Under Regulation (EU) 2023/1115, the EU Deforestation Regulation, wooden toys sit outside the scope of the regulation - and wooden furniture does not. Heading 9503 of the Combined Nomenclature, which covers toys, is not in Annex I. Wooden furniture under 9403 30, 9403 40, 9403 50, 9403 60 and 9403 91 is. Wooden seats under ex 9401 are. A container that carries a toy range and a children's furniture range therefore carries out-of-scope and in-scope goods at the same time, on one invoice.
This page sets out what Annex I lists, where the line falls, and what to collect before a purchase order is confirmed.
What Annex I lists for wood
Annex I lists goods by Combined Nomenclature code under seven relevant commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. These are the wood entries, as published in the Official Journal.
| 4401 to 4406 | Fuel wood and wood chips, wood charcoal, wood in the rough, hoopwood and stakes, wood wool and wood flour, railway sleepers |
| 4407 to 4409 | Sawn wood, veneer sheets, continuously shaped wood including parquet strips |
| 4410 to 4413 | Particle board and OSB, fibreboard, plywood and laminated wood, densified wood |
| 4414 | Wooden frames for paintings, photographs, mirrors and similar objects |
| 4415 | Wooden packing cases, boxes, crates, drums, pallets, box pallets, load boards and pallet collars |
| 4416 to 4418 | Casks, barrels and staves, tool bodies and handles of wood, builders' joinery and carpentry, assembled flooring panels, shingles |
| 4419 to 4421 | Tableware and kitchenware of wood, marquetry and inlaid wood, caskets, statuettes and ornaments, other articles of wood |
| Chapters 47 and 48 | Pulp and paper, except bamboo-based and recovered waste and scrap |
| ex 49 | Printed books, newspapers and other printed products of paper |
| ex 9401 | Seats of wood, whether or not convertible into beds, and parts of them |
| 9403 30, 9403 40, 9403 50, 9403 60, 9403 91 | Wooden furniture and parts of wooden furniture |
| 9406 10 | Prefabricated buildings of wood |
Chapter 95 is not in that list. A wooden toy that is correctly classified in heading 9503 is not a relevant product, and the obligations in the regulation do not attach to it.
Why toys are out and furniture is in
The regulation works from the customs code, not from the material. Two products cut from the same beech board can sit on opposite sides of the line: a stacking toy declared in 9503, and a children's table declared in 9403 60. The timber is identical and the classification decides. That is why the useful first question is not whether a product is wooden, but which heading it will be declared under.
Three cases where a toy order still meets EUDR
1. Wooden furniture and wooden seats in the same shipment
Children's tables and chairs, storage units, play units built as furniture and doll house furniture classified in Chapter 94 are relevant products even when they ship alongside toys. The obligation follows the item, not the container.
2. Wooden packaging and pallets
Entry 4415 covers wooden pallets, box pallets, load boards, pallet collars, crates, boxes and drums. Annex I then adds an explicit carve-out: packing material used exclusively as packing material to support, protect or carry another product placed on the market is not included. A pallet that only carries your order is treated differently from wood packaging you buy in order to resell it.
3. Items declared in Chapter 44 rather than 9503
Some items bought as wooden toys are declared as general wood articles: wooden ornaments and statuettes fall in 4420, and 4421 is a residual heading for other articles of wood. Both are in Annex I. If an item is classified in Chapter 44 it is a relevant product, whatever the catalogue calls it.
When the obligations start
The European Commission lists the current entry into application as follows.
| Large and medium operators | 30 December 2026 |
| Micro and small operators already covered by the EU Timber Regulation | 30 December 2026 |
| Micro and small operators | 30 June 2027 |
| Products added to scope by Commission Delegated Regulation (EU) 2026/2102 | 30 December 2027 |
The EUDR repeals the EU Timber Regulation. If your business was already covered by the EUTR, the earlier date applies to you, so the later deadline is not a reason to wait.
What to ask a supplier for
Even where the regulation does not apply to an item, this is the paperwork European buyers now request as standard, and it is the same set that satisfies the regulation where it does apply.
- The species of wood in each component, in commercial and Latin names.
- A chain-of-custody certificate number for the mill that supplied the timber, with its validity dates.
- Whether the timber is FSC, PEFC or uncertified, component by component.
- The country and region of harvest.
- The CN heading the factory and its forwarder use for the item.
What we can provide
We are a wooden toy factory in Yunhe, Zhejiang. We hold FSC Chain of Custody certificate ESTS-COC-240650, and we document wood species per item. If your order includes children's wooden furniture or wooden seats, raise it at enquiry stage: those are the lines that need the chain-of-custody record and the harvest origin, and it is easier to collect them before production than after packing.
This page explains how we read the regulation as a supplier. It is not legal advice. Classification is decided by the customs authority in the country of import, so confirm the current Annex I and your own obligations with your customs broker or with the competent authority in the Member State where the goods are placed on the market.
Frequently asked questions
Are wooden toys covered by EUDR?
No, provided the item is classified in CN heading 9503. Heading 9503 does not appear in Annex I to Regulation (EU) 2023/1115, so a correctly classified wooden toy is not a relevant product.
Is children's wooden furniture covered by EUDR?
Yes. Wooden furniture and parts of wooden furniture under CN 9403 30, 9403 40, 9403 50, 9403 60 and 9403 91 are listed in Annex I, as are wooden seats under ex 9401.
Do wooden pallets need EUDR documents?
Annex I covers wooden pallets under 4415, but excludes packing material used exclusively as packing material to support, protect or carry another product placed on the market. Pallets bought to be resold are a different case from pallets that only carry your order.
What if the factory declares the toy under a Chapter 44 code?
Then it is a relevant product. Wooden ornaments fall in 4420 and general wooden articles in 4421, both of which are in Annex I. The CN code decides, not the name on the invoice.
When does EUDR start to apply?
30 December 2026 for large and medium operators and for micro and small operators already covered by the EU Timber Regulation, and 30 June 2027 for other micro and small operators.
Does the EU Timber Regulation still apply?
No. The EUDR repeals the EU Timber Regulation and replaces its obligations from the dates above.
This sits alongside the guides that cover the rest of the compliance file: wooden toy safety standards for EN71 and ASTM F963, and CPSIA and the Children's Product Certificate for the United States. Material choice is covered in wooden toy materials, the manufacturing sequence in the wooden toy production process, and the range affected by the furniture entries on kids wooden furniture.
Source: Regulation (EU) 2023/1115, Official Journal L 150, 9.6.2023, Annex I, page 246. Entry into application dates are taken from the European Commission page on the regulation.
The FSC and due-diligence documents we hold are listed with their dates on our document download page.
The due-diligence file sits with the manufacturer rather than with the brand on the box.
Where timber sourcing meets market rules is covered in rubberwood against beech, and the product-side obligations in CE marking for wooden toys.
Whether a wooden product counts as a toy or as furniture decides which rules apply to it, and the pieces that sit closest to that line are on the kids wooden furniture manufacturer page.