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EUDR Explained: What UK Home & Gift Businesses Need to Know About Selling into Europe
HGA Takeaway | International Trade
EUDR Explained: What UK Home & Gift Businesses Need to Know About Selling into Europe
New EU deforestation rules are changing the requirements for certain products sold into Europe. Here's what they mean for Home & Gift businesses, how to identify affected products and how to make compliance as straightforward as possible.
If your business sells products into Europe, there's an important piece of legislation you need to be aware of.
The EU Deforestation Regulation, better known as EUDR, introduces new requirements designed to prevent certain products linked to deforestation from entering or being traded within the European Union.
For the Home & Gift industry, this could affect businesses selling wooden gifts, furniture, paper products, stationery, chocolate, coffee and other products containing specified commodities.
But before you start worrying about mountains of paperwork, there's something important to understand.
Not every product is covered, and not every business has the same responsibilities.
The key is understanding which products fall within the rules, who is responsible for compliance and what information you may need to provide to your European customers.
The HGA's advice? Start with your products, not the paperwork. Establish what's actually covered before investing time or money in compliance systems.
Understanding EUDR
What exactly is EUDR?
EUDR is the European Union's Regulation on Deforestation-free Products.
Its aim is to reduce the EU's contribution to global deforestation and forest degradation by ensuring that certain commodities and products traded within the EU meet specific environmental and legal requirements.
The legislation covers seven commodities:
Wood
Cocoa
Coffee
Oil palm
Rubber
Soy
Cattle
It also covers certain products made from these commodities, specifically those listed in Annex I of the Regulation.
For a covered product to be placed on the EU market, the applicable requirements include demonstrating that it:
1. Is deforestation-free, meaning the relevant commodities were not produced on land deforested after 31 December 2020.
2. Was produced in accordance with relevant legislation in the country of production.
3. Is covered by the required due diligence statement or, where applicable, a simplified declaration.
For wood products, the deforestation-free requirement also addresses forest degradation after 31 December 2020.
Important: EUDR doesn't apply to every product simply because it contains wood, paper, cocoa or another relevant material. The product must fall within the categories specified in Annex I.
Important deadlines
When do businesses need to comply?
The EU has delayed implementation and introduced simplifications to give businesses additional preparation time.
30 December 2026
The main application date for large and medium operators. It also applies to micro and small operators handling products covered by the previous EU Timber Regulation.
30 June 2027
The later application date for eligible micro and small operators, subject to the Regulation's conditions. This includes the requirement that the undertaking was established as micro or small by 31 December 2024.
30 December 2027
The application date for products newly added to the scope by the September 2026 amendment, including certain palm oil derivatives and soluble coffee.
For UK businesses: Don't assume that being a small company automatically gives you until June 2027.
The relevant date depends on the operator's legal status, when it was established, the products involved and its position in the supply chain.
European customers may also request supporting information well before the relevant deadline so they can prepare their own compliance processes.
Source: European Commission, EUDR implementation timetable and Regulation (EU) 2025/2650.
Home & Gift products
Which products should our industry be checking?
This is arguably the most important question for Home & Gift businesses.
EUDR uses customs classifications to determine which products are covered. These are known as HS or CN codes.
That means two products made from similar materials may be treated differently depending on their classification.
The following categories are worth reviewing.
Wooden gifts and home accessories
Certain wooden ornaments, decorative objects, kitchenware, picture frames, jewellery boxes and other wooden products may fall within EUDR.
What to check: Whether the finished product falls within a relevant wood product classification in Annex I.
Furniture
Certain wooden furniture and furniture components are specifically included within the Regulation.
Products made from several materials should be assessed using their correct customs classification rather than assuming the presence of wood automatically makes them covered.
Paper, card and stationery
Certain paper and paperboard products are covered, including specified products classified under Chapter 48.
However, the scope of printed products has changed, and not every greeting card, notebook, calendar or stationery product should automatically be treated as covered.
What to check: The exact commodity code against the updated Annex I. If you're unsure about classification, seek advice from a customs specialist.
Packaging and gift boxes
Certain paper, cardboard and wooden packaging products are covered when sold or supplied as products in their own right.
However, packaging used solely to support, protect or carry another product can be excluded.
This distinction is particularly relevant to businesses selling gift boxes, presentation packaging and packaging supplies.
Food gifts
Coffee, cocoa and certain chocolate products fall within EUDR.
Businesses selling food hampers, chocolate gifts or coffee-based products should check the classification of the individual products involved.
Candles, ceramics and other gifts
Products such as ceramic ornaments and ordinary candles aren't automatically covered simply because they're sold within the Home & Gift industry.
However, businesses should still check the finished product's classification, particularly where it contains relevant materials or falls within a specifically listed product category.
The golden rule: Check the finished product's customs code against the latest Annex I before deciding whether EUDR applies.
Exemptions and exclusions
Where businesses may be able to avoid unnecessary paperwork
The September 2026 amendments clarified several exclusions that are particularly relevant to Home & Gift businesses.
Packaging used to protect another product
Packaging used exclusively to support, protect or carry another product, rather than being supplied as a commercial product in its own right, can fall outside EUDR.
For example, a cardboard shipping box used to transport a ceramic vase is treated differently from cardboard boxes sold separately as merchandise.
However, packaging sold as a product in its own right may still be covered.
Products made entirely from qualifying recycled materials
Products made entirely from materials that have completed their lifecycle and would otherwise have been discarded as waste can fall outside EUDR.
However, manufacturing by-products aren't automatically treated as qualifying waste, and products containing virgin material require further assessment.
A product being described as recycled or sustainable doesn't, by itself, establish that it qualifies for an exclusion.
Used and second-hand products
The updated rules provide exclusions for specified used and second-hand products.
Businesses should check the conditions rather than assuming every product described as vintage or second-hand is automatically exempt.
Bamboo and rattan
Bamboo and rattan products can fall outside the wood-related product scope, as reflected in UK Government guidance.
However, mixed-material products should still be checked against their correct customs classification and the full list of covered products.
Samples and testing materials
The updated product scope also includes exclusions for qualifying product samples and products used for examination, analysis or testing.
Don't assume an exemption applies without checking
If you're relying on an exclusion, keep a short record explaining why it applies, including the relevant product classification and supporting evidence.
UK exporters
Does a UK business have to submit an EUDR declaration?
Not necessarily.
EUDR does not generally apply to products placed solely on the Great Britain market.
However, businesses exporting covered products into the EU need to understand who is legally responsible for placing those products on the EU market.
For many UK suppliers, the main practical responsibility will be providing information to their European customers.
Scenario 1: You sell to an EU importer
Where an EU business imports your covered products and acts as the operator, that business will generally be responsible for the applicable EUDR due diligence requirements.
However, the importer may need detailed information from you, including information about where the relevant commodities originated.
Scenario 2: You sell directly to EU customers
Direct sales, including online sales, require closer examination of who is legally placing the goods on the EU market.
The fact that a business is established outside the EU does not automatically remove EUDR responsibilities from the transaction.
Businesses should establish the operator's identity and the arrangements for customs clearance and due diligence before shipping affected products.
Scenario 3: You sell through an EU distributor
The distributor's responsibilities depend on whether it is the first business placing the covered product on the EU market or is acting further down the supply chain.
It's worth agreeing exactly what information needs to be supplied, who will submit any required declaration and how supporting records will be shared.
Even if your European customer is responsible for the declaration, your business may still need to provide the traceability information that allows them to comply.
Understanding due diligence
What information might your European customers need?
For operators responsible for full EUDR due diligence, the process involves gathering information, assessing risk and, where necessary, reducing that risk to a negligible level.
Depending on the product, relevant information includes:
Product details
The product description, customs classification and relevant quantities.
Country of production
Where the relevant commodity was actually grown, harvested or produced.
Geolocation
Information identifying the plots of land where the relevant commodity was produced.
Production dates
Relevant dates or production periods.
Supplier information
Details of relevant suppliers and businesses in the supply chain.
Evidence of compliance
Supporting information showing that the relevant products meet the deforestation-free and legal production requirements.
What is geolocation?
Geolocation identifies the land where the relevant commodity originated.
For example, if a wooden gift is made from timber, the operator may need information identifying where the timber was harvested.
This can become more complicated where materials are sourced from multiple locations or pass through several suppliers before reaching the manufacturer.
That's why businesses should start gathering information early rather than waiting until an order is ready to ship.
One important distinction
A supplier's statement that a product is sustainable or deforestation-free is not automatically sufficient evidence for a business with full EUDR due diligence obligations.
Making compliance easier
How can businesses make the process more manageable?
EUDR can involve a considerable amount of information, particularly where supply chains are complicated.
However, there are practical ways to reduce unnecessary administration.
1. Start with a simple product spreadsheet
List the products you sell into Europe, their commodity codes, materials, suppliers and whether they appear to be covered by EUDR.
Add a column for exemptions or exclusions, together with the reason for your conclusion.
2. Agree responsibilities with your European customers
Find out who will act as the operator and what information they require from you.
Agree a consistent format for sharing that information so you aren't responding to different requests for every shipment.
3. Create one standard supplier questionnaire
Use a consistent information request for suppliers of affected products.
This could cover the product classification, relevant commodities, country of production, available traceability information and supporting documentation.
4. Keep supporting documents together
Create a central folder for relevant supplier information, traceability records, supporting evidence and any due diligence reference numbers received.
Make sure records can be linked to the relevant products and batches.
5. Reuse information where legally permitted
The rules allow a due diligence statement to cover multiple shipments or batches where the statement accurately covers the relevant products and all applicable requirements are met.
This can reduce repetitive administration, but the underlying traceability and due diligence information must remain accurate.
6. Don't buy software before understanding your obligations
Some businesses may benefit from specialist traceability or compliance software, particularly where they handle large numbers of affected products or complex supply chains.
However, smaller businesses supporting an EU importer may be able to begin with organised spreadsheets, supplier records and a clear information-sharing process.
Different responsibilities
Does every business have to complete full due diligence?
No.
The EU has introduced simplifications intended to reduce unnecessary duplication within supply chains.
However, the exact obligations depend on a business's role.
Operators
Businesses first placing covered products on the EU market, or exporting covered products from the EU, generally have the main due diligence responsibilities.
These include collecting required information, assessing and mitigating risk where applicable, and submitting a due diligence statement before placing products on the market or exporting them.
Micro and small primary operators
A specific simplified regime applies to qualifying micro and small primary producers established in low-risk countries.
Eligible businesses can use a simplified declaration rather than the standard due diligence statement process.
Important: This category is not the same as every small business. A small retailer or importer does not automatically qualify as a micro or small primary operator.
Downstream operators and traders
Businesses handling products that have already been placed on the EU market under the relevant EUDR procedures benefit from reduced obligations.
They generally do not need to repeat the original operator's full due diligence process, but must meet the applicable record-keeping, information-sharing and other requirements for their role.
Additional registration obligations can apply to certain larger downstream businesses.
The key point: Don't assume every business handling the same product must independently complete the same due diligence process.
Establish your role first, then identify the obligations that apply to you.
Certification
Does FSC or PEFC certification guarantee compliance?
No.
Certification schemes such as FSC and PEFC can provide useful supporting information about responsible sourcing and supply chain traceability.
However, certification alone does not automatically demonstrate that a product meets every EUDR requirement.
Businesses with full due diligence obligations must still meet the applicable legal requirements, including gathering the necessary information and assessing risk where required.
Certification can help, but it isn't a shortcut
If your suppliers hold relevant certifications, ask what supporting traceability information they can provide. This may help with compliance, but it should not be treated as a substitute for the legal requirements.
Country risk
Can sourcing from a low-risk country make compliance easier?
Yes, in certain circumstances.
The European Commission has introduced a country benchmarking system that classifies countries as low, standard or high risk.
Eligible operators sourcing commodities produced in low-risk countries may benefit from simplified due diligence.
This can remove the routine requirement to conduct a full risk assessment and risk mitigation where the conditions are met.
However, businesses must still collect the required information and respond appropriately if they become aware of a risk of non-compliance.
It's also important to distinguish between the country where a finished product was manufactured and the country where the relevant commodity originated.
For example, a wooden ornament manufactured in the UK using timber harvested elsewhere may need to be assessed using the timber's country of production.
Useful to know
The UK is currently classified as a low-risk country under the EU's country benchmarking system. However, this does not automatically make every product manufactured in the UK eligible for simplified due diligence.
Northern Ireland
What about businesses trading with Northern Ireland?
EUDR will apply in Northern Ireland, but not directly to products placed solely on the Great Britain market.
This means businesses moving covered products between Great Britain and Northern Ireland need to understand the specific requirements for those movements.
Depending on the circumstances, relevant movements may require a due diligence statement reference number or simplified declaration identifier.
Businesses should also check the requirements for the particular movement scheme being used.
The UK Government has published dedicated guidance covering movements between Great Britain, Northern Ireland, the EU and the rest of the world.
Don't assume EU and Northern Ireland movements follow identical procedures
If you supply Northern Ireland retailers, distributors or consumers, check the relevant UK Government guidance before sending affected goods.
Practical action plan
Your EUDR preparation checklist
Not sure where to start? Work through these steps in order.
Step 1: List your European products
Identify everything you currently sell, or plan to sell, into the EU or Northern Ireland.
Step 2: Check commodity codes
Compare your products against the latest Annex I and identify those that are covered, excluded or require further investigation.
Step 3: Establish your role
Confirm who is legally placing each affected product on the EU market and who is responsible for the required due diligence.
Step 4: Contact your suppliers
Request relevant information about the origin of covered commodities and the traceability evidence available.
Step 5: Speak to your European customers
Agree what information they need and how it will be supplied.
Step 6: Organise your records
Keep supporting documentation together and make sure it can be linked to the relevant products and shipments.
Step 7: Check whether you need to use the EU Information System
If your role requires a due diligence statement, simplified declaration or registration, familiarise yourself with the official system.
Step 8: Keep your information updated
Review records when products, suppliers, sourcing locations or other relevant circumstances change.
Ready to use
A simple email to send your suppliers
Here's a straightforward starting point for businesses gathering information about affected products.
Subject: EUDR information request
Hi [Name],
We're currently reviewing our products in preparation for the EU Deforestation Regulation (EUDR), which introduces traceability and due diligence requirements for certain products sold into Europe.
Could you please help us establish whether any of the products you supply to us fall within the Regulation?
For any affected products, it would be helpful if you could provide:
• Product descriptions and relevant commodity codes, if available.
• Details of the relevant materials or commodities used.
• The country where those commodities were produced or harvested.
• Any available traceability information, including geolocation data where applicable.
• Supporting documentation relevant to EUDR compliance.
If you already have an EUDR compliance process in place, please let us know what information you can share and whether any due diligence statement reference numbers are available for the relevant products.
Many thanks for your help!
The HGA Takeaway
EUDR is important, but compliance starts with understanding what actually applies to your business
1. Not every Home & Gift product is covered. Check commodity codes and exclusions first.
2. Understand who is responsible for placing your products on the EU market.
3. Start gathering supplier information early, particularly where materials come from several sources.
4. Don't assume FSC, PEFC or a supplier declaration automatically establishes compliance.
5. Keep records organised and make it easy to share information with your European customers.
6. Use the simplified procedures available to your business, but make sure you genuinely qualify.
Official guidance and useful resources
The following resources are published by the European Commission, the EU or the UK Government.
European Commission: EUDR overview
Read the official EUDR guidance
European Commission: Frequently Asked Questions
Read the official FAQs
EU legislation: Regulation (EU) 2023/1115
Read the original EUDR legislation
EU legislation: September 2026 product scope amendment
View the updated product scope
European Commission: Country risk classifications
Check the country risk list
UK Government: Northern Ireland EUDR guidance
Read the UK Government guidance
A quick note
This article provides general information based on official EU and UK Government guidance available in October 2026. EUDR requirements depend on the classification of individual products, supply chain arrangements and the legal responsibilities of the businesses involved. The information should not be treated as legal or customs advice. Businesses should consult the latest official guidance and seek specialist advice where necessary.
One thing to do this week
Take your ten bestselling products in Europe and check their commodity codes against the EUDR product list.
It's a simple first step that will help you understand whether EUDR is likely to affect your business and where you should focus your attention.