EUDR and CITES: do protected timber species need both?

CITES and the EUDR are separate regimes that can both apply to the same shipment, and neither replaces the other. A CITES permit does not satisfy EUDR due diligence, and an EUDR due diligence statement does not satisfy CITES permitting. If your timber is a CITES-listed species such as rosewood, afrormosia, ramin or bubinga, you need both before the goods clear an EU border.

Why the two regimes exist side by side

CITES (the Convention on International Trade in Endangered Species) controls trade in specific species at risk of over-exploitation. In the EU it is implemented through the Wildlife Trade Regulations, based on Council Regulation (EC) No 338/97, most recently amended by Commission Regulation (EU) 2026/1383 to reflect the species list agreed at CITES CoP20 in Samarkand in late 2025. A CITES permit exists to stop a specific, named species being traded to extinction.

The EUDR controls something different: whether any relevant commodity, listed or not, was produced on land deforested or degraded after 31 December 2020, and whether it was produced legally in its country of origin. A shipment of a CITES-listed timber species is almost always also an EUDR "wood" product under Annex I, so it sits inside both regimes at once, each checking for a different kind of harm.

Because the two tests are different, passing one tells you nothing about the other. A CITES permit confirms a shipment doesn't breach the trade quota or export conditions set for that species. It says nothing about which specific plot the timber was cut from, or whether that plot was forest as at the end of 2020 — the question the EUDR actually asks.

Does a CITES permit replace an EUDR due diligence statement?

No, and this is the point importers who also handled EU Timber Regulation (EUTR) compliance most often get wrong, because the old rules worked differently. Under the EUTR, Article 3 treated timber covered by a valid FLEGT licence or a CITES permit as automatically meeting the EUTR's legality requirement — a recognised presumption that let operators skip part of their own due diligence for that shipment.

The EUDR carries no equivalent presumption. A CITES permit is evidence you can hold on file, and it can support the legality limb of your risk assessment, but it does not substitute for the due diligence statement itself, the plot-level geolocation Article 9 requires, or the deforestation-free assessment against the 2020 cut-off date. The same is true of FLEGT licences and of forest certification generally — see whether FSC, RSPO or Rainforest Alliance certification satisfies EUDR due diligence for the parallel case. If you imported CITES-permitted timber under the EUTR and treated the permit as your compliance file, that approach does not carry over.

Which commercial timbers are affected

Most traded wood is not CITES-listed, but a meaningful share of high-value hardwood is, and the overlap with EUDR-scoped wood products is close to total because timber is an EUDR Annex I commodity regardless of species.

Species / genus	Common trade name	CITES listing	Typical use
Dalbergia spp. (except D. nigra)	Rosewood	Appendix II, since 2 January 2017	Furniture, musical instruments, veneer
Dalbergia nigra	Brazilian rosewood	Appendix I	Musical instruments (restricted trade)
Pericopsis elata	Afrormosia	Appendix II, since 1992	Decking, joinery, boat building
Swietenia macrophylla	Bigleaf mahogany	Appendix II	Furniture, cabinetry
Gonystylus spp.	Ramin	Appendix II, since 2001	Mouldings, dowels, picture frames
Guibourtia tessmannii, G. pellegriniana, G. demeusei	Bubinga	Appendix II, since January 2017	Furniture, veneer, guitar bodies
Pterocarpus erinaceus	Kosso / African rosewood	Appendix II, since January 2017	Furniture, flooring

Annotations attached to each listing can exempt small quantities, finished goods below a stated weight, or specific product forms (worked veneer rather than logs, for example). Those exemptions apply to the CITES permit requirement only — they have no bearing on whether the EUDR due diligence statement is still needed, which it is, in full, for any quantity.

CITES compliance can also feed into your EUDR legality test

Beyond the EU's own permit requirement, CITES has a second, separate way of mattering under the EUDR. Article 2(40) defines "legal production" by reference to the relevant legislation of the country of production, across several categories including trade and customs regulations. Where a country of production has its own CITES-implementing export licensing law for a listed species, failing to hold a valid export permit there is a legality failure under that country's own law — which makes the product not "legally produced" for EUDR purposes, independently of whatever happens at the EU border.

In practice this means a CITES-listed shipment can fail EUDR legal production in the country of origin (no valid export permit obtained there) even before you reach the separate question of whether the EU will issue the corresponding import permit. Build a check for the exporting country's own CITES permit into your supplier due diligence, not just a check for your own EU import permit, and keep both on file alongside your Article 9 information as supporting evidence for the legality limb of your risk assessment. What the forest and forest degradation definitions actually cover under Article 2 matters just as much for a CITES-listed plot as for any other.

What happens at the EU border

Customs checks the two documents through different channels, and currently neither substitutes for the other:

• The DDS reference number has to be on the customs declaration before goods can be released, under Article 26 — see how the DDS reference works at customs clearance for the mechanics.
• The CITES import permit is checked separately, through the national CITES management authority's own licensing system, which customs consults through established wildlife-trade border controls that predate the EUDR by decades.
• The EU's Single Window Environment for Customs programme is intended, over time, to connect multiple partner-authority systems — CITES licensing among them, alongside plant health and others — to a single customs declaration interface. Until that integration covers both EUDR and CITES in the same flow, expect the two checks to be made independently, which means a shipment can be held up by either one on its own even if the other is in perfect order.

Build lead time into your import planning for a CITES-listed shipment accordingly: filing the DDS early does not shorten how long the CITES import permit takes to obtain, and the two are not sequenced to arrive together just because the same shipment needs both.

Getting a CITES permit alongside your EUDR filing

CITES export permits are issued by the exporting country's designated Management Authority, and the corresponding EU import permit is issued by the destination Member State's own Management Authority — a national body, not an EU-level one, and not the same body that administers your country's EUDR competent authority function. Apply for the import permit well ahead of shipment: processing times vary by Member State and by species, and a permit application is not something a freight delay can be solved around at short notice.

Treat the two filings as parallel workstreams run by the same team, not a single combined process:

1. Confirm the species' current CITES appendix and any quantity or product-form annotations that apply to it, since these change at each CITES Conference of the Parties.
2. Obtain the export permit from the country of production's Management Authority, and keep it as part of your supplier's legality evidence.
3. Apply for the EU import permit from your own Member State's Management Authority in parallel with, not after, your EUDR due diligence work.
4. File the EUDR due diligence statement in TRACES on its usual timeline, covering the deforestation-free and legality assessment in full — see the full Article 9 information checklist for what that assessment has to contain.
5. Reconcile species, quantity and country of production across both documents before the goods move; a mismatch between what the CITES permit and the DDS each state is one of the more common reasons a consignment gets queried at either checkpoint.

If you only handle non-CITES timber

Most sawn timber, plywood, construction lumber and furniture-grade wood moving into the EU is not CITES-listed, and nothing in this guide changes what you have to do for it — see EUDR for furniture and timber importers after the Timber Regulation repeal for the general timber obligations that apply regardless of species. The point of checking CITES status at all is that a small number of high-value species carry a second, independent permit requirement layered on top of the due diligence you already owe everyone else.

Run the free checker to get a dated plan for your due diligence obligations based on your actual products, sourcing countries and size band, separate from whatever CITES permitting your specific species also requires.

FAQ

Does a valid CITES permit mean I don't need an EUDR due diligence statement? No. The EUDR has no equivalent of the EU Timber Regulation's old presumption that FLEGT-licensed or CITES-permitted timber is automatically compliant. A CITES permit is supporting evidence, not a substitute for the due diligence statement, the geolocation data, or the deforestation-free assessment.

Does an EUDR due diligence statement mean I don't need a CITES permit? No. The due diligence statement addresses deforestation and legality under the EUDR; it has no bearing on the separate wildlife-trade permit requirement for a CITES-listed species. Both documents are required where both regimes apply.

Which timber species are both CITES-listed and EUDR-scoped? Any CITES-listed tree species traded as timber falls into this overlap, because the EUDR's wood category covers timber regardless of species. Commercially significant examples include rosewood (Dalbergia spp.), afrormosia, bigleaf mahogany, ramin, bubinga and kosso.

Who issues the CITES import permit? Your own EU Member State's designated CITES Management Authority, a national body separate from your EUDR competent authority. The corresponding export permit comes from the Management Authority of the country of production.

Does a CITES annotation exempting small quantities also exempt me from the EUDR? No. CITES annotations (for example, exemptions for small non-commercial quantities, or for specific finished-product forms) apply only to the CITES permit requirement. They have no effect on the EUDR due diligence statement, which is required for any quantity of a relevant product.

Can a missing CITES export permit in the country of production affect my EUDR compliance? Yes, indirectly. Where the country of production has its own CITES-implementing export licensing law, failing to hold a valid permit there is a breach of that country's own legislation, which can make the product fail the EUDR's "legal production" test under Article 2(40), separately from any EU-side permit question.

Is there a single combined system for filing both the DDS and a CITES permit application? Not currently. The EU's Single Window Environment for Customs programme aims to connect CITES licensing and the EUDR's information system to customs declarations over time, but the two checks are made through separate systems today, so treat them as parallel filings rather than one combined process.

Does this affect every EUDR commodity, or just timber? In practice, almost entirely timber and timber products. The other six EUDR commodities — cattle, cocoa, coffee, oil palm, rubber and soya — are not species subject to CITES trade controls, so the overlap this guide describes is a wood-sector issue specifically.