Applies to you · 6 Oct 2026 · eur-lex.europa.eu

Regulation (EU) 2023/1115 — Article 5

Wooden furniture: due 30 December 2026, not moved to 30 June 2027

Leather goods: moved to 30 June 2027 for small companies

The move to 30 June 2027 leaves out products listed in the Annex to the EU Timber Regulation (Regulation (EU) No 995/2010), which lists wooden furniture. Leather goods were due 30 June 2026. The dates in RegWatch already use these.

This applies if your company was already small by 31 December 2024.

Moved by Regulation (EU) 2025/2650, which amends Article 38(3) of Regulation (EU) 2023/1115.

Read the amended text

“Except as regards the products covered by the Annex to Regulation (EU)No 995/2010, for operators, whether natural persons or micro- or small undertakings within the meaning of Article 3(1) or Article 3(2), first subparagraph, respectively, of Directive 2013/34/EU, irrespective of their legal form, who were established as such by 31 December 2024, the Articles referred to in paragraph 2 of this Article shall apply from 30 June 2027.”— Regulation (EU) 2023/1115, Article 38(3), as amended by Regulation (EU) 2025/2650 · eur-lex.europa.eu

“9403 30 , 9403 40 , 9403 50 00 , 9403 60 and 9403 90 30 Wooden furniture”— Regulation (EU) No 995/2010, Annex · eur-lex.europa.eu

“Subject to paragraph 3 of this Article, Articles 3 to 13, Articles 16 to 24 and Articles 26, 31 and 32 shall apply from 30 December 2026.”— Regulation (EU) 2023/1115, Article 38(2), as amended by Regulation (EU) 2025/2650 · eur-lex.europa.eu

Before: “Except as regards the products covered in the Annex to Regulation (EU)No 995/2010, for operators that by 31 December 2020 were established as micro-undertakings or small undertakings pursuant to Article 3(1) or (2) of Directive 2013/34/EU, respectively, the Articles referred to in paragraph 2 of this Article shall apply from 30 June 2026.”— Regulation (EU) 2023/1115, Article 38(3), as set by Regulation (EU) 2024/3234 · eur-lex.europa.eu

Non-SME downstream operators and traders must register in the EU information system before placing relevant products on the market. All downstream operators and traders must collect and keep supplier and customer information for at least five years and provide it to authorities upon request.

Why this applies to you

Applies because you sell wooden furniture and leather goods, which are relevant products under the EU Deforestation Regulation, and you place them on the market in Germany and other EU countries.
As a downstream trader, you must collect and keep supplier and customer information, retain it for five years, and cooperate with authorities.
The obligations apply to all downstream operators and traders regardless of company size, though the registration requirement is only for non-SMEs.

What to do

Before listing any wooden furniture, confirm you have the supplier and customer details required by the regulation.

by 30 Dec 2026

“Downstream operators and traders shall place or make available on the market or export relevant products only if they are in possession of the information required under paragraph 3.”— eur-lex.europa.eu

Before listing any leather goods, confirm you have the supplier and customer details required by the regulation.

by 30 Jun 2027

“Downstream operators and traders shall place or make available on the market or export relevant products only if they are in possession of the information required under paragraph 3.”— eur-lex.europa.eu

Set up a system to record the name, address, email, and website of each supplier and business customer for your wooden furniture, including due diligence statement references from suppliers who are operators.

by 30 Dec 2026

“Downstream operators and traders shall collect and keep the following information relating to the relevant products they intend to place or make available on the market or export: (a) the name, registered trade name or registered trade mark, the postal address, the email address and, if available, a web address of the operators, downstream operators, or the traders who have supplied the relevant products to them, as well as, only in the event that their supplier is an operator, the reference numbers of the due diligence statements or the declaration identifiers associated to those products; (b) the name, registered trade name or registered trade mark, the postal address, the email address and, if available, a web address of the downstream operators, or the traders to whom they have supplied the relevant products.”— eur-lex.europa.eu

Set up a system to record the name, address, email, and website of each supplier and business customer for your leather goods, including due diligence statement references from suppliers who are operators.

by 30 Jun 2027

“Downstream operators and traders shall collect and keep the following information relating to the relevant products they intend to place or make available on the market or export: (a) the name, registered trade name or registered trade mark, the postal address, the email address and, if available, a web address of the operators, downstream operators, or the traders who have supplied the relevant products to them, as well as, only in the event that their supplier is an operator, the reference numbers of the due diligence statements or the declaration identifiers associated to those products; (b) the name, registered trade name or registered trade mark, the postal address, the email address and, if available, a web address of the downstream operators, or the traders to whom they have supplied the relevant products.”— eur-lex.europa.eu

Store the supplier and customer records for your wooden furniture for at least five years from each sale and be ready to share them with authorities if asked.

by 30 Dec 2026

“Downstream operators and traders shall keep the information referred to in paragraph 3 for at least five years from the date of the placing or making available on the market or export, and shall provide that information to the competent authorities upon request.”— eur-lex.europa.eu

Store the supplier and customer records for your leather goods for at least five years from each sale and be ready to share them with authorities if asked.

by 30 Jun 2027

“Downstream operators and traders shall keep the information referred to in paragraph 3 for at least five years from the date of the placing or making available on the market or export, and shall provide that information to the competent authorities upon request.”— eur-lex.europa.eu

If you learn that any wooden furniture you've sold may not meet the regulation, notify the competent authorities in the EU countries where you sold it and the downstream traders you supplied.

by 30 Dec 2026

“Downstream operators and traders that obtain or are made aware of relevant new information, including substantiated concerns, indicating that a relevant product that they have placed or made available on the market is at risk of not complying with this Regulation shall immediately inform the competent authorities of the Member States in which they placed or made available on the market the relevant product as well as downstream operators and traders to whom they supplied the relevant product. In the case of exports, downstream operators shall inform the competent authority of the Member State which is the country of production.”— eur-lex.europa.eu

If you learn that any leather goods you've sold may not meet the regulation, notify the competent authorities in the EU countries where you sold them and the downstream traders you supplied.

by 30 Jun 2027

“Downstream operators and traders that obtain or are made aware of relevant new information, including substantiated concerns, indicating that a relevant product that they have placed or made available on the market is at risk of not complying with this Regulation shall immediately inform the competent authorities of the Member States in which they placed or made available on the market the relevant product as well as downstream operators and traders to whom they supplied the relevant product. In the case of exports, downstream operators shall inform the competent authority of the Member State which is the country of production.”— eur-lex.europa.eu

Be prepared to give authorities access to your premises, documentation, and records on your wooden furniture for checks under Article 19.

by 30 Dec 2026

“Downstream operators and traders shall offer all necessary assistance to the competent authorities to facilitate the carrying out of the checks under Article 19, including access to premises and the making available of documentation and records.”— eur-lex.europa.eu

Be prepared to give authorities access to your documentation and records on your leather goods for checks under Article 19.

by 30 Jun 2027

“Downstream operators and traders shall offer all necessary assistance to the competent authorities to facilitate the carrying out of the checks under Article 19, including access to premises and the making available of documentation and records.”— eur-lex.europa.eu

Obligations in the text

Place or make available relevant products only if in possession of required information.

“Downstream operators and traders shall place or make available on the market or export relevant products only if they are in possession of the information required under paragraph 3.”— eur-lex.europa.eu

Collect and keep supplier and customer information relating to relevant products.

“Downstream operators and traders shall collect and keep the following information relating to the relevant products they intend to place or make available on the market or export: (a) the name, registered trade name or registered trade mark, the postal address, the email address and, if available, a web address of the operators, downstream operators, or the traders who have supplied the relevant products to them, as well as, only in the event that their supplier is an operator, the reference numbers of the due diligence statements or the declaration identifiers associated to those products; (b) the name, registered trade name or registered trade mark, the postal address, the email address and, if available, a web address of the downstream operators, or the traders to whom they have supplied the relevant products.”— eur-lex.europa.eu

Keep collected information for at least five years and provide it to competent authorities upon request.

“Downstream operators and traders shall keep the information referred to in paragraph 3 for at least five years from the date of the placing or making available on the market or export, and shall provide that information to the competent authorities upon request.”— eur-lex.europa.eu

Immediately inform competent authorities if a placed product is at risk of non-compliance.

“Downstream operators and traders that obtain or are made aware of relevant new information, including substantiated concerns, indicating that a relevant product that they have placed or made available on the market is at risk of not complying with this Regulation shall immediately inform the competent authorities of the Member States in which they placed or made available on the market the relevant product as well as downstream operators and traders to whom they supplied the relevant product. In the case of exports, downstream operators shall inform the competent authority of the Member State which is the country of production.”— eur-lex.europa.eu

Offer all necessary assistance to competent authorities to facilitate checks under Article 19.

“Downstream operators and traders shall offer all necessary assistance to the competent authorities to facilitate the carrying out of the checks under Article 19, including access to premises and the making available of documentation and records.”— eur-lex.europa.eu

Source

Document: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML?uri=CELEX%3A02023R1115-20251226
Jurisdiction: EU
Dates: 30 Dec 2026 · 30 Jun 2027
Fetched: 19 Oct 2026 14:10 UTC
Content hash: 71827bc54801
Extracted by: recorded seed run
Classified by: nvidia/Nemotron-3-Ultra-550b-a55b · $0.0119

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