Since the EUDR was postponed again in December 2025, many small EU importers have heard one simple message: large companies start on 30 December 2026, micro and small companies on 30 June 2027. For a furniture importer, that message is often wrong. Whether you get the extra six months depends less on your size than on what you import.
The rule
Regulation (EU) 2025/2650 moved the main application date of the EUDR to 30 December 2026. Article 38(3) of the EUDR gives operators that are natural persons, micro or small undertakings until 30 June 2027. That later date does not apply to products listed in the Annex to the EU Timber Regulation (Regulation (EU) No 995/2010), the law the EUDR replaces for wood.
So three conditions must all be true before you can use 30 June 2027:
- You are an operator. You place the product on the EU market for the first time, for example because you import it from Vietnam.
- You were already micro or small on 31 December 2024. A company founded or grown into that size later does not qualify.
- The product was not in the EUTR Annex. This is the condition most furniture importers miss.
What counts as micro or small
The EUDR uses the size classes of the EU Accounting Directive (2013/34/EU). A company is micro or small if, on its balance sheet date, it does not exceed two of three limits:
| Employees | Balance sheet total | Net turnover | |
|---|---|---|---|
| Micro | 10 | EUR 450,000 | EUR 900,000 |
| Small | 50 | EUR 5 million (up to 7.5 million where the member state allows) | EUR 10 million (up to 15 million where the member state allows) |
The monetary limits were raised in 2023. Member states may set higher limits for small companies, so check the figures in your national accounting law.
Which furniture keeps the December 2026 date
The EUTR Annex listed wooden furniture under CN 9403, but not seats under CN 9401. In practice, for a micro or small operator that meets the other two conditions:
| Product | CN code | In the EUTR Annex? | Date |
|---|---|---|---|
| Wooden furniture for offices, kitchens, bedrooms, dining and living rooms, shops | 9403 30, 40, 50, 60 | Yes | 30 Dec 2026 |
| Parts of furniture, of wood | 9403 91 (formerly 9403 90 30) | Yes | 30 Dec 2026 |
| Seats with wooden frames, upholstered or not | 9401 61, 9401 69 | No | 30 Jun 2027 |
| Parts of seats, of wood | 9401 91 | No | 30 Jun 2027 |
| Most wood products in Chapter 44 (sawn wood, panels, frames, tools) | 44… | Mostly yes | Usually 30 Dec 2026 |
Large and medium operators start on 30 December 2026 for all of these.
Two practical consequences. If you import tables and chairs, you have two dates in the same container. And the CN code your customs broker uses decides the date, so check it before you plan around June 2027.
Downstream operators and traders
The extension is for operators. Companies that buy the product after it has already been placed on the EU market, such as retailers buying from an EU importer, are downstream operators or traders. They do not get the later date, whatever their size. Since the 2025 amendment, their obligations are lighter: the due diligence statement is submitted by the operator who first places the product on the market, and downstream companies mainly keep records of their suppliers and customers.
Old stock
A transition rule matters for timber products that are already in the supply chain. Products covered by the EUTR that were produced before 29 June 2023 stay under the EUTR, not the EUDR, until 31 December 2029.
What your supplier's size has to do with it
Nothing. Your date depends on your role, your size and the product. That your manufacturer in Vietnam is a small company does not move your date. What you need from them stays the same: where the wood was grown, proof that it was harvested legally, and the link from the wood to your product.
What to do now
- List your products by CN code and mark which ones were in the EUTR Annex.
- Check your company size on 31 December 2024, using your national thresholds.
- For every product with a 30 December 2026 date, ask your suppliers for the data now. Collecting plot locations and harvest papers from a supply chain in Vietnam takes weeks, not days.
If the answer to step 1 or 2 is unclear, start there. A wrong assumption about June 2027 is the most expensive mistake a small furniture importer can make this year.
