Lacey Act and EUDR: Timber Paperwork for Hardwood Floor Imports

A Lacey Act declaration and an EUDR due diligence statement are not certificates you collect from a supplier. They are statements you file, in your own name, about wood you did not harvest and cannot see. That is the whole problem with hardwood flooring import documentation: the legal obligation sits with the importer, the data sits three tiers upstream, and the mill that milled your floor is usually the fourth party in the chain rather than the first.

If you are buying custom parquet or wide-plank hardwood out of China, the mill imports its logs and lumber rather than cutting them. A Guangdong parquet workshop working in Burma teak, black walnut, rosewood, Indonesian rosewood (Sonokeling) and cedar is a converter, not a forest operator. Every species and origin fact you need is one or more steps behind the factory gate, held by a log trader, a sawmill, or a veneer supplier. Your declaration still has to name it.

The two regimes ask different questions

The US Lacey Act, as amended in 2008 to cover plants and plant products, does two separate things. It makes it unlawful to trade in plants taken in violation of any underlying law — foreign or domestic — and, separately, it requires an import declaration for products in phased-in tariff headings. Those two prongs are independent. The prohibition applies whether or not a declaration is required for your HTS line; a product outside the declaration phase-in is still illegal to import if the timber was taken unlawfully.

The EU Deforestation Regulation, (EU) 2023/1115, replaced the older EU Timber Regulation and works differently. It is a due diligence system, not a customs declaration. Before placing relevant products on the EU market, the operator collects information, assesses risk, mitigates risk where it is more than negligible, and then submits a due diligence statement in the EU information system. The regulation covers legality and deforestation: the timber must be legal under the laws of the country of production and must come from land not deforested after 31 December 2020.

The practical difference matters when you are writing a purchase order. Lacey asks you to state facts on a form. EUDR asks you to hold a defensible file that shows how you established those facts, keep it for five years, and be able to hand it to a competent authority. Confirm the EUDR application date in force at the time of your shipment before you plan around it — the timetable has been amended more than once, and the obligations for micro and small enterprises phase in on a different date from those for larger operators.

What a Lacey Act declaration actually requires

PPQ Form 505 — filed electronically through the ACE partner government agency message set on most formal entries — asks for a short list of fields per line item. It is short enough that people underestimate it, and specific enough that a supplier email saying "all our wood is legal" satisfies none of it.

Three details in that table cause most of the rework.

Genus and species, not trade name. "Teak", "walnut", "rosewood" and "cedar" are trade names, and two of them are dangerous. Rosewood covers most of the genus Dalbergia, dozens of species with different regulatory status. Cedar is worse: it can mean Cedrus, Cedrela, Thuja, Chamaecyparis or Toona depending on which side of which ocean the packing list was typed on, and one of those genera carries CITES obligations. A declaration line that reads "cedar" is not a declaration.

Country of harvest, not country of shipment. The container leaves Shenzhen or Guangzhou. The teak may have been harvested somewhere else entirely, and the walnut somewhere else again. China is the country of manufacture and the country of export; it is rarely the country of harvest for imported precious hardwoods. Filing "China" as country of harvest on a Burma teak line is a misstatement, not a shortcut.

Multiple species on one product. Inlay and marquetry work is hand-cut from contrasting timber species and set into a base panel — that is the whole point of the craft. A single medallion can carry five or six species. An engineered plank is a wear layer of one species over a core that may be several others. Each has to be identified. Where the exact species genuinely varies lot to lot, the APHIS instructions allow you to list every species that may be present rather than guess one; confirm the current wording before you rely on it, and note that "may be present" lists get long fast on inlay work.

Why "and other imported species" is the phrase that stops a filing

Read any Chinese flooring mill's capability text and you will find a species list that ends in an open clause — teak, walnut, rosewood, Sonokeling, cedar, "and other imported species". For a marketing page that is reasonable. For a declaration it is fatal, because the declaration has no field for "other".

That open clause is also where the real risk concentrates. The named species are the ones the mill is proud of and can probably trace. The unnamed ones are the offcuts, the contrast strips in a border, the filler species in a substrate, the batch someone bought opportunistically. On a parquet panel with 1,500-plus pattern options in the design library, the species mix is a per-design question, not a per-factory question.

The fix is procedural, and it belongs in the specification rather than in a compliance email:

• Freeze the species list per design, per order, before production. Not "teak and contrast woods" — a numbered bill of materials with one row per species and the component it appears in.
• Require the scientific name on that bill of materials, written by the mill, not filled in by you afterwards from a common name.
• Require the harvest country per row, and the name of the tier immediately upstream — the sawmill or trader the mill bought that lot from.
• Require it before the mill cuts, because after assembly nobody can tell you which lot went into which panel.
• Carry the same rows onto the commercial invoice and packing list so your broker is not reconciling three documents that disagree.

If you want a benchmark for how far a mill's traceability actually reaches, the useful test is whether the answer changes when you ask about substrates. A mill that laminates its own substrate in house — rather than buying finished core panel — has one more tier of its own timber purchasing to account for, and either it can show you those purchase records or it cannot. Ask early. This ties into the wider question of what documents to request before a first order.

What a supplier statement is, and is not

A letter on factory letterhead saying the timber is legally sourced is a commercial assurance. It is not a due diligence record, under either regime, for a simple reason: it contains no verifiable data. Under Lacey, your exposure is measured by whether you exercised due care given what a reasonable person in your position should have known. Under EUDR, the operator must hold information that is "adequately conclusive and verifiable" — a phrase that rules out unsupported assertions by definition.

What does count, in rough order of strength:

1. Harvest-country permits or transport documents for the specific lot, traced through to the mill's purchase.
2. Sawmill or trader invoices naming species and origin, matched by date and volume to your production lot.
3. Species identification by an independent laboratory — wood anatomy, and where the genus needs splitting, stable isotope or DNA testing on a sample cut from your goods.
4. A mill-issued bill of materials with scientific names and harvest countries, signed, plus the upstream invoices behind it.
5. A supplier declaration alone.

A laboratory identification, note, confirms what the wood is and says nothing about where or how it was harvested — use it to check species claims on high-risk genera, not to replace the origin record. Item five on its own is where most files sit, and it is the reason most files fail. Note also what is absent from this list: a forest-certification claim. Third-party scheme certificates address a different question, they are held by specific legal entities for specific product groups, and nothing in the published record for a given mill should be assumed to exist. For the Huizhou parquet workshop discussed here, no third-party timber legality or chain-of-custody certification appears in the public record at all, so treat any such claim as something you must see documented and verify with the issuing body before it enters your file.

Where the other timber rules cut across

Legality paperwork does not sit alone. Two adjacent regimes commonly apply to exactly the species a custom parquet mill likes to work in, and both are separate filings with separate lead times:

• CITES. Dalbergia species — the genus behind most timber sold as rosewood, including Sonokeling — carry Appendix II obligations, as do some species sold as cedar. Permits are issued by the exporting country's management authority and must be presented at import. Check the current annotation text, which has been revised.
• Sanctions and origin restrictions on Myanmar teak. Both US and EU measures target the state timber enterprise that controls harvest, which means a Burma teak line item raises a sanctions question in addition to a Lacey or EUDR question.

Neither is satisfied by the other. A CITES permit is not a Lacey declaration; an EUDR statement is not a sanctions screen. Build them as three separate checks against the same bill of materials, alongside the rest of your market-by-market import compliance checklist.

Common questions

Does the Chinese factory file any of this?

No. The Lacey declaration is filed by the US importer of record; the EUDR due diligence statement is submitted by the EU operator placing the goods on the market. A Chinese manufacturer cannot file either, and cannot transfer the liability to you by signing something. The mill's role is to supply accurate species and origin data and the records behind it — which is a contractual obligation you have to write, price and enforce.

Is solid flooring treated differently from engineered?

They usually fall under different tariff headings, which affects whether a Lacey declaration is currently required for your line and how the goods are classified, but both are wood products within the scope of the regimes. Engineered construction adds species, because the core layers are timber too. See the separate discussion of HS classification across 4409, 4412 and 4418 before assuming your heading is exempt.

How precise does EUDR geolocation have to be?

The regulation requires geolocation of the plots of land where the commodity was produced, expressed as coordinates, with polygons required above a plot-size threshold. For imported tropical hardwood converted in a third country, that data has to travel from the concession through every trader to your file — which is why sourcing decisions made at the log yard determine whether your EU shipments are filable at all. Confirm the current precision and polygon requirements in the consolidated text.

What to ask the supplier next

Before you release a purchase order for custom hardwood flooring, put these on the table and get written answers:

1. A per-design bill of materials with one row per species, giving genus and species in Latin, the component it appears in, and the volume.
2. The harvest country for each row, and the name and location of the immediately upstream supplier for that lot.
3. Copies of the mill's purchase invoices for the lots assigned to your order, dated before your production start.
4. Confirmation of whether any species in the order sits in a CITES-listed genus, and who applies for the export permit.
5. A written statement of which species, if any, appear only in substrates, backing layers or inlay contrast strips — the components buyers forget to declare.
6. Agreement that species and origin data will be frozen at order confirmation and that substitution requires your written approval.
7. Sample retention: one physical reference sample per species per order, held by both sides, so a laboratory check later has something to test against.

Mills set up for custom, small-to-medium batch work tend to handle this better than commodity producers, because they already track timber lots by project — a workshop that grain-matches skirting, stair treads and trim to the main floor from the same timber batch has to know which batch went where. Anrantabu Flooring in Huiyang, Huizhou is one example of that project-based model, working in imported precious hardwoods across solid, three-layer and multi-layer structures; as with any mill, the species and origin records are something to request and verify per order rather than assume. For the wider documentation set that surrounds a first shipment, start from the China import compliance requirements guide.