Hardwood Federation warns EUDR geolocation requirement to be 'insurmountable barrier' for US exporters, as fragmented forest ownership complicates tracking and tracing; group supports Lacey Act enforcement, prioritizing US hardwood for federal projects

May 5, 2025 (press release) –

By Merly T. Lapig

TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK , editor, editor@targetednews.com, Springfield, Virginia ; 703/304-1897; https://targetednews.com

WASHINGTON , May 2 -- The Hardwood Federation , a national trade association representing the U.S. hardwood industry, has formally submitted comments to the U.S. Department of Commerce (DOC) regarding its investigation into the effects of wood product imports on national security. In a letter dated April 1, 2025 , addressed to Stephen Astle , Director of the Defense Industrial Base Division, the Federation expressed its appreciation for the opportunity to comment while emphasizing the distinct characteristics of the hardwood sector and the potential pitfalls of a "one size fits all" trade policy.

The DOC investigation, initiated under Docket Number 250310-0030, aims to determine the national security implications of timber, lumber, and their derivative product imports. The Hardwood Federation's detailed response highlights the integrated nature of the U.S. hardwood industry, spanning from logging and manufacturing to the production of a wide array of consumer and industrial goods. These include flooring, furniture, railway ties, and even byproducts like paper and wood fuel pellets. The sector also supports numerous jobs in rural communities across the nation.

Dana Lee Cole , Executive Director of the Hardwood Federation , underscored the industry's commitment to sustainable practices and its vital role in environmental stewardship. "Companies and employees engaged in the U.S. Hardwood economy firmly believe that the sustainable forestry practices used to grow our raw materials, and the manufacturing of products derived from harvest of Hardwood trees are an essential part of promoting high quality rural manufacturing jobs here in the U.S. ," Cole stated in the letter. She further noted that these practices "provide the co-benefit of improving the quality of the environment, which should provide a competitive edge for U.S. exports."

The Federation's comments stressed the fundamental differences between hardwood and softwood markets, urging the DOC to consider these nuances in its investigation. Hardwoods, derived from deciduous trees, possess unique properties and applications compared to softwoods from coniferous trees, impacting their respective import and export dynamics. While the U.S. enjoys a trade surplus in hardwood logs and lumber, derivative products often face deficits due to import competition.

A significant concern raised in the letter is the potential impact of the European Union Deforestation Regulations (EUDR), slated to take effect in December 2025 . The Hardwood Federation argues that the EUDR's stringent requirements for geolocation data for each consignment will create an "insurmountable barrier" for U.S. hardwood exporters due to the fragmented nature of forest ownership in the U.S. "A typical export consignment will include wood potentially derived from several thousands, sometimes even tens of thousands, of individual properties," the letter explained.

To bolster the domestic hardwood industry, the Federation proposed several recommendations, including prioritizing the use of U.S. hardwood products in federal procurement projects. They also advocated for continued funding and enforcement of the Lacey Act to prevent the import of illegally harvested wood.

Furthermore, the Hardwood Federation called for the establishment of a $450 million support fund for industry members who might be negatively impacted by future trade policies that trigger retaliatory tariffs. The proposed relief mechanism would be based on a formula comparing current and base year receipts, with additional support tied to potential price declines in key export species.

In conclusion, Cole emphasized the industry's willingness to collaborate with the government while urging a cautious and well-informed approach to any trade actions. "Before action is taken that will impact our companies' ability to expand global markets and maintain and grow domestic markets, much more thought and analysis needs to be done to understand the differences between Hardwood and softwood markets, the integration of our domestic and international manufacturing processes, and the past, and potentially future impacts on domestic manufacturing if trade actions result in retaliatory action targeting the U.S. Hardwood industry," Cole wrote. The Hardwood Federation stands ready to engage further with the Department of Commerce as the investigation progresses.

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Read full text of the public communication here: https://downloads.regulations.gov/BIS-2025-0011-0056/attachment_1.pdf

View Regulations.gov posting on April 10, 2025 , and docket information here: https://www.regulations.gov/comment/BIS-2025-0011-0056

TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK , editor, editor@targetednews.com, Springfield, Virginia ; 703/304-1897; https://targetednews.com