Importing Timber and Wood Products from the UK – EUDR, Documents and HS44 Classification

Importing timber and wood products from Great Britain to Poland is one of the strategically significant trade flows — the HS44 sector generates over $500 million annually in trade between these two countries. Polish companies import from the UK sawn timber, plywood, chipboard, wooden flooring, furniture and joinery components. Since 2025, however, this trade has been subject to a new and demanding regulation: EUDR — the EU Deforestation Regulation (Regulation 2023/1115). Timber importers from the UK must now carry out mandatory due diligence, document the supply chain all the way back to the forest plot and submit statements in the EU information system. An additional challenge is the fact that the UK — as a third country outside the EU — does not benefit from any automatic "low risk" exemption under EUDR. This article explains all the obligations: from HS44 classification, through customs documents and FSC/PEFC certificates, to a complete due diligence framework under EUDR.

What is EUDR and when does it apply?

EUDR (EU Deforestation Regulation) — Regulation of the European Parliament and of the Council (EU) 2023/1115 — entered into force on 29 June 2023. For large operators (including most B2B importers) the due diligence obligations apply from 30 December 2024 (the deadline was postponed several times). For micro-enterprises the deadline is 30 June 2025.

The objective of EUDR: to prevent placing on the EU market goods that contribute to deforestation or forest degradation globally.

Which wood products are covered by EUDR?

HS Code	Product	Covered by EUDR?
4401–4413	Raw timber, charcoal, sawn timber, veneers	YES
4414–4421	Joinery products, plywood, boards	YES
4701–4707	Pulp, recovered paper	YES (paper)
4801–4823	Paper and paperboard	YES (paper)
9401, 9403	Wooden furniture	YES
Cocoa, soya, beef, coffee, palm oil	Other EUDR commodities	YES (other categories)

Important: EUDR covers not only raw material but also finished products containing wood — plywood, furniture, structural components.

The UK as a third country under EUDR — no automatic exemption

The EUDR classifies countries into three risk categories: low, standard and high. The classification is conducted by the European Commission and determines the scope of due diligence obligations.

The UK is not automatically classified as a "low risk" country — as a non-EU country the UK is subject to the standard assessment procedure, which had not been concluded at the start of 2026. This means that importing timber and wood products from the UK is subject to full, standard due diligence — in the same way as imports from any other third country.

For comparison: - Low-risk country → simplified due diligence (less documentation required) - Standard-risk country (UK) → full due diligence - High-risk country → enhanced due diligence + increased controls

EUDR due diligence — what must a Polish importer do?

Full EUDR due diligence for timber imports from the UK consists of three steps:

Step 1: Collection of information

The importer must collect and document: - a description of the goods with HS and CN codes - the country of production (UK) and the country of origin of the raw material (if different from the UK — e.g. tropical timber processed in the UK) - geolocation of the forest plot(s) from which the timber was harvested (GPS polygon coordinates or a point for areas <4 ha) - supplier details (name, address, contact information) - evidence that the timber was harvested in compliance with the laws of the country of production (including forestry law, environmental law and human rights law) - a statement that the goods do not originate from areas that were deforested or degraded after 31 December 2020

Step 2: Risk assessment

On the basis of the information collected, the importer assesses the risk of non-compliance with EUDR. If the risk is "negligible" — the statement may be submitted. If the risk is non-zero — mitigation measures must be applied.

Step 3: Risk mitigation

Mitigation measures may include: - additional checks and supplier verification - requesting additional documentation - independent audits - FSC/PEFC certification as a supporting element (but not a substitute for) due diligence

FSC and PEFC certificates — are they sufficient for EUDR?

This is one of the most frequently asked questions from importers. The answer is: FSC and PEFC help, but on their own they do not replace EUDR due diligence.

Aspect	FSC/PEFC	EUDR Due Diligence
Legality of harvesting	Yes — confirms it	Yes — required
No deforestation	Partially — depends on the standard	Yes — explicitly required
Geolocation of plots	Not always	YES — required
Statement in EU system	No	YES — required
Sufficient for EUDR?	NO — on its own	YES — once all steps are fulfilled

Holding an FSC or PEFC certificate from the UK supplier is a good starting point and can facilitate due diligence, but it does not waive the obligation to obtain the geolocation of forest plots and to submit a statement in the EUDR EU information system.

How to obtain documents from a UK supplier?

Standard document package from a UK supplier required for EUDR:

1. Forestry Commission certificate / felling licence — confirmation of the legality of felling in the UK (any harvesting above 5 m³ requires a licence issued by the Forestry Commission or its devolved equivalents)
2. Chain of Custody Certificate (CoC) — FSC or PEFC, confirming the chain of custody from forest to processor
3. Geolocation data — GPS coordinates of forest plots in GeoJSON or KML format (from the forest owner or forestry manager)
4. Timber Regulation Statement — a declaration of compliance with the UK Timber Regulation (the equivalent of the EU Timber Regulation, which the UK retained after Brexit as UK EUTR)
5. Species Declaration — declaration of the tree species (important for exotic species in view of CITES)

HS44 classification — key CN codes for importers

For correct customs clearance, 8-digit classification under the CN (Combined Nomenclature) is essential:

CN Code	Description	Notes
4406 10 00	Railway sleepers (ties) of wood	Creosote-impregnated → ADR
4407 10 00–4407 99	Coniferous and non-coniferous sawn timber	Most common import from UK
4412 31 00–4412 99	Plywood and veneered wood	Check species of wood
4415	Cases and wooden pallets	ISPM 15 rules for packaging
4418	Builders' joinery (windows, doors, flooring)	Finished product
4421	Other articles of wood	Miscellaneous wooden articles

Important rule: wooden packaging materials (pallets, cases, crates) accompanying a consignment must comply with the ISPM 15 standard (International Standard for Phytosanitary Measures No. 15) — phytosanitary treatment (fumigation or heat treatment) confirmed by the IPPC mark. The absence of an ISPM 15 mark on pallets is one of the most common reasons for a consignment being held at the border.

Duty rates on timber from the UK

Under the TCA, duty rates on wood products from the UK are as follows:

Category	MFN Rate	TCA Rate (UK origin)
Raw timber (4401–4403)	0%	0%
Sawn timber (4407)	0%	0%
Plywood (4412)	3.7–7.0%	0%
Wooden flooring (4418)	0–3.7%	0%
Wooden furniture (9401–9403)	0–5.6%	0%

Rules of origin for HS44 products are typically based on CTH (Change of Tariff Heading) or on a value-added criterion. For processed timber (e.g. plywood), production in the UK from imported raw material may satisfy the rules of origin.

Customs documents for timber imports from the UK

Complete list of documents for timber imports from the UK:

Document	Issued by	Notes
Commercial invoice	UK exporter	Species description, dimensions, grade
UK Origin Statement / REX	UK exporter	For 0% TCA rate
CMR / waybill	Carrier
EUDR Due Diligence Statement	Polish importer	Submitted in the EU EUDR system
Geolocation of forest plots	Forestry manager / owner	GPS polygon, GeoJSON
FSC/PEFC CoC	UK supplier	Supporting evidence for EUDR
Forestry Commission licence	UK producer	Confirmation of lawful felling
Phytosanitary certificate (phyto)	APHA UK	For unprocessed timber, bark
ISPM 15 mark on packaging	Pallet manufacturer	Mandatory for wooden packaging materials