EUDR · 2023/111530.12.2026 — 57 days
EUDRcheck

EUDR bamboo and rattan furniture: why it stays exempt

Bamboo and rattan are not EUDR commodities and sit outside Annex I wood. Why that holds, what 2026 changed, and where mixed-material products still catch you.

8 min read8 primary sources
On this page
  1. 01Why bamboo and rattan were never Annex I commodities
  2. 02What Delegated Regulation (EU) 2026/2102 actually changed
  3. 03The customs code evidence stands on its own
  4. 04Don't confuse rattan with oil palm
  5. 05Where mixed-material products stay in or fall into scope
  6. 06Quick reference: what's in, what's out
  7. 07What this means for your sourcing and paperwork
  8. 08How to actually confirm your classification

Furniture and homeware made purely from bamboo or rattan is not covered by the EUDR. Neither material is one of the regulation's seven Annex I commodities, and both sit outside the "wood" category specifically — a point Delegated Regulation (EU) 2026/2102 wrote into Annex I directly in 2026. The caveat is "purely": a bamboo chair with a real wood frame, or a rattan item made using glue, metal or textile components, is assessed on what the finished product actually is, not on its most eye-catching material.

Why bamboo and rattan were never Annex I commodities

Annex I to Regulation (EU) 2023/1115 lists seven relevant commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Bamboo is not on that list, and neither is rattan. That was true when the regulation was adopted in 2023 and it remains true after every amendment since.

The reason runs deeper than a simple omission. Bamboo is botanically a grass (subfamily Bambusoideae), not a tree, and commentary applying FAO forestry classifications treats it as a non-wood forest product rather than timber. Rattan is a climbing palm (genus Calamus), an entirely different plant again, grown and harvested more like a vine than felled like timber. Neither fits the deforestation-risk model the regulation was built around: large-scale clearance of forest to plant or graze the seven listed commodities. Fast-growing bamboo plantations and wild-harvested rattan do not carry that same profile, which is the policy reason they were left out rather than a drafting oversight.

What Delegated Regulation (EU) 2026/2102 actually changed

The Commission's delegated act recasting Annex I, adopted on 13 July 2026 and in force from 18 September 2026, is reported across multiple compliance and legal sources as adding an explicit note under the "wood" entry: wood does not extend to bamboo, rattan, and other materials of a similarly woody character, including cane, reed, wicker, osier, raffia, cleaned or dyed cereal straw and lime bark. That is a clarification of existing scope, not a new exclusion — bamboo and rattan products were never caught in the first place, because their own customs codes were never listed. EUDR Annex I changes 2026: what's in and out under Delegated Regulation (EU) 2026/2102 covers the rest of that act, including the products it genuinely did remove and add.

We have not located the Official Journal's own wording for this specific note, only consistent secondary reporting from several independent compliance sources. Treat the clarification as reinforcing an already-sound position rather than as the sole basis for it — the customs classification evidence below holds regardless of how that note is ultimately worded.

The customs code evidence stands on its own

Annex I's wood-furniture entries cover specific Combined Nomenclature headings for furniture made of wood — broadly the ex 9403 30 to 9403 91 range, plus the equivalent wooden-seat codes under 9401. Furniture classified as being of bamboo sits under its own heading, CN 9403 82; furniture of rattan sits under CN 9403 83. These are separate four-digit-plus subheadings from the wood-furniture entries, assigned precisely because bamboo and rattan are not wood under the Combined Nomenclature either. A product that is correctly classified under 9403 82 or 9403 83 was never going to appear on an Annex I wood list that only names the wood-furniture codes.

That is also why one Polish customs-advice page circulating online, which describes bamboo and rattan furniture as "forest-related commodities" subject to EUDR, does not hold up: it is not consistent with how Annex I actually lists wood furniture, and no primary EU source treats bamboo or rattan furniture as in scope on that basis.

Don't confuse rattan with oil palm

Rattan is a palm, and "oil palm" is one of the seven Annex I commodities, so it is worth being precise about why that does not catch rattan furniture. The oil palm commodity in Annex I is limited to the genus Elaeis — the species grown for palm oil — not palms generally. Rattan belongs to the unrelated genus Calamus. Being a palm family member has no bearing on EUDR status; what matters is whether the specific genus is the one the regulation names.

Where mixed-material products stay in or fall into scope

EUDR scope follows the finished product's own customs classification, not a percentage test on its materials. That principle cuts both ways for bamboo and rattan homeware:

  • A rattan chair with a structural wood frame. Customs classification uses the "essential character" test (General Rule of Interpretation 3(b)) to decide which single heading a composite article gets. If the frame — not the rattan weave — gives the piece its essential character, the finished chair can be classified as wooden furniture, which would bring it inside Annex I's wood-furniture codes despite the rattan content. We have not found a Commission ruling on this exact example; treat it as the logical consequence of the classification rules rather than a confirmed official position, and get an actual tariff classification for the specific product rather than assuming either way.
  • Bamboo flooring or panels bonded with adhesive or resin. A small proportion of synthetic adhesive does not pull in the "rubber" commodity — Annex I's rubber entry is specifically natural rubber from Hevea brasiliensis, not synthetic resins or adhesives generally. The flooring's own classification is what decides its status, not its glue content.
  • Multi-material homeware — a bamboo tray with a leather strap, a rattan basket with a metal frame. Each case turns on the CN code the finished, assembled product actually receives. Where a genuinely Annex I material (real wood, natural rubber, cattle leather) gives the product its essential character, due diligence attaches to that product. Where bamboo or rattan dominates the classification, it does not.

If you import a mixed-material range and are not confident how a specific product is classified, that classification — not a guess about which material looks more prominent — is the fact to pin down before your application date. EUDR for furniture and timber importers after the Timber Regulation repeal covers the position for businesses whose range is genuinely wood-based, including why the usual SME extension does not apply to them.

Quick reference: what's in, what's out

Product EUDR status Why
Furniture entirely of bamboo (CN 9403 82) Out of scope Not wood under Annex I; bamboo is not an Annex I commodity
Furniture entirely of rattan (CN 9403 83) Out of scope Not wood under Annex I; rattan is not an Annex I commodity
Bamboo flooring, panels, textiles, kitchenware Out of scope Same reasoning applies outside furniture specifically
Rattan basket with a wood or metal frame giving it essential character Depends on classification May take the frame's CN code, which can be in scope if wood-based
Chair with a real wood frame and a woven bamboo or rattan seat Depends on classification Essential-character test decides the single CN code the finished piece gets
Bamboo or rattan item bonded with synthetic resin or adhesive Out of scope on that basis Annex I's rubber entry is natural rubber only, not synthetic adhesives

What this means for your sourcing and paperwork

If your range is genuinely bamboo or rattan — baskets, trays, lampshades, pure-bamboo flooring, woven furniture with no structural wood, metal or leather component — you have no EUDR due diligence statement to file for it, no geolocation data to collect, and no application date to plan around for that product. That does not mean no paperwork at all: keep a record of how each product is classified and why, because "it's bamboo, so it's out" is the kind of claim a competent authority may ask you to substantiate at the border, particularly while customs officers are still getting used to a 2026 exclusion. What EUDR records must be kept, and for how long sets out the retention standard that applies to anything you do import under the regulation, which is a reasonable model to follow even for products you are confident sit outside it.

If your range mixes bamboo or rattan with genuine wood, natural rubber or leather components, do not assume the bamboo or rattan content gets you out. Get the actual tariff classification for each product line, and treat any item that is properly classified under a listed wood, rubber or leather heading as in scope on its own terms, on whichever application date applies to a business your size.

How to actually confirm your classification

Do not rely on a supplier's product description or your own website copy to decide this. A supplier calling something "bamboo furniture" in a catalogue does not bind a customs authority to that classification if the piece physically contains enough wood, metal or other material to change the answer under the essential-character test. Three steps are worth taking before your application date rather than after a shipment is queried:

  1. Get or confirm the actual CN code your customs broker uses for each product line, not the marketing description. If it is genuinely 9403 82 or 9403 83, you have your answer; anything else needs a closer look at the Annex I wood-furniture codes it might fall under instead.
  2. Where a product is mixed-material and the classification is not obvious, a Binding Tariff Information ruling from your national customs authority gives you a decision you can rely on and show a competent authority if asked, rather than your own interpretation of the essential-character test.
  3. Keep the classification evidence with your product records, alongside whatever you already retain for the items in your range that are genuinely in scope. A note of how and why a product was classified out of Annex I costs little to keep and is exactly what a border check or a competent authority enquiry will ask for first.

None of this is EUDR-specific paperwork — it is ordinary customs classification practice that happens, in this case, to also settle your regulatory position. Businesses that already have a customs broker or a compliance function handling tariff classification have most of what they need already; the gap is usually that nobody has connected that classification work to the EUDR question explicitly.

Check whether your specific product range is in scope rather than relying on a general rule about the material it is best known for.

General information about Regulation (EU) 2023/1115 as amended, not legal advice. EUDR scope is determined by customs (CN) code — confirm your own classifications before acting on this. Checked against primary sources on .

Questions

Frequently asked

01Is bamboo furniture covered by the EUDR?

No, not where it is genuinely bamboo furniture. Bamboo is not one of the seven Annex I commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood), and Delegated Regulation (EU) 2026/2102 added a clarifying note confirming that the EUDR's wood category does not extend to bamboo. Furniture classified under CN 9403 82 (furniture of bamboo) was never on the Annex I wood-furniture list in the first place.

02Is rattan furniture covered by the EUDR?

No, for the same reasons as bamboo. Rattan is not an Annex I commodity, is not treated as wood under the regulation, and its own customs heading, CN 9403 83, sits outside the wood-furniture codes that Annex I lists.

03Does it matter that rattan is a type of palm?

No. The Annex I commodity is specifically oil palm, genus Elaeis, grown for palm oil. Rattan belongs to the unrelated genus Calamus. Sharing the word "palm" in everyday usage has no bearing on EUDR scope.

04What if a chair has a wood frame but a rattan or bamboo seat?

It depends on how the finished piece is classified for customs purposes. If the wood frame gives the product its essential character under the standard classification test, the whole piece can be classified as wooden furniture and fall inside Annex I, regardless of the bamboo or rattan content. Get the actual tariff classification for the specific product rather than assuming the woven material decides it.

05Does bamboo flooring bonded with resin bring in the rubber commodity?

No. Annex I's rubber entry covers natural rubber from Hevea brasiliensis specifically, not synthetic resins or adhesives. A small proportion of bonding resin in bamboo flooring or panels does not pull the product into scope on rubber grounds.

06Do I need to keep any records for products that are out of scope because they're bamboo or rattan?

The EUDR itself does not require due diligence records for products outside its scope. In practice, keep a note of how you classified each product and why, since a competent authority can ask you to justify an out-of-scope claim, particularly for a product category that only became an explicit written exclusion in 2026.

07When did the bamboo and rattan clarification take effect?

Delegated Regulation (EU) 2026/2102 entered into force on 18 September 2026. For bamboo and rattan specifically this is a clarification of scope that was never caught, so the effective date has limited practical consequence — it did not change which bamboo or rattan products you can place on the market, only how explicitly the regulation states the position.

08Where can I check whether my specific product is in scope?

Use the EUDRCheck tool at /check, which works from your actual product description and materials rather than a general rule about bamboo or rattan.

References

Sources

  1. [1]Regulation (EU) 2023/1115 on deforestation-free products (EUR-Lex)
  2. [2]European Commission — EUDR: Commission adopts Delegated Act on the product scope and Implementing Act on the Information System
  3. [3]EU Deforestation Regulation: Delegated and Implementing Acts Adopted (Ropes & Gray)
  4. [4]EUDR Annex I Update: Delegated Regulation (EU) 2026/2102 (Polygon One)
  5. [5]EUDR Used Products and Bamboo Now Out of Scope (Wood Central)
  6. [6]EUDR simplification: what it means for wood and rubber (FSC International)
  7. [7]EUDR-relevant HS codes based on Annex I (Prewave help centre)
  8. [8]The amended EUDR: what has changed and what has remained? (Stibbe)
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