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).
Up to date as of July 2026
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, and guides made from paper or paperboard fall within the scope of the EUDR if they are distributed in a commercial context (i.e.,not for private use or personal consumption). 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.
On 13 July 2026, the European Commission adopted a Delegated Act confirming that the following are excluded from the EUDR:
- User manuals, information leaflets, catalogues, brochures, marketing materials as well as labels accompanying other products, unless they are placed or made available on the market or exported in their own right. Refer to FAQ 2.5
- Samples of negligible value and quantity, and used only to solicit orders for goods. This includes products used for examination, testing and analysis. Refer to FAQ 2.14
The Delegated Act now goes to the European Parliament and the Council for a standard scrutiny period before it formally enters into force. Neither body can amend the text, only object to it, so we don't expect the substance to change.
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 Commission's July 2026 Delegated Act confirms this directly: packing materials and packing containers used exclusively to support, protect, or carry another product are not "relevant products" and sit outside 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. If you are importing 100% recycled materials under the exemption TARIC code Y133, be prepared to be able to evidence on request that the goods are indeed 100% recycled.
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
Items of Correspondence
Letters, postcards and other ‘items of correspondence’ which are not subject to customs declarations and which are not placed on the EU market but rather serve a communication purpose, are exempt from having to submit DDS. Per FAQ 2.13, relevant products contained in items of correspondence (e.g. in an envelope) cannot be considered as ‘items of correspondence’ and therefore, where applicable, are subject to customs declaration requirements and to the presentation of a DDS reference number.
Rented Goods
If a product is rented or leased, i.e., not placed on the EU market and where there is no legal transfer of ownership, it is deemed to be not in scope of the EUDR.
Refer to FAQ 2.15
Second Hand Products
If a product has completed its lifecycle and sold as a secondhand item when otherwise it would have been disposed of as waste, it is not subject to the obligations of EUDR.
Refer to FAQ 2.7
What's New: Simplified Submission Rules (Implementing Regulation (EU) 2026/1565)
New: Products Used in Medicinal Manufacturing
The July 2026 Delegated Act also excludes certain palm oil-derived oleochemicals (such as specific fatty alcohols, glycerol, and related acids) when used in the manufacture of human or veterinary medicinal products under EU pharmaceutical law. This is a narrower exclusion than it might first appear — it doesn't cover pharmaceutical manufacturing inputs generally, only this specific palm oil derivative category.
What Else Changed in July 2026
Alongside the scope confirmations above, the Commission also adopted an Implementing Act updating the EUDR Information System, the platform businesses use to submit due diligence statements. It introduces simplified declarations for micro and small primary operators, the ability to group multiple due diligence statements together, and contingency arrangements for when the system is unavailable.
Separately, the Delegated Act adjusts the product list in Annex I itself. Cattle hides, skins and leather, retreaded tyres, soybeans for sowing, and several rubber and seating products are removed from scope. Soluble coffee, certain palm oil derivatives, and frozen cattle tongues are added, taking effect from 30 December 2027. These changes sit outside the packaging and promotional materials covered here, but they're worth a look if your business touches any of those commodities.
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.
- Products used in the manufacture of medicinal products are now excluded, following the July 2026 Delegated Act.
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.
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