires exact geo-coordinates of all plots of land where the wood contained in the product was (possibly) harvested. Forests are defined as areas greater than 0.5 hectares that contain trees 5 meters or taller.
For plots of land 4 hectares or less, a single point is sufficient, provided the coordinates are at least one second of latitude and longitude (an area 32m x 32m); for plots of more than 4 hectares, a sufficient number of points is required to describe the perimeter of the plot. Coordinates consist of a latitude and a longitude value with a minimum of at least six decimal places. No definitive quality has been announced as to what constitutes “a sufficient number of points” for plots of more than 4 hectares.
The following are some examples of potential compliance challenges:
Understanding the cost breakdown and final product margins because of more complex stock keeping units (SKUs).
Identifying products and raw materials with the highest environmental impact and building implementation plans and due diligence processes for supply chains must be adaptable to regulatory changes.
Screening the supplier base and developing a Supplier Code of Conduct will be required for the policies to consider the implications of the new regulation.
Identifying key technologies (including satellite imagery) and partners to increase evidence-based traceability.
Auditing the base of suppliers, including providing proof with satellite imagery when sourcing from several suppliers or scattered production sites.
The EUDR also requires operators to establish and maintain a 'due diligence system' of procedures and measures to ensure relevant products comply.* As an example, the sofa diagram below would require the wood and leather be traced back to the raw materials. Track your products to the source with Zeus.
Zeus can help you stay compliant. Our software puts the following in motion:
Maps your supply chains: Gain full visibility into your supply chain, tracing products and components back to the source. Identify any gaps in traceability or areas of high risk. Zeus helps you trace your products at the SKU level. This granular data provides
Prioritizes risk assessment: Establish robust due diligence systems to collect, verify, and report on the origin and production methods of their commodities and products.
Implements risk mitigation: Based on your risk assessment, work directly with suppliers to improve practices and compliance. Engage with suppliers and partners to ensure they are also aware of the EUDR requirements and are taking the necessary steps to comply.
Monitors progress continuously: Compliance is an ongoing process. Make sure to stay informed about the latest developments and guidance related to the EUDR, as the regulation and its implementation may evolve.
* Source: Article 12 of the Regulation.