As a joiner, cabinetmaker or furniture manufacturer you place finished products on the market – but whether you have to file your own due diligence statement for them depends, under the EU Deforestation Regulation (EUDR), on whether your timber is already covered. Since the December 2025 amendment: anyone who makes products from timber that is already covered is a downstream operator and files no statement of their own. Anyone who imports their own timber or processes timber that is not yet covered is the operator placing it on the market for the first time, with full due diligence.
Your role in the supply chain
What matters is not that you make a new product, but whether the timber used for it is already covered by a due diligence statement. That gives rise to three typical cases:
- Covered sawn timber from a sawmill or wholesaler (with a reference number): you are a downstream operator – no statement of your own; you manage the reference numbers and pass them on.
- Timber you import yourself (e.g. tropical timber direct from a third country): you are the operator placing it on the market for the first time – full due diligence with geolocation data, risk assessment and your own statement. Tropical timbers usually come from countries with standard or high risk, so additional evidence is required.
- Buying directly from a forest owner who is not yet registered: small forest owners are only obligated from mid-2027, or simply have not recorded anything yet – then your timber is not covered and you effectively become the first-placer operator, gathering the origin data and filing the statement yourself.
Smaller workshops almost always count as SMEs and in the downstream role carry the fewest obligations – as an SME they do not even have to register in TRACES. But the relief only applies where someone else has already covered the timber.
Why almost every workshop needs a system: All three cases involve work – in the downstream case you have to collect, check and pass on reference numbers (and without a valid reference no delivery may be processed and sold), in the first-placer case you have to gather geolocation data, assess the risk and file the statement. Especially when buying in from small forest owners, the effort often falls to you, because the supplier delivers nothing themselves.
Your obligations
Always – regardless of your role:
- Document the timber origin per batch: supplier, species, quantity and – for covered timber – the reference number of the supplier's statement.
- Collect and file supplier invoices and certificates (FSC, PEFC).
- When passing on (for example to the furniture trade): hand over the reference number with the delivery note.
- Keep all records digitally for five years.
Additionally, if you are the first-placer operator (self-import or timber not yet covered):
- Gather the geolocation coordinates of the harvest area and legality evidence.
- Assess the deforestation and legality risk and mitigate it where necessary.
- File your own due diligence statement via the EU system TRACES NT.
Typical process in the workshop
- Timber order with the sawmill or wholesaler – the statement number is supplied with it.
- Goods intake: the batch is created in the system and linked to the order.
- Processing into furniture: the system connects the timber batch and the bill of materials.
- For covered timber, the reference number is imported and checked; for timber you import yourself or that is not yet covered, your own due diligence statement is created and submitted via TRACES NT.
- The customer document contains the statement number for the next stage in the chain.
Practical tip: Start collecting the statement references of your timber suppliers today – even if your deadline only takes effect in 2027. That way you avoid a delivery sitting with you without any proof. How to fill in a statement is shown in the article Completing a due diligence statement – step by step.
What the software must do
- Material master record with species, batch and supplier
- Record, check and pass on reference numbers to customers
- Link between bill of materials and order
- Certificate management (FSC, PEFC)
- Geolocation and risk checks for timber you import yourself or that is not yet covered
- Your own due diligence statement with TRACES NT integration if you are the first-placer operator
- Authority file at the push of a button and a five-year archive of all records
Deadlines for joiners & cabinetmakers
| Business size | Obligation from |
|---|---|
| Larger businesses | 30 December 2026 |
| Small and medium-sized enterprises (SMEs) | 30 December 2026* |
* Important for the timber sector: Under Art. 38(3) the extended deadline of 30 June 2027 – only for natural persons, micro and small undertakings established as such on 31 December 2024 – only applies to products that were not already covered by the old Timber Regulation (EUTR). Roundwood, sawn timber, panels and furniture were covered by the EUTR – for these the 30 December 2026 applies regardless of company size.
Even though most joinery and cabinetmaking businesses are SMEs: for timber and furniture the 30 December 2026 applies, because these products were already covered by the old Timber Regulation (EUTR). Use the time to record your suppliers and certificates cleanly. The simplifications the EU recently adopted are explained under EU simplifications to the EUDR.
Submission via an authorised representative
You do not have to submit the statement yourself. Under Art. 6, natural persons and micro-enterprises may appoint an authorised representative to submit on their behalf – typically the next buyer, such as the sawmill or trader you already work with.
For the representative the effort stays manageable: they can submit for many principals from a single account. Responsibility for the accuracy of the information remains with you; only the technical handling is delegated.
Frequently asked questions
Must a joiner file its own due diligence statement?
It depends on where the timber comes from. If you process sawn timber that your supplier has already placed on the market with a due diligence statement, you have – since the 2025 amendment – been a downstream operator and only pass on the reference numbers, without your own statement. If you import timber yourself (for example tropical timber) or buy timber that is not yet covered, you are the operator placing it on the market for the first time and must file your own statement via TRACES NT.
Is an FSC or PEFC certificate enough for a joiner?
No. FSC and PEFC do not replace due diligence, but they lower the risk and make the assessment easier. You still have to document the origin and the statement reference of your timber deliveries. Read more under Certificates: FSC, PEFC and FLEGT.
What happens if a supplier does not provide data?
Then you are missing a mandatory record and you may not readily place the finished product on the market. Speak to the supplier early – read more under What to do when your supplier does not cooperate?