EUDR for hamper and subscription box companies

A hamper or subscription box that bundles chocolate, coffee and a wooden spoon does not get one single EUDR answer. Regulation (EU) 2023/1115, as amended by Regulation (EU) 2025/2650, applies by Combined Nomenclature (CN) code, and it applies to each regulated commodity inside the bundle separately. The chocolate, the coffee and the wooden item each carry their own due diligence obligation; the box that holds them together usually does not.

Why bundling the products doesn't bundle the compliance

Annex I of the regulation lists products by CN code, not by retail concept. "Hamper", "subscription box" and "gift set" are marketing categories, not customs or regulatory ones, so there is no single Annex I entry for them and no single due diligence file that covers the whole box. The question the EUDR actually asks — repeatedly, once for each item — is whether the specific product falls under one of the seven covered commodities: cattle, cocoa, coffee, oil palm, rubber, soya or wood.

This is the same logic the regulation already applies to any composite product, such as furniture with a leather seat pad or a toy with a rubber grip: due diligence follows the regulated material inside the product that is actually being placed on the market, not every item that happens to travel in the same shipment or sit in the same box. A hamper is simply a more visible version of that same pattern, because it is deliberately built from several commodities at once.

Which items in a typical hamper are actually in scope

Most hampers and subscription boxes mix covered and uncovered items without anyone intending to. The pattern below covers what shows up most often.

Typical hamper item	Commodity	In scope?
Chocolate bars, cocoa powder, drinking chocolate	Cocoa	Yes — Annex I cocoa entry (CN Chapter 18)
Roasted or ground coffee	Coffee	Yes — CN heading 0901
Instant or soluble coffee sachets	Coffee	Yes, but from 30 December 2027, not the main date — see below
Wooden spoon, board, coaster or trinket box	Wood	Yes — Annex I wood entry
Leaf or bagged tea	—	No — tea is not an Annex I commodity at all
Greeting card, recipe booklet, printed insert	—	No — printed matter (CN Chapter 49) was removed from scope by Regulation (EU) 2025/2650
Soy wax candle	—	No, unless the wax is palm-derived, in which case it falls under the oil palm entry
The cardboard box, tissue paper, ribbon	—	No, where it only carries the product — see next section
A decorative wooden crate marketed and sold as part of the product	Wood	Possibly — see next section

Tea sits outside Annex I entirely, unlike coffee, for reasons that trip up a lot of buyers who assume the two are treated alike — it is worth checking against that logic before assuming any hot-drink item in a hamper is covered.

Is the box itself a wood product, or just packaging?

Packaging is exempt from the EUDR when it does nothing but support, protect or carry another product to market — a cardboard hamper box, tissue paper, a ribbon. It stops being exempt the moment it is itself the product being placed on the market, which is the same test a pallet manufacturer or a cosmetics bottler already has to apply to their own packaging.

For most hamper and subscription box businesses the outer box is plainly packaging and carries no obligation of its own. The genuine edge case is a decorative wooden crate, drawer or box sold as part of the product's appeal — something a customer might reasonably keep and reuse, rather than discard. The closer that container is to being a wood product in its own right, rather than disposable packaging, the more it looks like a line that needs its own Annex I check. There is no fixed threshold in the regulation for exactly where that line falls; treat a reusable wooden container as a wood product unless you are confident it is functioning purely as packaging.

Who is the operator: you, or whoever supplied the finished goods

Most hamper and subscription box companies buy finished, retail-ready goods — chocolate bars, bagged coffee, wooden utensils — from EU-based wholesalers or distributors, then assemble and sell them as a bundle under their own brand. Assembling an existing EU-placed product into a new bundle is not the same act as placing it on the EU market for the first time. If your coffee, chocolate and wooden items were already imported and placed on the EU market by someone earlier in the chain, you are a trader for those lines, and the same ownership-and-placing test that decides operator status for private label goods decides it here — you need the due diligence statement reference number for each line, not your own filing.

That changes the moment you import any component yourself. A hamper business that sources wooden bowls directly from a supplier outside the EU, or buys green coffee and has it roasted to its own specification before importing it, is the operator for that specific line — regardless of how the finished bundle is marketed — because it is the party placing that product on the EU market for the first time. Mixed sourcing is common and means mixed status: operator for the lines you import yourself, trader for the lines you buy already placed. Downstream traders generally no longer file their own due diligence statement for the lines where that applies, but still need to be able to produce the reference number on request.

Soluble coffee and the later 2027 date

Subscription boxes and hampers lean heavily on instant and soluble coffee sachets because they travel and store well. That specific product — soluble coffee, and coffee extracts, essences and concentrates under CN heading 2101 11 — was only brought into Annex I by Commission Delegated Regulation (EU) 2026/2102, alongside frozen cattle tongues and a wider set of palm oil derivatives. Those three additions run on their own later date, 30 December 2027, rather than the dates that already applied to coffee, cattle and palm oil generally. If your box includes soluble coffee, check which date actually governs that line — it is a full year later than roasted or ground coffee in the same box, even though both are nominally "coffee".

Size and timing: which date applies to a hamper business

The two main application dates turn on the size of your business, tested under Directive 2013/34/EU as amended by Delegated Directive (EU) 2023/2775 — the same thresholds used across the EU for company size, not a figure specific to the EUDR.

Band	Staff	Turnover	Balance sheet	Application date
Micro	≤ 10	≤ €900,000	≤ €450,000	30 June 2027 (non-timber items)
Small	≤ 50	≤ €10m	≤ €5m	30 June 2027 (non-timber items)
Medium	≤ 250	≤ €50m	≤ €25m	30 December 2026
Large	exceeds two of the medium thresholds			30 December 2026

A micro or small hamper business gets the later date of 30 June 2027 only for non-timber lines. Its wooden items — if they, or any earlier version of them, were already covered by the EU Timber Regulation — are caught by the earlier 30 December 2026 date regardless of the business's size. That split between dates is the single most misread part of the amended regulation, and a hamper business with both cocoa or coffee and wooden items is exactly the kind of business that ends up running two dates on the same product range.

Building a compliance file for a multi-commodity bundle

The practical task is the same whatever the retail packaging looks like:

• List every SKU component separately by CN code, not by what it is called on the hamper's contents list. Chocolate, coffee and wood each go on their own line.
• For each line, establish whether you are the operator (you imported it or had it produced to your specification) or a trader (you bought it already placed on the EU market).
• Where you are the operator, you need geolocation of the plot or area of production, evidence the commodity is deforestation-free since 31 December 2020, and a due diligence statement filed before the product is placed on the market.
• Where you are a trader, keep the due diligence statement reference number from your supplier for each line, and be able to produce it on request.
• Flag any line, such as soluble coffee, that runs on the later 2027 date so it is not filed — or missed — against the wrong deadline.
• Treat any reusable or decorative outer packaging as a separate line to check, rather than assuming it is covered by the same answer as what is inside it.

Micro and small operators get three specific simplifications on top of this, but none of them removes the need to work through the bundle component by component first.

What happens if you get this wrong

A missing or inaccurate due diligence statement is not a labelling problem. Penalties under the regulation include fines of up to at least 4% of the operator's total annual EU-wide turnover, confiscation of the products and any revenue from them, and temporary exclusion from public procurement. None of that is scaled down because the product in question was one item inside a gift box rather than a standalone shipment.

Run the free checker against each commodity in your range to see which lines are in scope, which operator or trader category applies, and which date is actually yours.

One point genuinely has no settled answer yet: where a hamper is sold and classified for customs purposes as a single retail set under one combined tariff code, rather than as separate lines, how that interacts with Annex I's own CN-code basis is a customs classification question the Commission has not addressed specifically for composite retail sets. Treat each regulated component as its own line for EUDR purposes regardless of how the set is classified for duty, and take customs advice on the classification question separately if it affects what you declare at import.