The EU Deforestation Regulation (EUDR) now has a fixed product list and a fixed date. For importers bringing engineered oak flooring from Vietnam into the EU, the next three months are the window to agree what data the factory supplies, in what format, and for which containers. This article summarizes what changed in September 2026, why flooring is still covered, and what to ask your supplier before shipments that will arrive after 30 December 2026.
This is a practical overview for buyers, not legal advice. Check the details of your own obligations with your compliance advisor.
What happened in September 2026
The Commission adopted Delegated Regulation (EU) 2026/2102 on 13 July 2026. It amends the list of relevant commodities and products in Annex I of Regulation (EU) 2023/1115, the EUDR. It was published in the Official Journal on 17 September 2026 and entered into force the day after publication.
The act closes out the simplification package the Commission presented on 4 May 2026. That package included a report to the European Parliament and the Council, an updated guidance document and FAQ, the draft of this product-scope act, and an updated draft implementing act on the EUDR Information System.
The main scope changes reported by the Commission are:
- Removed: products such as cattle hides, skins and leather, retreaded tyres, and aircraft and motor vehicle seats.
- Added: products such as soluble coffee and certain palm oil derivatives.
- Clarified: used and second-hand products are excluded from many entries.
The official text is on EUR-Lex, and the Commission’s implementation page is here.
Engineered oak flooring stays in scope
Wood is one of the seven commodities covered by the EUDR, alongside cattle, cocoa, coffee, palm oil, rubber and soy. The delegated act did not remove flooring. It rewrote the entry as “ex 4418”: builders’ joinery and carpentry of wood, including assembled flooring panels, not including used and second-hand products. New engineered oak flooring shipped from a factory falls under that heading, as do unassembled parquet strips under the ex 4409 entry.
The dates that matter
According to the Commission, the regulation applies:
| Who | From |
|---|---|
| Large and medium companies | 30 December 2026 |
| Micro and small enterprises in the timber sector | 30 December 2026 |
| Other micro and small enterprises | 30 June 2027 |
The second row is easy to miss. The later date is not available to small companies that deal in timber products. Many flooring importers are small companies, and for them 30 December 2026 is the relevant date.
What this means for containers already being planned
The customs check happens at import. Under the regulation, the reference number of the due diligence statement must be available to customs before the goods are released for free circulation. What counts is when a container is cleared in the EU, not when it left Vietnam. A container produced in October and cleared in January needs the data behind a due diligence statement, even though it was produced before the date.
Sea freight from Vietnam to Europe takes several weeks. Production orders placed now are likely to clear customs close to or after 30 December 2026, so treat them as in scope.
Who does the due diligence
The regulation places the main obligation on the operator: the company that first places the product on the EU market. For flooring made in Vietnam and imported into the EU, that is usually the EU importer, not the factory. The Commission’s guidance distinguishes upstream operators, who must carry out due diligence, from downstream operators and traders, who have lighter requirements.
The factory does not submit your statement. What it can do is supply the information you need to complete it, and keep supplying it in the same format for every shipment.
The information your statement depends on
Article 9 of the regulation lists the information the operator must collect and keep for five years. For an engineered oak floor, the points that depend on the factory are:
- Product description, including the common name and full scientific name of each wood species in the product.
- Quantity, in net mass and, where applicable, the supplementary unit for the HS code.
- Country of production: the country where the wood was harvested. For an oak wear layer, that is where the oak logs were felled, not Vietnam.
- Geolocation of all plots of land where the wood was produced, with the date or time range of production. Geolocation means latitude and longitude with at least six decimal digits, and polygons for plots of more than four hectares used for commodities other than cattle.
- Evidence of legality of harvest under the laws of the country of production.
- Evidence that the wood is deforestation-free: harvested without inducing forest degradation after 31 December 2020.
Every wood layer counts
Engineered flooring contains more than one wood component. A 2-layer board has an oak wear layer bonded to a plywood core; a 3-layer board adds a backing layer. The core and backing are wood products too, and they may come from a different species and a different country than the oak. Each component needs its own species, origin and geolocation data. A file that covers only the oak wear layer is incomplete. Our 2-layer vs 3-layer guide describes what each construction contains.
What to ask your Vietnamese factory now
Ask these questions in writing, before production starts, and ask for a sample data file for a real past lot.
Raw material and origin
- For each wood component (wear layer, core, backing), what is the species, its scientific name, and the country of harvest?
- Who supplies the logs, lumber or veneer, and can the supplier provide plot geolocation and harvest dates?
- For plots over four hectares, can the data be provided as polygons?
- What documents support legal harvest in the country of production?
Traceability through the factory
- How is incoming material recorded, and how is it linked to a production lot?
- Can a finished carton or pallet be traced back to the incoming material batches it was made from?
- Is material from different origins kept apart, or mixed in one lot? Mixed lots mean more plots to declare.
Data format and delivery
- In what format will the data be delivered: spreadsheet, GeoJSON, or another file your system can import?
- Will it arrive before the goods ship, so your statement can be filed before customs clearance?
- Who at the factory is responsible for the file, and how are corrections handled?
Contract points to agree before the first affected shipment
- Data as a delivery obligation. State that the EUDR data file for each shipment is part of delivery, with a deadline before shipment.
- Scope of data. List every wood component and require species, country of production, geolocation and production dates for each.
- Change notification. Require the factory to tell you before changing a raw material supplier or origin for your product.
- Record retention. Ask the factory to keep its supporting records for at least as long as you must keep yours, five years under Article 9.
- Access for checks. Agree that you or your appointed inspector can review traceability records on request.
- What happens if data is missing. Decide in advance whether a shipment without complete data is held, and who bears the cost.
Your compliance advisor should review the wording against your own due diligence system.
A three-month plan for Q4 2026
October. Send your questions to each supplier. Ask for a sample data file for a recent lot. Identify which open orders will clear EU customs after 30 December 2026. Register in the EUDR Information System if you have not already done so.
November. Review the sample files against Article 9. Resolve gaps, especially for core and backing materials. Add EUDR clauses to purchase orders for affected shipments.
December. Receive the data file with each shipment’s documents. File due diligence statements before arrival so the reference number is ready for customs clearance.
Our order process article explains where confirmation of materials fits in the production sequence, which is the right point to lock origin data for each order.
Frequently asked questions
Does the EUDR apply to engineered oak flooring made in Vietnam?
Yes, when it is placed on the EU market. Assembled flooring panels are listed under ex 4418 in Annex I, as amended by Delegated Regulation (EU) 2026/2102. The factory location does not change this; the obligations attach to the product entering the EU.
Is the country of production Vietnam?
For the EUDR, the country of production is where the wood was harvested. For an oak wear layer, that is the country where the oak was felled. Each other wood component, such as a plywood core, has its own country of production.
We are a small importer. Do we have until June 2027?
Not if you deal in timber products. The Commission states that the regulation applies from 30 December 2026 to micro and small enterprises from the timber sector. Confirm your status with your compliance advisor.
Can the factory file the due diligence statement for us?
The statement is filed by the operator placing the product on the EU market, usually the EU importer. The factory’s role is to provide accurate and complete origin data in time for you to file.
Working with Vu Uy Wood
Vu Uy Wood manufactures solid and engineered French White Oak flooring to specification in Song Than 3 Industrial Park, Ho Chi Minh City, and has done so since 2006. If you are planning EU deliveries that will clear customs after 30 December 2026, send your EUDR data requirements with your request for quotation through the contact page, and we will respond within 24 business hours with what we can supply for each wood component of your specification.