UK Timber Regulation due diligence

At a glance

References are to the OPSS Guidance on the UK Timber Regulations, January 2021 text (PDF created 12 Feb 2025). The operator keeps all ten; a trader keeps the supplier and customer records (item 4) for 5 years.

Who is the operator?

The guidance says you are an operator if you place timber or timber-related products on the GB market for the first time, making them available for distribution or for use in your own business (para 2.6). For an import, the operator is the entity identified in box 8 of the C88 customs form (para 2.7). Placing on the market means supplying for the first time, wherever the timber was grown; timber in transit, under special customs procedures or imported only to be re-exported is not placed on the market (paras 2.9 to 2.11).

You are a trader if you are based in Great Britain and buy or sell products that a GB operator has already placed on the market (para 2.13). A business that first places timber and then sells it is both (para 3.1).

Three of the guidance’s own scenarios, and one rule, are the nearest to furniture and joinery:

• A maker imports timber and makes furniture from it (scenario 7). The maker is the operator. The EU buyer of the finished furniture is likely to be an operator under the EU rules and will need information from the maker for its own due diligence.
• A customs agent clears goods for a buyer (scenario 3). The agent is neither operator nor trader. The buyer becomes the operator the moment the goods clear customs.
• Furniture arrives from the EU that entered the EU on an EU FLEGT licence (scenario 11). The GB importer is the operator and must do due diligence: the EU licence is not valid in Great Britain.
• A business first places goods, then supplies them in Great Britain (para 3.1). It has operator duties for the first step and trader duties for the sale.

So the answer for any one order depends on the facts: who imports, who is named in box 8, who owns the goods at that moment, and whether the goods were bought from a GB operator. The guidance does not say that a designer, a client or a workshop is always the operator. Ask the supplier to say in writing who it believes the operator is for each item, and ask OPSS if the answer is unclear (para 2.18). Make Bespoke Studio coordinates manufacture through partner workshops, and nothing on this page states who the operator is on any order.

What products are in scope

The scope is set by HS (customs) codes in Table 1 of the guidance. The rows nearest to furniture and joinery are: 4408 veneer sheets 6 mm or less; 4409 continuously shaped wood such as moulded or tongued and grooved; 4410 particle board and OSB; 4411 fibreboard; 4412 plywood, veneered panels and similar laminated wood; 4414 wooden frames for pictures and mirrors; 4418 builders’ joinery and carpentry; and 9403 wooden furniture (subheadings 9403 30, 9403 40, 9403 50 00, 9403 60 and 9403 90 30). Sawn wood over 6 mm (4407), pulp and paper, and prefabricated wooden buildings are also listed.

Exempt, per paragraph 2.19: recycled timber that has completed its life cycle and would otherwise be waste; printed matter; packaging used only as packing; tools and brush bodies and handles; seats; and musical instruments. Table 1 has no row for the seats heading, and the exemption list names seats, so wooden chairs and similar seating are described as outside the regulations. The guidance does not spell out the edge cases (upholstered seating, frames, parts), so where there is doubt ask OPSS, as paragraph 2.18 invites.

The EU Deforestation Regulation lists wooden seats; this one does not. See EUDR for wooden furniture exports for the other regime.

The due diligence system, in three stages

The operator must exercise due diligence before placing timber on the market, and maintain and regularly evaluate the system (paras 4.3, 4.11). It has three stages: gather information, assess the risk of illegally harvested timber, and, if the risk is not negligible, mitigate it. Where the information available is not sufficient, the guidance says the operator has to conclude that the risk is not negligible (para 5.3). Where risk is not reduced to negligible, the operator may not legally place the product on the market (para 4.14).

The risk assessment looks at each item of information at each stage of the supply chain (para 4.18). The parts of Table 3 read for this sheet ask: are the documents recent, original and verifiable; does a certification scheme cover all the applicable legislation; is the species at risk (the guidance points to sources such as the IUCN Red List and CITES); and how long and complex is the supply chain. Collaboration with suppliers is called essential, and where a supplier will not cooperate the operator should seriously consider whether a conclusion of negligible risk is possible (para 4.19).

Mitigation depends on the risk found. The guidance lists, among others: requesting more certified or verified documents, mapping the chain from harvest to delivery, timber analysis for species or origin, on-site audit, third-party verification, and replacing the supplier (paras 4.22, 5.6). It suggests keeping the paperwork as an accessible file, labelled by stage, with a record of the decision and its reasons (para 4.15).

Evidence: certificates, licences and documents compared

A certificate is one input, not the system. The table sets the four kinds of paper side by side. The glance table at the top lists the file itself.

Make Bespoke Studio does not claim here that any partner workshop holds any certificate. For the claim types, the invoice checks and certificate databases, see specifying FSC and PEFC; for other paperwork a tender may ask for, sustainability documents a tender will ask for.

Penalties, Northern Ireland and what is coming

Offences. Regulation 4 of SI 2013/233 makes it an offence to fail to comply with the prohibition on placing illegally harvested timber, the duty to exercise due diligence, the duty to maintain and evaluate a due diligence system, the traceability and record-keeping duties, to obstruct an inspector, or to comply with a notice of remedial action. Regulation 13, as shown on legislation.gov.uk on 7 November 2026, sets for the first three a fine up to the statutory maximum or up to three months in prison on summary conviction, and a fine or up to two years on indictment; for the other offences (traceability, records, obstruction and the remedial notice), a fine up to level 5 on the standard scale. OPSS enforces the regulations.

Northern Ireland. The guidance says the EU Timber Regulation continues to apply to operators and traders in Northern Ireland (para 2.3). The EU is replacing it with the deforestation regulation: see the sister sheet for the dates.

Proposed changes in Great Britain. The gov.uk page “The UK’s approach to deforestation regulations”, shown as updated on 2 September 2026, says the government plans to strengthen the UK Timber Regulations alongside regulations under the Environment Act 2021. It describes due diligence, reporting, geolocation data and alignment with the EU rules for businesses with turnover over £1 million, and expects legislation in 2027. It gives no consultation date. These are proposals, not law. Check the page again before relying on them.

Before order, the Supplier states in writing, for each item in [HS code / item list] within the scope of the UK Timber and Timber Products (Placing on the Market) Regulations 2013 (as amended), who the operator is for that item, and where goods are imported names the entity identified in box 8 of the customs declaration.

The Supplier confirms that the operator has exercised due diligence for all timber and timber products supplied and that no illegally harvested timber is supplied. On request for [each consignment / each item] the Supplier provides: the common and scientific names of every species; country (and where relevant region) of harvest; quantity; supplier name and address; a summary of the legality evidence; and the outcome of the risk assessment, including any mitigation. The Supplier keeps the records for at least [5] years, in a form that can be shown to the Office for Product Safety and Standards on request, and makes them available to [the Designer / Client] on [reasonable] notice.

Where reliance is placed on [FSC / PEFC / FLEGT / CITES], the Supplier provides a copy, the certificate or licence number and what it covers, and states that, in its assessment, the scheme covers the applicable legislation.

A change of species, country of harvest, supplier or importer requires written notice and updated records before the item is ordered.

Standards and sources

• OPSS Guidance on the UK Timber Regulations (January 2021 text): Jan 2021 text.
• gov.uk: Regulations: timber and FLEGT licences: Updated 20 Aug 2025.
• The Timber and Timber Products (Placing on the Market) Regulations 2013, SI 2013/233: Regs 4 and 13.
• gov.uk: The UK's approach to deforestation regulations: Updated 2 Sep 2026; proposals.

Questions we are asked

Who is the operator for imported furniture?

The person who first places it on the Great Britain market. For an import, the guidance says that is the entity identified in box 8 of the customs form. It can be a maker, a merchant, a designer or a client, depending on the facts. A customs agent acting for a buyer is neither operator nor trader.

If I buy from a UK supplier, do I have to do due diligence?

Not if the products were already placed on the market by a GB operator. You are then a trader and keep records of your supplier and your customers for at least five years. If you import the timber or furniture yourself, you are the operator.

Does FSC or PEFC certified timber satisfy the regulations?

Not automatically. Certification can be part of the risk assessment, but the operator must check that the scheme covers all the applicable legislation and that the certifying body is in good standing, and must keep the records.

What if a supplier will not tell me the species or origin?

The guidance says that where information is not sufficient the operator has to conclude that the risk is not negligible, and then either mitigate (for example by changing supplier) or not place the product on the market.

Are chairs covered?

The guidance lists seats as exempt and Table 1 has no row for them, but it does not spell out edge cases such as upholstered frames or parts. Ask OPSS about a specific product.

Is the law changing?

The government has published plans to strengthen the regulations and to introduce rules aligned with the EU Deforestation Regulation in Great Britain, with legislation expected in 2027. We saw no consultation date and no draft law on 7 November 2026.