EUDR firewood sellers: in scope even for households

Yes. Selling firewood or logs directly to households rather than through a retailer does not take you outside the EUDR. What matters is whether you are supplying fuel wood in the course of a commercial activity, not who buys it or how small the transaction is. If you place logs, billets or similar fuel wood on the EU market commercially, you face the same 30 December 2026 date as a large timber importer, because fuel wood was already covered by the EU Timber Regulation.

Why selling to households doesn't change anything

The EUDR's due diligence duty attaches to an "operator" — anyone who places a relevant product on the EU market in the course of a commercial activity (Article 2, read with Article 2(19) on what counts as commercial activity). The Commission's own implementation FAQ is explicit that a relevant product is in scope whether it is sold, given away, or supplied "for distribution to commercial or non-commercial consumers" — the status of the buyer is irrelevant to whether the seller owes due diligence.

The EUDR does carve out private use: a household that burns firewood it bought is a consumer, not an operator, and has no EUDR obligations of its own. That protection runs one way. It covers the buyer. It does nothing for the farmer, smallholder or log merchant doing the selling, because they are still acting commercially — cutting, splitting, bagging and selling fuel wood for money is a business activity whatever the buyer does with it afterwards. A local log supplier delivering trailer-loads to nearby houses, a farm diversifying into firewood sales at the gate, or a seller running a stall at a Christmas market are all operators for EUDR purposes if the wood they sell is a relevant product placed on the EU market.

This only applies to the EU market

The EUDR is an EU regulation: it reaches products placed on the Union market, not domestic sales within a country outside the EU. A UK firewood merchant selling only to UK households, with no wood crossing into an EU member state at any point, is outside the EUDR's territorial scope — though separate UK rules on timber legality may still apply, and our comparison of UK deforestation law and the EUDR sets out where those diverge. The moment firewood is imported into an EU member state, or produced and sold within one, the position above applies regardless of the seller's size or how local the sale is.

Which CN code your firewood falls under, and why it matters

Annex I to Regulation (EU) 2023/1115 lists fuel wood under CN heading 4401, which the Combined Nomenclature splits by species at the six-digit level:

CN code	Covers	Was it under the EUTR?	Micro/small deadline
4401 11	Coniferous fuel wood, in logs, billets, twigs, faggots or similar forms	Yes	30 December 2026
4401 12	Non-coniferous fuel wood, in logs, billets, twigs, faggots or similar forms	Yes	30 December 2026
4401 21 / 4401 22	Wood in chips or particles	Yes	30 December 2026
4401 31	Wood pellets	Yes	30 December 2026
4401 32	Wood briquettes	Yes	30 December 2026

Fuel wood in logs and billets was already within the scope of the EU Timber Regulation (EUTR, Regulation (EU) No 995/2010), the law the EUDR replaced. Regulation (EU) 2025/2650 gave micro and small operators an extra six months, to 30 June 2027, but withheld that extension from any product that was already an EUTR product. Firewood falls squarely in that carve-out: a one-person firewood round and a national timber importer face the identical 30 December 2026 date. Size changes what you have to do in practice, not when you have to start doing it. Our wood pellet and biomass guide covers the same CN 4401 mechanism for pellets and chips, and the charcoal comparison in our charcoal and briquette guide shows the one wood-fuel product that does get the later date, and why.

There is no small-quantity exemption

Unlike some environmental regimes, the EUDR has no de minimis threshold based on volume, value or turnover. A smallholder selling a dozen trailer-loads of logs a year is as much an operator as a firewood merchant selling thousands. What changes with size is the deadline — and, as set out above, firewood doesn't even get that — plus some procedural concessions available to micro and small operators sourcing from low-risk countries: a single simplified declaration instead of a statement per batch, and postal codes in place of precise coordinates. Those concessions reduce the paperwork; they do not remove the obligation.

Own-grown firewood is usually easier to document, not exempt

Many direct-to-household sellers are cutting firewood from their own land — farm woodland thinnings, hedgerow management, storm-damaged trees — rather than buying in stock. This changes how hard due diligence is, not whether it applies.

• Geolocation is the plot or plots you own or manage, which you already know precisely. Article 9 requires a single point for plots of 4 hectares or less and a polygon above that; for a farm woodlot this is usually a one-off exercise rather than a live supply-chain problem. Our geolocation guide covers the point-versus-polygon mechanics in full.
• Deforestation-free status means showing the land has not been converted from forest, or degraded, since the cut-off date of 31 December 2020. For a farm that has managed the same woodland for decades, this is usually a straightforward record to assemble — forestry management plans, felling licences and historical imagery typically already exist or are easy to obtain.
• Country of harvest risk still applies. Under Implementing Regulation (EU) 2025/1093, the country your woodland sits in carries a benchmarked risk category, which decides whether you can skip the formal risk assessment and mitigation steps. Our country benchmarking guide sets out what each tier removes.
• The due diligence statement still has to be filed in TRACES before the firewood is placed on the market, even for a single trailer-load. There is no exemption for filing a statement covering a small, regular batch rather than a single large consignment.

The practical upshot: a farm selling its own firewood locally has an easier due diligence job than an importer blending stock from several suppliers, because there is only one plot and one history to document. It does not have a smaller legal obligation.

Imported firewood for direct retail

A different pattern — importing logs from outside the EU and selling them on, perhaps at a farm shop, market stall or direct-delivery round — makes the importer the operator responsible for the due diligence statement, exactly as it would for any other imported Annex I product. If you buy firewood that has already been placed on the EU market by someone else (an EU-based wholesaler who has already filed), you are a downstream trader relying on their statement reference rather than filing your own — but confirm that in writing with your supplier rather than assuming it, because the obligation defaults to you if nobody upstream has actually filed.

Waste wood and storm-damaged timber

Firewood cut from storm-felled trees, dead wood clearance or arboricultural waste is sometimes assumed to fall under the EUDR's exemption for products made entirely from material that has completed its lifecycle and would otherwise be discarded. That exemption is narrow and generally does not cover this situation: a tree felled by storm damage or cleared for safety reasons has not completed a product lifecycle in the sense the exemption requires — it is freshly harvested wood, not reclaimed material recovered after use (the kind of case the exemption is built for is genuinely reclaimed timber, such as demolition wood or pallets at end of life). Treat storm-damaged and arboricultural firewood as in scope unless you can show otherwise.

If you're not sure whether your firewood business is covered

The facts that decide your position — whether the wood is placed on the EU market, whether the sale happens in the course of a commercial activity, and your size — are usually simple to answer for a firewood business, but the conclusion (no size exemption, no small-quantity exemption, no benefit from selling direct to the public) is the opposite of what many sellers assume. Check what the EUDR requires of your specific business to get the deadline and the due diligence steps that actually apply to your firewood or log sales.

What is still unsettled

The Commission's guidance treats fuel wood under CN 4401 11 and 4401 12 as an ordinary Annex I product and has not issued specific guidance for very small-scale or occasional domestic firewood sellers — there is no published simplified pathway beyond the general micro and small operator concessions described above. Treat the general rules as the current position for any firewood business, however small or local.