Most packaging teams hear "EU Deforestation Regulation" and mentally file it under someone else's problem - the sustainability team, the cocoa buyer, the coffee procurement lead. That assumption is wrong, and it is going to cost companies that hold it.
Regulation (EU) 2023/1115 - the EUDR - covers seven commodity groups, one of which is wood and its derived products. Wood-derived products include pulp, paper, and paperboard. That means corrugated shippers, folding cartons, kraft paper, solid board, and wooden transport packaging can all fall within the regulation's scope. If your company places paper- or wood-based packaging on the EU market as a standalone product, or imports it from outside the EU, you may be an operator under the EUDR - with full due diligence obligations - even if your core product has nothing to do with forestry.
This article explains exactly which packaging materials are affected, what the due diligence obligation requires, how the operator/trader/downstream operator distinction works after the December 2025 amendments, and what your team should be doing right now.
The Current EUDR Timeline (Updated for Mid-2026)
The EUDR has been delayed twice. It is worth being precise about where things stand.
Regulation (EU) 2023/1115 entered into force on 29 June 2023. The original application date was December 30, 2024, then pushed to December 30, 2025. In late 2025, the EU legislature acted again.
Regulation (EU) 2025/2650, published in the Official Journal on 23 December 2025, postpones the EUDR application date to 30 December 2026 for large and medium operators and traders, and to 30 June 2027 for micro and small enterprises. The Council and Parliament formally adopted the amendment on 17-18 December 2025 following a political agreement reached on 4 December 2025.
Three things the delay does not change:
- The product scope in Annex I - paper, board, and wood packaging remain in scope
- The core due diligence obligations under Articles 8-11
- The geolocation traceability requirement to plot level
The delays have been driven by operational readiness concerns - including the stability of the EU TRACES information system, which was temporarily taken offline in February 2026 for updates aligned with the new amendment. The substantive compliance work cannot wait for the system to be ready.
The deadline is December 30, 2026 for large and medium companies. Two delays have already occurred. Legal analysis published since December 2025 is consistent: the delays have not changed the core compliance obligations. Companies that have not started supplier data collection are already behind.
Which Packaging Materials Are Actually in Scope?
Annex I of the EUDR covers seven commodity groups: cattle, cocoa, coffee, oil palm, rubber, soya, and wood - along with their derived products, identified by specific CN/HS codes. For packaging teams, the relevant chapters are:
| CN Chapter | What it covers | Packaging relevance |
|---|---|---|
| HS 44 | Wood and articles of wood | Wooden crates, pallets, cable drums, box pallets (CN 4415) |
| HS 47 | Wood pulp and fibrous cellulosic material | Pulp used in packaging manufacturing |
| HS 48 | Paper and paperboard | Corrugated board, kraft paper, folding carton board |
Two important carve-outs apply, and both matter enormously for packaging teams:
Carve-out 1: Purely protective/carrier packaging is excluded. Packaging materials used solely to support, protect, or carry another product placed on the market are not subject to the regulation. A corrugated shipper that goes out with your product and is never sold separately is generally exempt.
Carve-out 2: Fully recycled content is excluded. If a product is made entirely from recycled or waste material, it is out of scope. However, if it contains any non-recycled components, those parts remain in scope.
What remains in scope for packaging teams:
- Paper or board packaging sold as a standalone product (e.g., gift boxes, retail packaging sold separately, POS display units)
- Wooden transport packaging marketed as a product in its own right (e.g., pallets, wooden crates sold independently)
- Paper and board imported for use in packaging manufacturing within the EU - the importer is the operator
- Any packaging with mixed recycled/virgin fibre content where the virgin component traces to wood
One clarification from the Commission's April 2026 FAQ update (version 5): products made exclusively from bamboo do not fall within the EUDR's scope, since bamboo is not classified as "wood" under customs law. Printed products (HS 49 - catalogues, instructions for use) were removed from Annex I in the December 2025 amendments.
The Due Diligence Obligation: What It Actually Requires
Under Article 8 of Regulation (EU) 2023/1115, operators must operate a three-step due diligence system before placing any in-scope product on the EU market or exporting it.
Collect product descriptions, HS/CN codes, quantities, geolocation coordinates of the production plots (GPS polygon for plots ≥4 ha, or point coordinates for smaller plots), supplier details, country of origin, and evidence that the product is deforestation-free and legally produced. The cut-off date is December 31, 2020 — no deforestation on the plot after that date.
Assess the risk that the product is not deforestation-free or not legally produced. The EU's country risk classification (published May 2025) assigns countries to low, standard, or high-risk tiers, which determines the depth of due diligence required. Inspection rates are 1% (low risk), 3% (standard), or 9% (high risk) of consignments.
Where risk is not negligible, apply mitigation measures. Then submit a Due Diligence Statement (DDS) via the EU TRACES system before the product enters or leaves the EU market. The DDS generates a reference number that must accompany the shipment. Records must be retained for a minimum of five years.
The geolocation requirement is the hardest element operationally. For a paper manufacturer sourcing timber from thousands of private forest plots, this means collecting precise GPS coordinates for each plot - and the legal responsibility for accuracy rests with the operator, not the supplier.
Sustainability certifications (FSC, PEFC) are supportive evidence that can reduce audit burden, but they do not replace the DDS requirement. A certified supply chain still requires a DDS filed in TRACES with verified geolocation data.
Operator, Trader, Downstream Operator: Which Are You?
The December 2025 amendments (Regulation (EU) 2025/2650) restructured who must do what. This is where packaging teams need to be precise.
| Role | Definition | DDS obligation | Other obligations |
|---|---|---|---|
| **Operator** | First places a regulated product on the EU market, or exports it from the EU | Must submit full DDS via TRACES before placing/exporting | Full 3-step due diligence; 5-year record retention; register in TRACES |
| **Downstream Operator** | Places on the market a product already covered by an upstream DDS | No DDS submission required | Collect & retain DDS reference numbers from upstream; 5-year records; notify authorities of concerns |
| **Trader (non-SME)** | Makes regulated products available on the EU market after an operator has placed them | No DDS submission required | Register in TRACES; collect and pass DDS reference numbers; maintain traceability records |
| **SME Trader** | Same as trader but qualifies as small or micro enterprise | Reduced obligations; application date 30 June 2027 | Collect DDS reference numbers from suppliers; lighter documentation requirements |
For most packaging procurement teams at FMCG or manufacturing companies, the practical question is: who first placed the paper or board on the EU market? If you import paper or board directly from a non-EU supplier, you are the operator. If you buy from a European paper merchant who already imported it, you are likely a downstream operator - and your primary obligation is to collect the DDS reference number from that merchant.
The critical point: even as a downstream operator, you cannot simply assume your supplier has filed a DDS. You must actively collect and retain those reference numbers, and you must have a system to do so at scale across your packaging portfolio.
The EUDR-PPWR Intersection: One Data Problem, Two Regulations
Packaging teams already managing PPWR compliance will recognize the data challenge immediately. PPWR requires structured, auditable data on material composition, recyclability, recycled content, and supplier declarations. EUDR requires structured, auditable data on material origin, geolocation, and deforestation-free status.
These are not the same data sets - but they live in the same place: your packaging specifications and your supplier records.
Companies relying on scattered PDFs, Excel files, and email threads to manage packaging data will face this problem twice over. A single, structured packaging data foundation - where material composition, supplier details, and compliance documentation are centrally managed - is the only scalable answer to both regulations simultaneously.
PPWR + EUDR data synergy: Your PPWR Declaration of Conformity already requires you to document material composition and supplier information per packaging type. Use that same supplier record as the starting point for EUDR data collection — add geolocation fields and DDS reference number tracking to the same structured record rather than building a parallel process.
Penalties: What Non-Compliance Costs
The EUDR is not a reporting exercise with soft consequences. Article 25 of Regulation (EU) 2023/1115 requires Member States to set maximum fines of at least 4% of an operator's or trader's total annual Union-wide turnover for breaches of the EUDR. Member States may set higher national ceilings but cannot go below that floor.
Additional enforcement measures include confiscation of non-compliant products and the revenues derived from them, temporary exclusion from public procurement, and - for serious or repeated infringements - temporary prohibition from placing products on the EU market. Directive (EU) 2024/1203 adds criminal liability, with imprisonment up to 10 years for natural persons and fines up to 5% of worldwide turnover or €40 million for legal persons.
A missing DDS reference number is not a paperwork gap. It is a shipment block at EU customs.
Prepare-Now Checklist for Packaging Teams
The window between now and December 30, 2026 is your preparation runway. Here is what to do in sequence:
1. Map your packaging portfolio against Annex I For every packaging type in your portfolio, check the CN/HS code against Annex I. Apply the three carve-outs: not in Annex I -> out; 100% recycled/waste -> out; purely protective/carrier packaging -> out. Document every decision.
2. Determine your supply chain role per packaging type For each in-scope packaging type, establish whether you are an operator (first placing on EU market), downstream operator, or trader. This determines your DDS obligation.
3. Identify your Tier-1 suppliers for in-scope materials For paper, board, and wood packaging, identify which suppliers are your first point of contact for in-scope materials. Initiate conversations now - geolocation data collection from forest plot owners takes time.
4. Request DDS reference numbers or geolocation data
- If you are an operator: request GPS coordinates (polygon or point) for each production plot, plus legal land use documentation and deforestation-free evidence as of December 31, 2020.
- If you are a downstream operator: request the DDS reference number from the upstream operator who first placed the material on the EU market.
5. Register in TRACES Non-SME operators and traders must register in the EU TRACES information system. The system was updated in early 2026 to align with Regulation (EU) 2025/2650.
6. Build a structured, auditable data system Spreadsheets and email threads cannot manage this at scale. You need a system that links packaging specifications to supplier records, tracks DDS reference numbers, and maintains a five-year audit trail - ideally the same system you are using for PPWR compliance.
7. Align with your PPWR data collection Use your existing PPWR supplier outreach as a vehicle to simultaneously collect EUDR-relevant data. Both regulations require structured supplier data - build one process, not two.
What Packa Does Here
Packa's platform is built around a single principle: packaging compliance requires a structured, auditable data foundation - not a collection of disconnected tools. The same AI-powered specification management that digitizes your PPWR data also structures your supplier records in a way that supports EUDR data collection.
One platform covers PPWR, EUDR, and CSRD readiness - because the underlying data problem is the same: scattered packaging information that needs to become an audit-proof source of truth.
Not sure whether your paper or board packaging falls under EUDR — or how to connect your PPWR and EUDR data collection? Our packaging experts map your portfolio and show you exactly where you stand.
Talk to a Packaging ExpertFrequently Asked Questions
Does EUDR apply to corrugated cardboard packaging?
It depends on how the packaging is used. Corrugated board used purely to protect or carry another product placed on the market is generally exempt. However, if you import corrugated board from outside the EU for use in manufacturing, you are likely an operator for that material. If you sell corrugated packaging as a standalone product, it falls within scope. Always check the CN code against Annex I and document your scoping decision.
Does FSC or PEFC certification replace the EUDR due diligence statement?
No. Sustainability certifications are supportive evidence that can reduce audit burden, but they do not replace the requirement to submit a Due Diligence Statement via EU TRACES with verified geolocation data. You must still file a DDS per consignment.
We buy paper packaging from a European supplier — are we in scope?
If your European supplier imported the paper or board from outside the EU, they are the operator and must have filed a DDS. Your obligation as a downstream operator is to collect and retain their DDS reference number. You do not submit your own DDS, but you must have a system to request and store those reference numbers.
What is the EUDR application date after the 2025 delay?
Under Regulation (EU) 2025/2650, published on 23 December 2025, the application date is 30 December 2026 for large and medium operators and traders, and 30 June 2027 for micro and small enterprises. The core due diligence obligations have not changed.
How does EUDR interact with PPWR compliance?
Both regulations require structured, auditable packaging data — material composition, supplier details, and compliance documentation. While the specific data fields differ (PPWR focuses on recyclability and recycled content; EUDR focuses on origin and deforestation-free status), both can be managed from the same structured packaging data foundation. Building one integrated data process is more efficient than running two parallel compliance workflows.
Are bamboo packaging materials covered by EUDR?
No. The European Commission clarified in FAQ version 5 (April 2026, point 2.12) that products made exclusively from bamboo do not fall within the scope of the EUDR. Bamboo is not classified as 'wood' under customs law.
