According the the EC Guidance Documents for the EU Timber Regulation (12.02.2016), the term “Placing on the market” means that a product is supplied:
On the internal market — this means that the timber must be physically present in the EU, either harvested here or imported and cleared by customs for free circulation, as products do not acquire the status of ‘European Union goods’ before they have entered the territory of the customs union. Goods subject to special customs procedures (e.g. temporary importation, inward processing, processing under customs control, customs warehouses, free zones), in transit or being re-exported are not
considered to be placed on the market.
For the first time — timber products already placed on the EU market and products derived from timber products already placed on the market are not covered. Making a product available for the first time further refers to each individual product placed on the market after the date of entry into application of the EU Timber Regulation (3March 2013), and not to the launch of a new product or product line. The concept of ‘placing on the market’ refers to each individual product, not to a type of product, irrespective of whether it was manufactured as an individual unit or a series.
In the course of a commercial activity — timber products must be placed on the market for the purpose of processing or for distribution to commercial or non-commercial consumers, or for use in the business of the operator itself. The Regulation does not impose requirements on non-commercial
All the above elements must be present simultaneously. ‘Placing on the market’ should therefore be understood as occurring when an operator first makes timber or timber products available on the EU market for distribution or for use in the course of its commercial activity. To make it possible to clearly, logically and consistently identify operators, it is necessary to define them according to how their timber is made available on the EU market, which varies depending on whether the timber is harvested inside or outside the EU.
(see the full Guidance document here: https://ec.europa.eu/environment/forests/pdf/eutr_guidance.zip)