EUDR for construction timber, sawn lumber and decking

Construction timber, sawn lumber and decking are in EUDR scope under CN headings 4407 and 4409, and because both headings were already covered by the EU Timber Regulation, there is no later small-business date: every importer, sawmill and builders' merchant placing these products on the EU market faces 30 December 2026, whatever their size.

Which products this covers

"Construction timber" is not a CN category in its own right, so scope runs through two headings that between them capture most structural and decking timber:

CN heading	Covers	Typical construction products
4407	Wood sawn or chipped lengthwise, sliced or peeled, exceeding 6 mm thick, whether or not planed, sanded or finger-jointed	Structural softwood (studs, joists, rafters), sawn hardwood sections, rough-sawn decking boards before profiling
4409	Wood continuously shaped along any edge, end or face (tongued, grooved, rebated, chamfered, V-jointed, beaded or moulded), whether or not planed or sanded	Profiled decking boards, skirting, architrave, cladding, flooring strip, construction mouldings

A few products sit just outside this pair and belong to a different conversation: wood-based panels used in construction (OSB sheathing, structural plywood) fall under 4410–4413, which our panel importers' guide covers, and builders' joinery such as finished doors, window frames and shuttering sits under CN 4418. If you deal in more than one of these, you need a due diligence position for each heading you place on the market, not one blanket assessment.

Why there is no 2027 date for this sector

Regulation (EU) 2025/2650, which postponed the EUDR's general application, gave micro and small operators until 30 June 2027 — but it explicitly withheld that extension from products that were already inside EU Timber Regulation (EUTR) scope. Sawn timber and continuously-shaped wood were EUTR products from the outset, so the carve-out never applied to them.

Operator size	Product	Application date
Large and medium	Sawn timber, decking, mouldings (4407, 4409)	30 December 2026
Micro and small	Sawn timber, decking, mouldings (4407, 4409)	30 December 2026
Micro and small	Non-timber Annex I commodities (e.g. cocoa, coffee, soya)	30 June 2027

A small builders' merchant importing structural softwood on the assumption that a headcount under 50 buys an extra six months is working from the wrong rule. The same point applies to the furniture sector for the same reason — see our guide to furniture and timber importers after the Timber Regulation repeal — and it is worth checking if you supply both.

Treatment, grading and finishing don't change scope

Pressure treatment, kiln drying, planing, sanding and strength grading are all explicitly allowed under the 4407 and 4409 headings' own wording ("whether or not planed, sanded or finger-jointed"), and none of them takes a product out of scope or changes which obligation applies. A tanalised decking board is still a 4409 product; a graded C24 structural stud is still a 4407 product. What determines your due diligence burden is the wood's species and the plot it was harvested from, not what happened to it afterwards in a planing mill or treatment plant.

This matters in practice because treatment and grading often happen at a different site, sometimes in a different country, from the sawmill that first cut the timber. The geolocation and legality evidence has to trace back to the harvest plot, not to wherever the board was last treated or graded — confirm with your supplier which stage they are actually reporting on.

What you need before you can file

The due diligence obligation for sawn and shaped construction timber does not differ in substance from any other Annex I wood product:

1. Species and country of harvest for every batch, since a single delivery of "spruce" can draw on multiple countries across a season.
2. Geolocation of the harvest plot or plots — points for plots under 4 hectares, polygons above that — collected from the sawmill or forest supplier, covered in more detail in our geolocation requirements guide.
3. Evidence the timber is deforestation-free after 31 December 2020, and that harvest was legal under the laws of the country of origin.
4. A risk assessment informed by the country's benchmarked risk category under Implementing Regulation (EU) 2025/1093 — standard, low or high — with mitigation measures where the country or supplier is not low-risk.
5. A Due Diligence Statement filed through TRACES before the timber is placed on the market, which our step-by-step TRACES guide walks through.

Where you buy sawn timber from an EU-based merchant who has already filed, you hold the role of downstream trader and keep that statement's reference number rather than filing your own. Confirm this in writing with your supplier — the obligation sits with whoever first placed the timber on the EU market, and assuming someone else carries it is not a defence if they did not.

Certification helps the risk assessment, not the filing

FSC or PEFC chain-of-custody certification on structural timber or decking is solid supporting evidence that sourcing is controlled and traceable, and it will usually strengthen a low-risk mitigation case. It does not substitute for geolocation data or the statement itself — a certified sawmill that cannot provide harvest-plot coordinates still leaves you unable to file. Our certification guide sets out exactly what certification can and can't carry for you.

The July 2026 Annex I update didn't touch this sector

Delegated Regulation (EU) 2026/2102, which came into force in September 2026, removed some products from Annex I (cattle hides, re-treaded tyres, vehicle seats among them) and added others on a later 30 December 2027 date (soluble coffee, frozen cattle tongues, further palm oil derivatives). CN headings 4407 and 4409 were not among either list. If sawn timber and decking are your only products, that change doesn't move your date or your scope — our guide to the 2026/2102 Annex I changes covers what actually moved, for anyone handling a mixed product range.

Questions construction timber importers actually ask

Does pressure-treated or tanalised decking need the same due diligence as untreated timber? Yes. Treatment happens after harvest and does not change the CN classification or the obligation. You still need geolocation and legality evidence back to the harvest plot, gathered from the sawmill rather than the treatment plant if they are different sites.

My decking boards are planed and end-matched after import — does that make me the operator? No, by itself. If you buy already-imported boards from an EU supplier and only finish or profile them domestically, you are likely downstream of whoever first placed the sawn timber on the market. If you import rough-sawn boards directly and finish them yourself, you are the operator for that batch.

Do micro and small builders' merchants get until June 2027? No, not for sawn timber, decking or mouldings under CN 4407 or 4409. Both headings were already within EU Timber Regulation scope, so every operator size faces 30 December 2026.

Is structural plywood covered by this guide or the panel guide? Structural plywood sheathing sits under CN 4412, with panel products generally — see our plywood and wood panel guide. This guide covers sawn and continuously-shaped solid timber under 4407 and 4409.

Does FSC certification on my timber mean I don't need geolocation data? No. Certification supports your risk assessment but is not a substitute for geolocation coordinates or the Due Diligence Statement itself.

What happens if my sawmill won't give geolocation data for the harvest plot? You cannot file a valid Due Diligence Statement without it, which means you cannot lawfully place that timber on the EU market from 30 December 2026. That makes supplier transparency a sourcing decision to resolve now, not something to chase once the deadline is close.

Did the 2026 Annex I changes add any new construction timber products? No. Delegated Regulation (EU) 2026/2102 added soluble coffee, frozen cattle tongues and further palm oil derivatives, and removed items including cattle hides and re-treaded tyres. Sawn and shaped timber headings were untouched.

We import timber for construction use but also sell offcuts as firewood — does that change anything? No. Scope runs by CN code at the point you place the product on the market, not by the end use your customer puts it to. Offcuts sold as firewood sit under a different heading (4401) with its own obligations if that is a meaningful share of your business.

Confirm your own scope

Sawn and shaped construction timber has no later date to fall back on, which makes an early supplier audit — species, origin country, and whether your sawmill can actually produce plot-level geolocation — the single highest-value step before the end of 2026.

Check which EUDR obligations apply to your construction timber and get a dated plan for the sawmills and merchants you need to assess first.