The EU Deforestation Regulation (EUDR) has introduced critical due diligence requirements to combat deforestation and forest degradation linked to global supply chains. For operators and traders, ensuring compliance is a must, including compliance of materials like wood, paper, and packaging.
As businesses across the supply chain work to navigate the complexities of this regulation, many questions have arisen - especially around the scope of packaging materials. Here, we break down the key considerations for packaging under the EUDR, incorporating the latest updates from the European Commission and the official EUDR Documentation (Annex 1).
Are Promotional Materials - Samples, Brochures, Guides in Scope?
The Regulation targets "relevant products" placed on the EU market or exported from it. These products are defined as those containing, produced with, or made from commodities like cattle, cocoa, coffee, oil palm, rubber, soya, and wood.
Printed materials such as books, newspapers, brochures, and guides made from paper or paperboard fall within the scope of the EUDR if they are distributed in a commercial context. Even if provided for free, these promotional materials must be compliant, as they are considered "relevant products" when made from or containing wood-based products. That being said, if promotional materials (like brochures) accompany a product that is in-scope or otherwise, then they do not need to comply with the EUDR.
Are Pallets in Scope?
Yes, pallets are subject to the Regulation, but there is an important nuance. Wooden packaging items like pallets are excluded from the EUDR if used exclusively for supporting, protecting, or carrying another product placed on the market. In other words, pallets become relevant only if they are sold or used as standalone products. If they are part of the shipping process for another product, they do not fall under the Regulation.
Reference FAQ 2.6
When is Packaging in Scope?
Packaging, especially when made of wood, can be a grey area, however, the key distinction lies in the purpose of the packaging. If packaging is used to support or protect another product and is not marketed as a standalone item, it typically falls outside the scope of the Regulation.
The updated FAQ clarifies this point, confirming that if packaging materials (like wooden crates or pallets) are used exclusively to support another product, they are not considered "relevant products" and are therefore excluded from the Regulation.
However, if packaging is sold as an independent product (such as wooden packaging sold to manufacturers), due diligence requirements must still be applied.
Reference FAQ 2.5
Does EUDR Apply to Recycled Materials?
One of the most common concerns among companies is whether EUDR applies to recycled materials. The short answer is: it depends. The Regulation does not apply to goods made entirely from materials that have completed their lifecycle and would otherwise have been discarded as waste. This includes recycled materials from commodities like wood, provided they have already fulfilled their lifecycle.
However, recycled materials that are by-products of manufacturing processes may still fall under the scope of the Regulation, and companies should ensure they are conducting proper due diligence.
Reference FAQ 2.8
Key Takeaways
- Packaging made from relevant commodities (like wood) must meet EUDR requirements, unless it’s used solely for protecting, supporting, or carrying another product.
- Promotional materials made from wood/paper are subject to the Regulation if they are distributed for commercial purposes.
- Recycled materials made from finished goods are not subject to EUDR, but by-products might be.
- Pallets and packaging materials are only in scope if they are sold as standalone products.
At Interu, we help businesses navigate the evolving landscape of EUDR compliance with precision and ease. Whether you're dealing with packaging, promotional materials, recycled goods or any other wood-related products, understanding and managing your due diligence requirements is essential.
Ready to ensure your business is fully compliant? Contact us today to learn how Interu can simplify your EUDR compliance journey and help you protect your market access.
