EU Deforestation Regulation (EUDR) Requirements for Packaging

The EU Deforestation Regulation (EUDR) covers packaging and materials used to manufacture packaging in the EU. However, this does not mean that the EUDR applies to every single paper box or pallet entering the European Union.

In this guide, we explain when the EUDR applies to paper and wooden packaging, and when it does not. We also address common questions about EUDR requirements in the context of packaging.

Does the EUDR apply to packaging?

Here are two common scenarios where the EUDR is applicable to packaging:

1. You import finished packaging materials from suppliers outside the EU

2. You import paper pulp or other materials covered by the EUDR to produce finished packaging inside the European Union

However, an EU guidance page states that packaging that accompanies finished goods and is not resold, but used exclusively as a protective container, is not covered by the EUDR.

Examples

Scenario	Description	EUDR status
Food packaging wholesaler	EU food packaging wholesaler procures paper cups from a factory in Turkey. The paper cups will be resold in the EU.	Applicable
Paper bag factory	EU magazine printing company imports paper rolls that will be used to manufacture paper bags.	Applicable
Watch brand	EU watch brand imports watches from China that come packed in paper boxes. The watch boxes are only used as protective containers and will not be sold individually.	Not applicable
Cargo shipped on pallets	Cargo is imported on pallets. The pallets are only used for transportation and protection and will not be resold.	Not applicable

What kind of packaging is covered by the EUDR?

The EUDR applies to products and materials covered under CN codes listed in Annex I. The following CN codes listed in Annex I can be relevant for finished packaging and raw materials:

4415 Packing cases, boxes, crates, drums and similar packings, of wood; cable-drums of wood; pallets, box pallets and other load boards, of wood;

This CN code applies to protective wooden packaging generally used for transportation. Examples include:

• Pallets
• Box pallets
• Boxes
• Crates
• Drums

Pulp and paper of Chapters 47 and 48 of the Combined Nomenclature, with the exception of bamboo-based and recovered (waste and scrap) products

1. Chapter 47 covers pulp that can be used in packaging manufacturing

2. Chapter 48 covers finished packaging

What packaging is exempt from the EUDR?

Packaging that is only used to protect the contained product is generally not covered by the EUDR.

This can be explained by the fact that the presence of packaging does not impact the applied CN code. For example, a watch delivered in a gift box is still covered by the CN code for watches, not the CN code for boxes.

However, a shipment only containing boxes would require that shipment to be classified under a CN code for boxes.

As the EUDR is only applicable to CN codes listed in Annex I, the applicable CN code generally determines whether or not the EUDR is applicable.

Do we need to comply with the EUDR if we import pulp and paper that is processed into packaging inside the EU?

Yes, Annex I of the EUDR covers chapter 47 of the Combined Nomenclature, which in turn lists the following:

4701 Mechanical wood pulp

4702 Chemical wood pulp, dissolving grades

4703 Chemical wood pulp, soda or sulphate, other than dissolving grades

4704 Chemical wood pulp, sulphite, other than dissolving grades

4705 Wood pulp obtained by a combination of mechanical and chemical pulping processes

4706 Pulps of fibres derived from recovered (waste and scrap) paper or paperboard or of other fibrous cellulosic material

4707 Recovered (waste and scrap) paper or paperboard

Does the EUDR apply to packaging manufactured in the EU?

Yes, the EUDR is applicable, for example, to materials used to manufacture packaging in EU-based production facilities. Here are some examples:

• Wood pulp
• Paper and paperboard
• Paper and paperboard waste
• Paper rolls
• Paper sheets

Does the EUDR apply if we buy packaging from a manufacturer in the EU?

Yes, the EUDR is applicable even in this scenario. However, the obligations differ between:

a. EU companies importing or manufacturing packaging

b. EU brands or retailers buying packaging from other EU companies

Generally speaking, the second category is not subject to the same due diligence requirements as companies that are initially introducing finished packaging or packaging used to manufacture packaging on the EU market.

Which EUDR requirements apply to packaging?

The EUDR does not set requirements specific to packaging. Instead, the requirements generally depend on the following criteria:

1. If you are defined as any of the following:

• SME operator
• SME trader
• Non-SME operator
• Non-SME trader

2. If your supplier is located in a country defined as low, standard, or high risk.

This, in turn, decides which due diligence procedures must be followed and the documentation you need to collect from your supplier. As mentioned, this is only relevant if you buy packaging that will be resold in the EU, or procure materials to produce packaging in the EU.