EUDR and Packaging: When Paper, Cartons and Pallets Need Deforestation Due Diligence
Does the EUDR Apply to Packaging?
The EU Deforestation Regulation, Regulation (EU) 2023/1115, covers paper, board and wooden packaging listed in its Annex I when placed on the market or exported as a product on its own. Under Delegated Regulation (EU) 2026/2102, packing material and packing containers used exclusively to support, protect or carry another product, and presented with that product, are outside that scope.
Delegated Regulation (EU) 2026/2102 of 13 July 2026 was published in the Official Journal on 17 September 2026 and, under its Article 2, entered into force on the day following its publication. This article reads the new entries for converters of paper, board and labels, pallet makers and poolers, importers of empty packaging, and brand owners and retailers. The PPWR side of the same pallets and cartons is covered in our articles on transport packaging for importers and on pallet pooling.
Key Facts
- Delegated Regulation (EU) 2026/2102, published in the Official Journal on 17 September 2026, replaces the Annex I entries of Regulation (EU) 2023/1115 for paper and paperboard, wooden packing cases and pallets, and casks.
- Under the new ex 48, ex 4415 and ex 4416 entries, single use packing material and packing containers used exclusively to support, protect or carry another product, and presented with that product, are not included.
- Under Article 38(2) of Regulation (EU) 2023/1115, as replaced by Regulation (EU) 2025/2650, Articles 3 to 13, 16 to 24, 26, 31 and 32 apply from 30 December 2026.
- Under Article 6(1), all packaging placed on the market shall be recyclable, an obligation that has applied since 12 August 2026, transport packaging included.
- Our dated PPWR referential (baseline reviewed 15 September 2026) confirms the line on Article 6(1); the other lines are read on EUR-Lex on 23 September 2026.
What Did Delegated Regulation (EU) 2026/2102 Change for Packaging?
Delegated Regulation (EU) 2026/2102 rewrote the Annex I entries of Regulation (EU) 2023/1115 for paper and paperboard, wooden packing cases and pallets, and casks. Each of these three entries excludes single use packing used exclusively to support, protect or carry another product presented with it, and packing clearly suitable for repetitive use from the moment it is used that way.
| Entry | Before Delegated Regulation (EU) 2026/2102 | After Delegated Regulation (EU) 2026/2102 |
|---|---|---|
| 4415: wooden packing cases, boxes, crates, drums, pallets, box pallets, load boards, pallet collars | Not including packing material used exclusively as packing material to support, protect or carry another product placed on the market | ex 4415: not including used and second-hand products, single use packing, and packing clearly suitable for repetitive use from its first use as packing |
| 4416: casks, barrels, vats, tubs and other coopers' products | No packing exclusion | ex 4416: the same three exclusions as ex 4415 |
| Paper and paperboard | Pulp and paper of Chapters 47 and 48, except bamboo-based and recovered (waste and scrap) products | ex 48: the same three exclusions, plus waste, recovered products and products derived from them, and marketing and information materials exclusively accompanying another product |
Recital 16 of Delegated Regulation (EU) 2026/2102 states that packing materials and packing containers placed on the Union market or exported as products on their own fall within the scope of Regulation (EU) 2023/1115. For packing clearly suitable for repetitive use, recital 16 adds that the exclusion applies regardless of whether the product carried is within that scope.
According to the Commission guidance published on 20 July 2026, relevant products made entirely from recycled material are not subject to the EUDR, while any amount of non-recycled material, such as virgin pulp used in paper production, is.
From When Do the EUDR Obligations Apply to Packaging?
Under Article 38(2) of Regulation (EU) 2023/1115, as replaced by Regulation (EU) 2025/2650 of 19 December 2025, the obligations of operators, downstream operators and traders apply from 30 December 2026. For paper packaging and for wooden packing cases, pallets and casks, the later date of 30 June 2027 for micro and small undertakings does not apply.
Article 38(3) of Regulation (EU) 2023/1115 sets 30 June 2027 for operators that are natural persons or micro or small undertakings established by 31 December 2024, except as regards the products covered by the Annex to Regulation (EU) No 995/2010, the EU Timber Regulation. That Annex lists headings 4415 and 4416 00 00 and pulp and paper of Chapters 47 and 48, except bamboo-based and recovered products.
Under Article 37(1) of Regulation (EU) 2023/1115, the EU Timber Regulation is repealed with effect from 30 December 2026. In its simplification review of 4 May 2026, the Commission did not consider it appropriate to propose further amendments to the basic legal text.
Who Carries the EUDR Obligations in a Packaging Supply Chain?
Under Articles 4 and 5 of Regulation (EU) 2023/1115, the operator that first places packaging on the market as a product exercises due diligence and submits a due diligence statement. A downstream operator, which makes packaging from paper or wood already covered by a statement, and a trader keep supplier and customer data instead, without a statement of their own.
An operator is any natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them, excluding downstream operators, under Article 2(15) of the consolidated Regulation (EU) 2023/1115. A downstream operator is any natural or legal person who, in the course of a commercial activity, places on the market or exports relevant products made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration, under Article 2(15b). A trader is any person in the supply chain other than the operator or downstream operator who, in the course of a commercial activity, makes relevant products available on the market, under Article 2(17). Placing on the market is the first making available of a relevant product on the Union market, under Article 2(16). Imported products are placed on the market when released for free circulation, according to the Commission guidance.
Under Article 4(7), operators communicate the reference numbers of their due diligence statements to downstream operators and traders. Under Article 5(3), downstream operators and traders collect the name, postal address and email address of their suppliers and of the downstream operators and traders they supply. Only where the supplier is an operator do they also collect the reference numbers. Under Article 5(4), they keep that information for at least five years. Under Article 5(2), downstream operators and traders that are not SMEs register in the information system of Article 33 first.
| Role | Packaging concerned | Position under Regulation (EU) 2023/1115 |
|---|---|---|
| Paper or board converter buying board in the Union | Empty boxes, cartons and paper bags sold as products | Downstream operator: supplier and customer data, plus reference numbers where the supplier is an operator |
| Importer of board or of empty packaging | Paper packaging, wooden cases or pallets released for free circulation | Operator: due diligence and a due diligence statement before placing on the market |
| Label converter | Paper labels sold to brand owners | Generally in scope when sold on their own, under recital 17; role as in the rows above |
| Pallet manufacturer | New wooden pallets and cases sold as products | Downstream operator when all its timber is covered by a statement; operator for timber or pallets it imports |
| Pallet pool operator | Pooled pallets after their first use | Outside the scope from first use as packing; new timber used to repair pallets is subject to the Regulation, according to the Commission guidance |
| Brand owner | Boxes, cartons and pallets carrying its goods | Outside the scope for that packaging; operator only for empty packaging it imports itself |
| Retailer | Empty boxes or paper gift bags sold as goods | Trader when buying in the Union: supplier data and, where the supplier is an operator, reference numbers |
The PPWR importer is a different role, described in our article on PPWR importer obligations.
Is a Pallet Under the EUDR the Same Thing as a Pallet Under the PPWR?
No. The same wooden pallet meets two regulations with different triggers. Under the ex 4415 entry of Regulation (EU) 2023/1115, a pallet placed on the market as a product on its own is in scope, and excluded once used exclusively to carry goods. Regulation (EU) 2025/40 treats a pallet as transport packaging, empty or with a product.
| Question | Regulation (EU) 2023/1115 | Regulation (EU) 2025/40 |
|---|---|---|
| What triggers it | Placing on the market or export of a relevant product listed in Annex I | Packaging placed on the market, whether empty or with a product, under Article 3(1)(10) |
| New pallet sold empty | In scope under ex 4415 | Transport packaging, under Article 3(1)(7) |
| Pallet carrying goods | Outside the scope, under the ex 4415 exclusions | Transport packaging, under Article 3(1)(7) |
| Pooled pallet on later trips | Outside the scope from its first use as packing onwards | Transport packaging, within the Article 29 re-use targets from 1 January 2030 |
| What is shown | Deforestation-free, produced in line with the law of the country of production, covered by a due diligence statement, under Article 3 | Requirements such as recyclable design under Article 6(1), applicable since 12 August 2026 |
Transport packaging is packaging conceived so as to facilitate the handling and transport of one or more sales units or a grouping of sales units, under Article 3(1)(7) of Regulation (EU) 2025/40. Regulation (EU) 2025/40 applies to all packaging, regardless of material, whether household, commercial or industrial, under Article 2(1). The Article 29 re-use targets bind the economic operators that use transport packaging within the territory of the Union. Article 29(1) lists pallets, pallet wrappings and straps among the transport packaging concerned from 1 January 2030.
Our guide to sales, grouped and transport packaging describes each level.
What Should Packaging Buyers Ask Their Suppliers?
Packaging buyers can ask each supplier whether the packaging is delivered as a product on its own under Regulation (EU) 2023/1115, which role the supplier holds, and, from a supplier that is an operator, the reference numbers of its due diligence statements, which Article 4(7) requires operators to communicate to downstream operators and traders.
- The role. Operator, downstream operator or trader, for each item delivered as a product on its own.
- The reference numbers. From a supplier that is an operator, the due diligence statement reference numbers or declaration identifiers that downstream operators and traders collect under Article 5(3).
- The supplier details. The name, postal address, email address and, if available, web address listed in Article 5(3).
- The fibre. Whether the paper or board is made entirely from recycled material, which the Commission guidance places outside the EUDR, or contains virgin pulp.
A brand owner that only fills packaging with its own goods is not named in the reference-number chain of Articles 4(7) and 5(3) for that packaging.
What Does the Referential Not Confirm?
Our dated PPWR referential (baseline reviewed 15 September 2026) covers Regulation (EU) 2025/40 only. It confirms three statements here: the scope of Article 2(1), the recyclability obligation of Article 6(1) and the territorial reach of the Article 29 re-use targets. The points below were read on the linked texts on 23 September 2026.
- Every statement on Regulation (EU) 2023/1115 and the acts amending it, on Regulation (EU) No 995/2010 and on the Commission guidance, report and pages.
- Articles 3(1)(7), 3(1)(10) and 29(1) and Annex I, point B, of Regulation (EU) 2025/40, and the absence of the words deforestation and due diligence from its text, read on the Official Journal text, not recorded in our referential.
- Our readings: the role table, including the brand owner that imports empty packaging as an operator, and the buyer that only fills packaging, outside the reference-number chain. No customs heading is named for labels.
- Not read: the full Commission FAQ on the EUDR. Nothing here is legal advice.
Frequently Asked Questions
Are paper labels within the scope of the EUDR?
Labels placed on the market as products on their own generally fall within the scope of Regulation (EU) 2023/1115, according to recital 17 of Delegated Regulation (EU) 2026/2102. Labels accompanying another product do not. Under Annex I, point B, of Regulation (EU) 2025/40, a label hung directly on or attached to a product is packaging.
Does the PPWR require deforestation due diligence?
No. Neither the word deforestation nor the words due diligence appear in the Official Journal text of Regulation (EU) 2025/40. Deforestation due diligence sits in Regulation (EU) 2023/1115.
How PPWR Connect Helps
PPWR Connect is software for Regulation (EU) 2025/40: it does not perform EUDR due diligence, does not file due diligence statements and is not a legal adviser. Its shared component library defines a part such as a label once, reuses it across SKUs and shows where each part is used. A packaging item can record its use context and whether it belongs to a reuse system. Each recorded value keeps where it came from: manual entry, import or supplier document. A supplier PDF such as a certificate or a datasheet is read by the platform and filed as evidence against the SKU for the Declaration of Conformity. To see which packaging parts are shared across your SKUs, start with our PPWR compliance software or the PPWR readiness assessment.
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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.