HUŞ KAPLAMARotary-cut birch veneer from Russia

What EUDR is: what changes for wood exporters

EUDR is EU Regulation 2023/1115, which requires proof that wood products placed on the EU market are not linked to deforestation; its application has been deferred to 30 December 2026. The real novelty is documenting, by geographic coordinates, the exact land plot the raw material was cut from — location, not a chain of documents. For a Turkish producer selling into the EU, that is a direct supply chain problem. For Russian-origin wood it is not a separate lock: Annex XXI of Regulation 833/2014 has prohibited the import of Chapter 44 wood of Russian origin into the EU since 10 July 2022. If you do not sell into the EU, EUDR does not apply to you.

Why this page is here

Explaining EU legislation on a site that sells Russian birch veneer may look odd at first. The reason is this: some Turkish wood producers export to the EU, and when those two lines of business get mixed, the outcome suits neither the supplier nor the buyer.

So we set the subject out as it stands rather than as a sales argument — and we say it up front: Russian-origin raw material is not suitable for a production line that exports to the EU.

What EUDR introduces

Regulation: (EU) 2023/1115, the EU Deforestation Regulation. Date of application: 30 December 2026 (deferred twice). Scope: wood (all of Chapter 44 and part of Chapter 94), soy, palm oil, cocoa, coffee, rubber, cattle.

The substantive change fits in one sentence: what is now demanded is coordinates, not paperwork.

EUTR (995/2010)EUDR (2023/1115)
The question it asksWas it harvested legallyWhich plot was it cut from, and was that plot deforested
Form of proofChain of documentsGeographic coordinates of the land plot
Reference date31 December 2020
Obligated partyEU operatorEU operator
PenaltyAt member state discretionIncluding fines of up to 4% of EU turnover

Russian-origin material: the prohibition that predates EUDR

Where sales into the EU are concerned, EUDR is in fact the second obstacle. The first is sanctions legislation:

  • Regulation 833/2014, Annex XXI: import into the EU of Chapter 44 wood products of Russian origin has been prohibited since 10 July 2022.
  • Rule of origin: processing in Turkey does not change the origin. Plywood made in Turkey from Russian veneer contains an input of Russian origin as far as EU customs is concerned.
  • Plus a trade defence measure: Regulation 2024/1287 applies a 15.8% anti-dumping duty to plywood from Turkey, irrespective of origin.

So for a Turkish producer selling plywood into the EU the picture has three layers: the sanctions prohibition, the anti-dumping duty, and EUDR from 30.12.2026. The three stacked on top of one another make the “into the EU via Turkey” model structurally unworkable.

If you sell outside the EU

For the Turkish domestic market, the Middle East, North Africa, the CIS and other non-EU markets, EUDR creates no obligation. Two practical recommendations even so:

  1. Keep stock separated by origin. If you later consider selling into the EU, you will not be able to extract clean origin from mixed stock. Separation is the one step that cannot be taken retroactively.
  2. Keep the documents. Certificate of origin, contract and shipping documents — you may need to show years later which batch came from where.

Where certificates sit in this picture

DocumentIts value under EUDR
FSC / PEFCDoes not replace the geolocation statement; a supporting element at most. FSC has been suspended for Russia since 08.04.2022
Russian “Lesnoy Etalon” (Forest Standard) schemeHas no equivalent in EU law. Usable outside the EU as an indicator of legal harvest
Certificate of originNecessary but not sufficient — it shows a country, not a plot
Phytosanitary certificateA different subject entirely: plant health, not deforestation

Our own certification position, and the claims we do not make, are on the about page.

Summary

  • If you sell into the EU: Russian-origin raw material is not suitable — because of sanctions legislation, before EUDR even enters the picture.
  • If you do not sell into the EU: EUDR does not apply to you, but keep your stock separated by origin.
  • Either way: the date and the scope are still moving, so verify the text in force with your own importer.
FAQ

Frequently asked questions

What is EUDR?

The EU Deforestation Regulation, (EU) 2023/1115. It requires proof that wood, soy, palm oil, cocoa, coffee, rubber and cattle products placed on the EU market come from land that was not deforested after 31 December 2020. For wood it covers the whole of Chapter 44 and part of Chapter 94.

When does EUDR take effect?

The date of application has been deferred to 30 December 2026; it was originally planned for the end of 2024 and has been pushed back twice. In May 2026 the Commission also put forward a simplification package. Both the date and the scope of the obligations are still moving — if you sell into the EU, verify the text in force together with your own importer.

What is the difference between EUDR and EUTR?

EUTR (995/2010) required legal harvest and was proven through a chain of documents. EUDR looks at the land itself: the plot the material was cut from must be declared by geographic coordinates, and that plot must be shown not to have been deforested after 31.12.2020. Proof of location rather than proof on paper — that changes supply chain traceability in kind, not just in degree.

Does it bind me as a Turkish producer?

The directly obligated party is the EU operator placing the product on the EU market. But that operator will ask you for the geolocation data and the due diligence information. So if you sell into the EU, the obligation reaches you through the contract. If you do not sell into the EU — domestic Turkey, the Middle East, North Africa, the CIS — EUDR does not apply to you.

Is Russian-origin veneer a problem under EUDR?

If you intend to sell into the EU, yes, but for a reason that predates EUDR: Annex XXI of Regulation 833/2014 has prohibited the import into the EU of Chapter 44 wood products of Russian origin since 10.07.2022. Processing in Turkey and re-exporting does not change the origin. EUDR adds a second, independent lock to that picture: once plot coordinates are requested, origin cannot be concealed.

What should I do if I do not sell into the EU?

You have no obligation under EUDR. Even so, it makes sense to keep your production lines and your stock separated by origin: if you later consider selling into the EU, you will not be able to extract clean origin from mixed stock. Separation is the one thing that cannot be done retroactively.

Does an FSC certificate deliver EUDR compliance?

No. FSC and PEFC are voluntary certification schemes and they do not replace the geolocation statement EUDR requires; at most they support due diligence. FSC has in any case been suspended for companies operating in Russia since 08.04.2022.

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Author: Andrey, Turkey representative, HUŞ KAPLAMA · Published: · Updated: