EUDR for packaging: when your box is in scope but your product is not

Packaging is out of scope of the EUDR when it is used solely to support, protect or carry another product to market — a pallet under your goods, a box around them. It comes into scope the moment it is itself the product being placed on the EU market, such as a pallet manufacturer selling empty pallets. Since September 2026 that exemption applies to packaging of any material, not only wood.

The rule the EUDR actually uses: is the packaging the product, or does it just carry one

The EUDR does not ask what your packaging is made of first. It asks what is being placed on the EU market. If a business imports coffee in jute sacks stacked on wooden pallets, the relevant product is the coffee — the sacks and pallets are simply how it travelled, and they carry no due diligence obligation of their own. If a different business imports the same pallets empty, to sell to a warehouse operator, the pallets are now the product being placed on the market, and Annex I's wood entry applies to them directly.

This is the same logic that already applies to composite products like furniture: due diligence follows the regulated commodity inside the product that is actually being sold, not every wood-based item that happens to be in the same shipment. The same principle carried through the amendments made by Regulation (EU) 2025/2650: what changed there was who files, not what counts as the product in the first place.

Where the exemption comes from, and what changed in 2026

Annex I's wood entry for packing cases, boxes, crates, drums, pallets, box pallets, load boards and pallet collars (CN 4415) has always carried a footnote excluding packing material used exclusively to support, protect or carry another product placed on the market. That footnote is why a business importing goods packed on wooden pallets was never expected to file a due diligence statement for the pallets themselves — only ever for the goods.

What changed is the reach of that principle. Commission Delegated Regulation (EU) 2026/2102, adopted on 13 July 2026 and in force from 18 September 2026, generalised the support-protect-carry exemption beyond CN 4415's own wording to packing material under other Annex I categories too. Reporting on the act describes it extending to single-use and reusable packaging of any material used solely for that purpose, and to related edge cases the original 2023 text had not addressed directly: pallets moving goods, trade samples, and accessory materials such as manuals and labels, none of which are treated as the relevant product themselves. The full set of Annex I changes made by this act covers the commodity-level additions and removals; this page stays with what it means for packaging specifically.

One exclusion is worth naming on its own because it surprises people: packaging made entirely from bamboo, rattan, reed, straw or similar plant material is reported to sit outside EUDR scope regardless of how it is used, because those materials are not wood as the regulation defines it and are not one of the seven regulated commodities. A cardboard-look bamboo tray is not a wood product under Annex I at all; a wooden crate is, subject to the exemption above.

Paper and cardboard packaging specifically

Wood is not the only Annex I commodity that shows up in packaging. Paper and paperboard, including much of what cardboard boxes and cartons are made from, sit under a wood-derived Annex I category because they are manufactured from pulp. The same support-protect-carry logic applies: a cardboard carton wrapped around goods you are placing on the market is packaging, not a product, and stays exempt. A business importing and reselling blank cardboard boxes or die-cut cartons as a product in their own right is placing that paper product on the market and needs to treat it accordingly.

The 2026 delegated act is also reported to have removed some purely informational paper items — marketing materials, catalogues and correspondence — from Annex I's paper entries altogether, on the basis that they are not really commercial products made from the regulated commodity in any meaningful sense. That is a narrower change than the packaging exemption: it removes certain paper items from scope entirely, rather than exempting them only while they are performing a packing function. If your business handles printed inserts, instruction leaflets or branded catalogues alongside a product, check the current Annex I wording for paper rather than assuming the packaging exemption is the only route out of scope — there may be two separate reasons the item does not need a statement.

What stays in scope

The exemption only removes packaging from scope while it is doing the job of packaging. These situations stay in:

• Packaging sold as a standalone product. A pallet manufacturer, box maker or drum producer selling empty units to another business is placing a relevant product on the market, not packing anything.
• Wood or paper packaging that is the commercial item itself, such as a wholesaler importing flat-packed cardboard boxes or wooden crates for resale to other businesses to fill.
• Packaging incorporated into a composite product you manufacture, where the packaging component is not incidental transport dressing but part of what you are selling — a branded wooden gift box sold with the product inside as a single retail item is more likely to be treated as part of that composite product than as exempt transport packaging, and the two are assessed differently.

Scenario	In scope?	Why
Wooden pallets under an import of furniture	No	Packaging supporting another product placed on the market
Cardboard boxes wrapped around a coffee shipment	No	Packaging protecting another product placed on the market
Empty wooden pallets imported for resale	Yes	The pallets are the product being placed on the market
Wooden crates manufactured and sold to other businesses to pack their own goods	Yes	The crates are the product, not transport dressing for something else
Bamboo trays and baskets, however used	No	Bamboo is not wood under Annex I and is not a regulated commodity

Who owes the due diligence statement when packaging is in scope

Regulation (EU) 2025/2650 concentrates the due diligence statement on whoever first places the product on the EU market. For a pallet or crate manufacturer outside the EU, that is the EU-based importer bringing the empty units in. For an EU pallet manufacturer selling to EU customers, it is the manufacturer itself as the primary operator. A business further down the chain that only buys already-compliant pallets to use as packaging for its own goods is not filing a second statement for the pallets — it is not placing them on the market as a product at all. How the statement obligation is split between operators and traders covers this in more detail for any relevant product, not only packaging.

When packaging is in scope, the same mechanics apply as to any other wood product: plot-level geolocation for production units above four hectares, evidence the wood was harvested after 31 December 2020 without deforestation, a documented risk assessment, and a statement filed in TRACES before the goods are placed on the market. Geolocation requirements cover the mechanics in full; nothing about them is different because the product happens to be a pallet rather than a plank.

Deadlines for a packaging business

Your business	Deadline if your packaging is in scope
Large or medium operator or trader	30 December 2026
Micro or small operator, product previously under the EU Timber Regulation	30 December 2026
Micro or small operator, otherwise	30 June 2027

Size is set by Directive 2013/34/EU thresholds: broadly, micro is up to 10 staff and €900,000 turnover, small up to 50 staff and €10 million turnover, medium up to 250 staff and €50 million turnover, and large above that. The full deadline breakdown covers how the two dates interact with role and product history.

Getting the classification wrong

Misreading which side of this line your packaging sits on carries the same consequences as any other EUDR scope error. If you assume packaging is exempt when you are in fact the business placing it on the market as a product, you have simply not filed a due diligence statement you owed — geolocation, deforestation-free evidence and the statement itself are all missing, and that is what a competent authority checks first, not your intentions. Conversely, filing a statement for genuinely exempt transport packaging wastes time and supplier data-gathering effort you do not need to spend. What non-compliance actually costs sets out the penalty regime in full; the point for packaging specifically is that the exemption is narrow and fact-specific, not a blanket carve-out for anything that looks like a box.

The safest way to get this right at scale is to classify by transaction, not by item type. The same wooden crate can be exempt packaging on one invoice and a relevant product on the next, depending on whether you are shipping goods in it or selling it empty. A classification exercise that asks "is this wood?" will miss that distinction; one that asks "what is this invoice actually for?" will not.

The practical test

Ask one question about each packaging line you handle: are you selling the packaging, or are you using it to get something else to market? If you are selling it, treat it as any other wood or paper product in Annex I — check the CN code, confirm origin, and plan for a due diligence statement on your applicable date. If you are only using it to ship, wrap or palletise a product you are selling, it needs no statement of its own, whatever it is made of.

Check what the EUDR requires of your specific products, including whether packaging you handle is itself in scope, rather than assuming the exemption applies because it usually does.