Planning to import or manufacture wooden products for sale in the United Kingdom? Then, you are obliged to ensure compliance with various regulations covering material traceability, safety standards, chemicals, labelling, and documentation requirements.
In this guide, we take closer look at Timber Regulation (EU) 995/2010, The Furniture and Furnishings (Fire) (Safety) Regulations 1988, and other regulations applicable to wooden furniture, and other wooden products in the UK.
Content Overview
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Timber Regulation (EU) 995/2010
The Timber Regulation (EU) 995/2010 establishes requirements for timber and timber products in the United Kingdom. The list of covered timber products is provided in the Annex. Here are some examples:
- Bedroom furniture
- Dining room furniture
- Living room furniture
- Frames for photos or paintings
- Seats with wooden frames
- Pallets
- Barrels
The Timber Regulation (EU) 995/2010 is the UK version of the EU Timber Regulation, and there may be some differences between the two.
Also, note that The Timber and Timber Products (Placing on the Market) Regulations 2013 set requirements for enforcing the Timber Regulation (EU) 995/2010 in the UK.
Due diligence requirements
The Timber Regulation (EU) 995/2010 requires operators, which are defined as legal entities that sell timber or timber products in the UK, to exercise due diligence by:
- Ensuring access to relevant information
- Assessing possible risks
- Mitigating the risks
The above-mentioned information should contain:
a. The product’s description:
- Trade name
- Product type
- Common name of tree species
- Full scientific name of tree species (where applicable)
b. Country of harvest:
- Sub-national region of harvest (where applicable)
- Concession of harvest (where applicable)
c. Quantity (in volume, weight, or number of units)
d. The supplier’s name and address to the operator
e. The trader’s name and address
f. Compliance documents
FLEGT and CITES
Wooden products that comply with the requirements of the following are considered to conform with the obligations of the Timber Regulation (EU) 995/2010:
a. Forest Law Enforcement, Governance and Trade (FLEGT), and
b. Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)
Protective Measures Against Pests of Plants Regulation (EU) 2016/2031
This regulation establishes requirements for determining phytosanitary risks posed by plant pests and mitigating said risks. It covers plants and plant products.
This section focuses on requirements for plant products, which are defined as raw plant materials and any processed products that could potentially spread quarantine pests due to their nature or how they’re made.
The regulation considers wood to be a plant product only if at least one of the following conditions is true:
a. It keeps some or all of its natural round shape, with or without bark
b. It loses its natural rounded shape due to cutting, sawing, or splitting
c. It has become scrap wood and has not been processed to create pellets, plywood, or particleboard
d. It has been, or would be, used as packaging material, whether or not it’s currently used for transporting products
Operators – defined as any person or entity involved in the production, processing, storage, transport, or sale of plants and related products that may spread pests – should:
a. Conduct surveillance and reporting on the presence of pests
b. Maintain records to ensure traceability of plant products
c. Ensure that plant products are accompanied by a phytosanitary certificate
d. Comply with import controls to prevent pest introduction
e. Have contingency plans in place to manage pest outbreaks
Note that the Protective Measures Against Pests of Plants Regulation (EU) 2016/2031 is the UK version of the EU regulation with the same name, but differences between the two may exist. Also, the Official Controls (Plant Health and Genetically Modified Organisms) (England) Regulations 2019 sets requirements for enforcing the UK version of the regulation.
Phytosanitary certificate
The provision of a phytosanitary certificate applies to the introduction of some plant products into the United Kingdom.
The certificate should contain the items listed in Annex V and certify that the plant product complies with the requirements listed in Article 71.
UK plant passport
The UK plant passport is a label that should contain the following items as listed in Part A of Annex VII:
- The words “UK Plant Passport” in the upper right-hand corner
- The letter “A”, followed by the plant’s botanical name
- The letter “B”, followed by the professional operator’s registration number
- The letter “C”, followed by the plant or plant product’s traceability code
- The letter “D”, followed by – where applicable – the third country of origin (“GB” if originating from Great Britain)
The passport applies to plants and plant products when they are:
a. Moved within Great Britain
b. Introduced into Great Britain from a CD territory (Bailiwick of Guernsey, the Bailiwick of Jersey or the Isle of Man), or
c. Introduced into a CD territory from Great Britain
ISPM15
The regulation requires the following products to comply with the requirements of International Standard for Phytosanitary Measures No. 15 (ISPM15) – Regulation of wood packaging material in international trade:
a. Wood packaging material imported into the UK from a third country
b. Wood packaging material marked in the UK and exported into a third country
c. Wood packaging material moving within the UK
d. Other wood packaging material marked within the UK
Specifically, such products should:
a. Be subjected to approved treatments and comply with the other requirements set in Annex 1 of the standard
b. Carry a mark indicating compliance with ISPM15 that is applied by authorised professional operators
The Furniture and Furnishings (Fire) (Safety) Regulations 1988
The Furniture and Furnishings (Fire) (Safety) Regulations 1988 establish fire safety standards and labelling requirements for furniture products – including cushions and filling materials incorporated in wooden furniture – that pose flammability risks.
Here are some examples of covered products:
- Chairs
- Bed bases
- Headboards
- Children’s furniture
The regulations require products to comply with several standards, which in turn set tests such as:
- Ignitability tests
- Cigarette tests
- Match tests
- Ignition resistance tests
It also sets labelling requirements.
Standards
You should ensure that your product complies with the standards mentioned by the regulations:
BS 3379 – Combustion modified flexible polyurethane cellular materials for loadbearing applications. Specification
BS 5651 – Cleansing and wetting procedures for use in the assessment of the effect of cleansing and wetting on the flammability of textile fabrics and fabric assemblies
BS 5852-1 – Fire tests for furniture – Methods of test for the ignitability by smokers’ materials of upholstered composites for seating
BS 5852-2 – Fire tests for furniture – Methods of test for the ignitability of upholstered composites for seating by flaming sources
Labelling requirements
The regulations require furniture to carry the appropriate display labels set out in Schedule 6 and the permanent labels set out in Schedule 7.
Appropriate display labels
Schedule 6 applies to some types of wooden furniture, such as cots and high chairs. It does not apply to bed bases, cushions, mattresses, and pillows.
Parts II and III of Schedule 6 provide examples of appropriate display labels.
The label in Part II must be used for compliant products and it should contain:
a. A pictograph of a match and a cigarette, and the word “RESISTANT” on one side
b. The “Filling material(s)” statement and the phrase “CARELESSNESS CAUSES FIRE” on the other
The label in Part III should be used when the cover does not comply with all the requirements and it should contain:
a. An exclamation mark and the phrase “COVER FABRIC NOT MATCH RESISTANT” on one side
b. The “Meets the 1988 safety regulations […]” statement and the phrase “CAUTION CARELESSNESS CAUSES FIRE” on the other
Permanent labels
Schedule 7 covers permanent labels for some types of furniture, which includes wooden furniture, such as cots and high chairs, but does not cover bed bases and mattresses. It lists the information that permanent labels should contain:
- The words “CARELESSNESS CAUSES FIRE”
- Manufacturer or importer name and postal code of the address
- Batch or identification number
- Manufacture or import date
- Description of filling material
- Description of covering materials
- Whether the product includes an interliner
REACH Regulation (EC) 1907/2006
The REACH Regulation (EC) 1907/2006 establishes substance restrictions, including in articles. This would include paints, coatings, and treatments that may be applied to wooden products. This regulation is the UK version of the EU REACH Regulation, and some differences between the two, such as the list of restricted substances, may exist.
Note that the REACH Enforcement Regulations 2008 establish requirements for enforcing the REACH Regulation (EC) 1907/2006.
Restricted Substances (Annex XVII)
Annex XVII lists substances that are restricted in articles, including substances that may be found in wooden products.
Here are some examples of listed substances that may be found in wooden products:
a. Creosote, wood – banned from use in wood treatment; treated wood is prohibited from use in toys and garden furniture (e.g. picnic tables), for instance
b. Mercury compounds – banned from use in wood preservation
c. Arsenic compounds – banned from use in wood preservation
Note that some substances, such as certain phthalates, are restricted in articles in general. As such, they would also be restricted in wooden products and their components.
UK REACH Candidate List
The UK REACH Candidate List contains substances of very high concern (SVHC), which are deemed to be dangerous for humans and the environment.
If your product contains over 0.1% of a substance listed on the UK REACH Candidate List, you should notify:
a. The Health and Safety Executive, as well as
b. Consumers, and provide them information, such as the name of the substance, that allows them to use the product safely
Here are some examples of substances that may exist in the paints, coatings, or treatment of wooden products:
- Boric acid (used as a fungicide, insecticide, and preservative)
- Sodium dichromate (used as a preservative and insecticide)
- Chromium trioxide (used as a wood treatment)
Standards
You should use standards to assess the safety of your product.
Referenced standards
Here are some examples of standards referenced under The General Product Safety Regulations 2005 that cover products that may contain wood:
EN 716-1 – Furniture – Children’s cots and folding cots for domestic use – Part 1: Safety requirements
EN 914 – Gymnastic equipment – Parallel bars and combination asymmetric/parallel bars – Requirements and test methods including safety
EN 1130 – Children’s furniture – Cribs – Safety requirements and test methods
EN 14988 – Children’s high chairs – Requirements and test methods
When your product complies with the referenced standards, you can assume that it complies with the safety requirements of the regulation. Note that some regulations use the term “designated”, instead of “referenced”.
Other standards
If you cannot find referenced standards for your wooden product, you can still use other standards to ensure product compliance. For instance, the BSI Group website lists various safety standards for wooden products. Here are some examples:
BS EN 15119-2 – Durability of wood and wood-based products. Determination of emissions from preservative-treated wood to the environment – Wooden commodities exposed in Use Class 4 or 5 (in contact with the ground, freshwater or seawater). Laboratory method
BS 1722-7 – Fences – Specification for wooden post and rail fences
BS 3459 – Specification for stands for drawing boards
BS 1722-5 – Fences – Specification for close-boarded fences and wooden palisade fences
Recalls and compliance risks
Non-compliant wooden products are dangerous as they may pose hazards, such as choking hazards to kids due to small parts or risk of fire, for example, when they contain components that are highly flammable.
The UK’s Product Safety Alerts, Reports and Recalls page lists various recalled wooden products. Here are several examples and the reasons for their recall:
a. Wooden candle holder – recalled for violating the General Product Safety Regulations 2005, risk of fire due to high temperatures
b. Beechwood children’s high chair – recalled for violating the General Product Safety Regulations 2005, risk of injuries due to potential cracking
c. Wooden train track set – recalled for violation of the Toys (Safety) Regulations 2011, risk of choking and death via accessible magnets
d. Wooden camera for children – recalled for violating the Toys (Safety) Regulations 2011, risk of choking on small parts
e. Wooden block puzzle – recalled for violating the Toys (Safety) Regulations 2011, risk of strangulation due to extended cord length
f. Wooden nesting dolls – recalled for violating the Toys (Safety) Regulations 2011, risk of choking due to small elements, and suffocation due to part not having an opening
Lab Testing
You should get your wooden products tested to prove they are safe to use, regardless of whether a regulation explicitly requires testing or not.
Testing should be performed against relevant standards and requirements. For instance, you should subject your upholstered furniture to flammability tests such as fire tests and ignitability tests to ensure it does not catch fire as easily.
If your product passes testing, you should receive a test report proving product compliance.
Additional Requirements
Wooden products may be subject to additional requirements, such as those explained below.
| Regulation | Description |
| The General Product Safety Regulations 2005 | These regulations establish requirements for general consumer products, which would include wooden products such as furniture. Producers (that is, brands, importers, and manufacturers) should:
a. Make sure their products comply with relevant safety standards and are safe for use b. Provide product-specific warnings and instructions c. Affix traceability information to the product or its packaging |
| The Toys (Safety) Regulations 2011 | These regulations set requirements for the safety of toys, which include wooden toys.
Importers and manufacturers should generally: a. Ensure their product complies with designated standards (e.g. EN 71-1), substance restrictions (e.g. limit value for formaldehyde in resin-bonded wood), and other requirements b. Provide documentation (e.g. Declaration of Conformity, technical documentation, test report, user instructions) c. Provide product labels (e.g. UKCA, marking, traceability information, and warnings) |
| Construction Products Regulation (EU) 305/2011 | This regulation sets quality, performance, and safety requirements for construction materials and products. This also includes products made of wood, such as:
The regulation generally requires importers and manufacturers to provide:
|
| Persistent Organic Pollutants Regulation (EU) 2019/1021 | This regulation sets restrictions on POPs and products that contain POPs. Wooden products may contain POPs in the finishes, treatments, and fire retardants, for instance. Here are some examples of restricted POPs in wooden products:
Note that The Persistent Organic Pollutants Regulations 2007 sets requirements for enforcing the Persistent Organic Pollutants Regulation (EU) 2019/1021. |
