Paper & packaging under the EUDR: what's in, what's out

With the EUDR applying to large and medium Operators from 30th December 2026 the question I hear the most from paper and packaging businesses has changed from "does this affect us?" to "which of our products are actually in, and which are out?"

Our first paper and packaging blog covered the basics: pallets, promotional material and recycled content. This article focuses more on the exemptions that catch people out in practice. I've used the examples I come across most often on calls with converters, merchants and brand owners. One rule runs through all of it. Scope starts with the product's HS code and the role it plays when it's placed on the market.

Start with the HS code, not the material

If your product sits under a code listed in Annex I, it's in scope unless there is an exemption. For our sector the codes that matter most are:

• 4415: wooden packing cases, boxes, drums and pallets
• 47: pulp
• 48: paper and paperboard, and articles made from them, such as board, reels and sheets, cartons (4819), labels (4821), and cups and trays (4823)

Printed products under Chapter 49 (books, brochures, catalogues) were taken out of scope by the 2025 amendment. One catch: if a printed item is classified under Chapter 48 rather than 49, it's still in. Get the classification confirmed early. A product that moves from 49 to 48 on a customs ruling moves straight back into scope.

The packaging exemption: it's about the job the packaging does

Packaging is out of scope when it's used only to support, protect or carry another product being placed on the market. The carton around a jar of coffee, the pallet under a load of tiles, the corrugated case around a dozen bottles of wine: none of these needs its own due diligence statement.

The word that matters is "only". The exemption follows the filled product, not the packaging business. It helps the brand owner shipping goods in boxes. It does not help the business that made and sold those boxes. A quick test: is anyone paying for the packaging itself, as the thing they ordered? If yes, it's a product in its own right.

When the packaging is the product, it's in scope

This is where most converters sit. Empty folding cartons, corrugated cases, labels, paper cups and bags are sold as goods in their own right, so they carry the same obligations as the board they're made from.

The same physical item can be in scope for one business and out for the next:

• Folding cartons: in scope for the converter selling them empty to a coffee brand. Out of scope for the coffee brand once they're filled and sold as coffee.
• Pallets: in scope for the manufacturer selling new pallets. Out of scope for the tile maker shipping goods on them.
• Labels: in scope for the printer selling reels of labels. Out of scope for the brand owner once they're applied to its products.

If you're a converter outside the EU, whether in the UK, Switzerland, Turkey or further afield, supplying EU customers, remember that your customer becomes the Operator when the cartons enter the EU. They'll need the evidence from you, so the easier you make that, the easier you are to buy from.

Recycled content: out, but only the recycled part

Products made entirely from material that has completed its life and would otherwise be waste are outside the EUDR. A 100% recovered-fibre board is the clean case.

However, most boards aren't 100% recycled. Where virgin and recycled fibre are mixed, due diligence applies to the virgin share. That means you need two things from your mill: the split between recycled and virgin content, and the traceability data for the virgin part. A "recycled" label on a spec sheet isn't enough on its own. Ask for the percentage in writing and keep it with the batch records.

The exemption covers post-consumer and post-industrial material that would otherwise have been discarded as waste, and you need to be able to prove it. The EUTR guidance gives a useful steer on acceptable evidence: certification of recycled material, a supplier confirmation backed by photos of the sorted waste, waste handling licences, and a technical dossier or test report stating the recycled content by weight.

If you’re a downstream non-SME operator or trader buying from an EU mill, and the virgin share is already covered by the mill’s Due Diligence Statement, you don’t need to repeat the due diligence yourself. But you do need to ascertain that it was done. The Commission’s April FAQs (3.4) say this means collecting the reference and verification numbers of the upstream DDS and checking they’re valid, either in TRACES or through Interu. They also suggest optional further checks on whether the country of production, quantities and HS codes in the DDS are complete and plausible. You don’t need to check every DDS.

The Commission’s August guidance goes further, suggesting downstream businesses could check that their suppliers have a working, up-to-date due diligence system, with proportionate policies, controls and procedures. In practice, that means asking your mill how it verifies its recycled content and how it traces the virgin fibre.

EU board that leaves and comes back

This matters a lot for converters outside the EU who buy board from EU mills and send finished cartons back into the EU. That covers UK converters, but also businesses in Switzerland, Turkey, the Balkans and North Africa that supply the EU market. 

(Note: Norway is a special case. It’s government has decided to adopt the EUDR's timber and paper provisions through the EEA Agreement, aiming to apply them at the same time as the EU or soon after. Norwegian businesses should plan to work within the same rules).

Material that was already placed on the EU market doesn’t need a fresh due diligence statement when it returns, and Commission guidance confirms this covers products made from EU material, not just goods returned unchanged.

In most cases you won’t have the original DDS reference numbers, and that’s fine. Your EU customer, as importer, uses a conventional DDS reference on the customs declaration instead: 22EU2222222222 or 99EU9999999999, depending on when the goods were previously in the EU. That goes alongside TARIC document code C720 for larger importers or C725 for SMEs.

What your customer does need is proof that the material was placed on the EU market and then exported, such as export declarations, invoices, bills of lading or CMRs. That proof only holds up if you can link each board batch to the carton batch made from it.

My advice: keep that paperwork from your EU suppliers and store it against each batch, not in an inbox. If a supplier can give you the original DDS references too, keep those as well, but the batch link is what matters most.

Mixed materials: where the paperwork has to add up

One product can fall under several of these exemptions at the same time, and this is where it becomes complicated. For example, a single carton might contain EU-origin board, a liner from outside the EU and some recycled fibre. Only the non-EU virgin material needs new due diligence, but the customs declaration still covers the whole product.

This is acceptable, as long as your records show where each part came from. If they don't, the simplest option is to treat the whole product as needing due diligence. That creates extra work for your customer. Traceability at batch level is what allows you to use the exemptions in practice.

Five things to check before 30 December 2026

1. Confirm the HS code of every product you sell, especially anything sitting between Chapters 48 and 49.
2. Separate products you sell as standalone packaging from packaging you only use to ship other goods.
3. Get the recycled and virgin split in writing from each mill.
4. Collect reference numbers from EU suppliers and link them to batches.
5. Check you can trace each component of a mixed product back to its source.

Exemptions only count if you can prove them

Every exemption in this blog depends on evidence: the HS code confirmed, the recycled split in writing, the EU reference numbers linked to the right batch. Most businesses have that information somewhere, spread across mill emails, spec sheets and spreadsheets. On 30th December, "somewhere" won't be good enough.

Interu brings it into one place. Your team collects supplier evidence, links it to each batch, and files due diligence statements from the same system. When a customer or authority asks why a product is out of scope, you can show them in minutes rather than days. And because your EU customers need that evidence from you, being able to hand it over cleanly makes you the easier supplier to buy from.

If you want to see how it works with your own products and suppliers, get in touch and we'll walk you through it.

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