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Quick summary: Discover how EUDR Regulations for Packaging impact box and pallet makers with practical examples, clear compliance rules, and tips to turn regulatory obligations into a market advantage.
EUDR Regulations for Packaging require compliance only when packaging materials, such as paper cartons, printed sleeves, or wooden pallets—are placed on the EU market as standalone products. In these cases, companies must submit a Due Diligence Statement (DDS), provide geolocation data for raw materials, and maintain five-year audit records. However, packaging used solely to support, protect, or carry another product (for example, a paper box carrying food) is exempt under Rule 5(b) of the Combined Nomenclature. Box and pallet makers must assess whether their products are sold independently or as packaging to determine EUDR obligations and avoid penalties.
For packaging manufacturers and exporters, the EU’s deforestation free requirements are no longer just for timber or soy. Under the EUDR Regulations for Packaging, even your cartons, sleeves, and pallets can trigger due diligence obligations if they are sold as standalone products. Many companies assume packaging is always exempt—only to face costly delays, rejected shipments, or fines when the rules apply. Knowing exactly when packaging is covered and when it isn’t is critical to protect market access and build trust with EU buyers. Let’s break it down with practical examples.
Key Takeaways
The EU Deforestation Regulation (EUDR) was designed to stop products linked to deforestation from entering EU markets. While most people immediately think of timber, soy, or palm oil, packaging materials, paperboard cartons, printed sleeves, wooden pallets, have emerged as a grey area that sparks a lot of confusion for exporters and manufacturers.
Because packaging often travels with another product, and companies naturally assume, “It’s just packaging, surely it doesn’t fall under EUDR.” But here’s the nuance:
Packaging is covered only if it’s placed on the EU market as a product in its own right.
For example, selling empty cartons or new pallets directly to a buyer in Europe triggers full EUDR obligations: you must prove the material’s legal origin, collect geolocation data for raw materials, submit a Due Diligence Statement (DDS), and maintain records.
Packaging used solely to support, protect, or carry another product is not covered.
For example, if you export chocolate in a paper box, the box is classified along with the chocolate under customs rules and doesn’t need its own EUDR compliance.
Think of it this way—packaging becomes a “relevant product” only when it stands alone in the market. It’s not about what it’s made of; it’s about how it’s sold and represented. This distinction is what many in the industry overlook, leading to unnecessary compliance work or, worse, missed obligations.
Don’t guess—map your packaging portfolio. Distinguish between products sold independently and those used purely as packaging. This clarity not only prevents penalties but also positions you as a trusted, compliant partner in EU supply chains.
Want to dive deeper into staying compliant?
Read our blog on EUDR Packaging Requirements to understand exactly when boxes, pallets, and sleeves fall under the regulation.
Explore our guide on What a DDS Is to master the essentials of Due Diligence Statements and how to file them with confidence.
Start here to get clarity and stay ahead of compliance risks!
When Packaging Is Not a Relevant Product -Rule 5(b) Explained
One of the most misunderstood parts of EUDR is how customs classification interacts with due diligence. Combined Nomenclature Rule 5(b) is your compass here, it states:
Packing materials and containers presented with the goods they contain are to be classified with those goods if they are of a kind normally used for packing such goods.
If you are exporting a product inside standard packaging, think cartons, sleeves, sacks, or pallets used only to protect or carry the goods—that packaging is not treated as a product in its own right.
Practical example
Many exporters and manufacturers overcompensate, trying to collect geolocation data for every pallet, sleeve, or box. This adds cost and complexity without benefit. Understanding Rule 5(b) allows you to focus your compliance efforts where they matter most, on the actual commodities, not their transport materials.
No. What matters is classification, not how it appears on your invoice. If the box is purely packaging, it follows Rule 5(b) and is exempt.
No, unless you are selling those pallets as a product in their own right.
If those cartons are sold separately as a standalone product, they’re covered by EUDR. But if they only accompany your product, you’re exempt.
Focus your due diligence resources where they drive real compliance, and don’t waste time chasing data for packaging that customs already considers part of your goods.
Under the EUDR (EU Deforestation Regulation), packaging is not always exempt.
It becomes a relevant product—and therefore subject to due diligence, when it is sold or exported as a standalone item rather than used solely to support, protect, or carry another product.
If you’re a packaging manufacturer shipping empty corrugated boxes or specialty cartons to a distributor in Europe, those boxes are the main product.
EUDR applies: You must geolocate the source of the paper or board, verify legal harvesting, and submit a Due Diligence Statement (DDS).
Many box makers think, “We only make packaging, not agricultural products.” But under EUDR, your cartons are treated exactly like other forest-based products when sold on their own.
Selling pallets as standalone goods—whether to logistics providers or manufacturers—places them squarely under EUDR.
EUDR applies: Every timber component must have documented origin and legality.
A single pallet may contain wood from multiple sources; without traceability, you risk penalties or blocked shipments. Some exporters are already using digital tools to attach geotagged data to each pallet batch.
Custom-printed paper sleeves or inserts, when shipped independently to EU buyers for future use, count as a product in their own right.
EUDR applies: Even though they’re “just packaging materials,” the EU classifies them as forest-risk commodities when sold separately.
Many print converters are onboarding traceability platforms not only for compliance but also to prove sustainability credentials, which opens up premium markets.
Our sleeves are 70% recycled content—are we exempt?
Only the recycled portion is exempt. Any virgin fiber must be traceable with a DDS.
Stand out from competitors by demonstrating full traceability—buyers and regulators are looking for suppliers who can prove it.
Navigating EUDR compliance isn’t always black and white—especially for packaging companies. Beyond the usual cartons and pallets, these special scenarios often cause confusion. Here’s how to handle them, with insights and angles that matter for your operations and customers.
Pallets that have already been used once to carry goods, and are now circulating within a closedloop rental or reuse system, do not trigger EUDR obligations.
Instead of treating every pallet as a fresh product, the regulation sees these as part of logistics operations, not as new forest risk commodities.
A pallet rental pool moving goods between warehouses in Germany and France is exempt.
If a pallet is repaired using new wood components, only those components fall under EUDR requirements.
Instead of treating the whole pallet as a new product, focus your due diligence on just the new material you’ve added.
Replacing a broken slat with a new plank? That plank’s source must be geolocated and documented.
Recycled material has special treatment. If your paperboard or cartons are made entirely from material that has completed its lifecycle and would otherwise be discarded, no DDS is required.
Many packaging firms market recycled content as a sustainability win, but forget that even a small fraction of virgin pulp brings them back into EUDR scope.
100% postconsumer recycled boxes? Exempt. Boxes with 80% recycled and 20% virgin pulp? That 20% must be traced.
Meeting EUDR compliance can feel overwhelming for packaging manufacturers, especially when juggling complex supplier networks, documentation, and regulatory updates. EUDR Compliance Platform powered with AI turn this challenge into a streamlined, automated process that reduces manual effort and risk.
Instead of compiling hundreds of documents manually, TraceX collects supplier data (including HS codes, quantities, and legality proofs) and autogenerates Due Diligence Statements (DDS) in EUTRACES–ready formats.
Benefit: Save weeks of reporting time and minimize errors.
TraceX links each paper or wood input to its source plot with AI-assisted geotagging and validation, ensuring you meet EUDR’s plot-level requirements.
Benefit: Eliminate the risk of shipments being rejected for missing or incorrect coordinates.
TraceX connects seamlessly with systems like SAP, Oracle, or Microsoft Dynamics, pulling and syncing data without overhauling your workflows.
Benefit: Avoid duplicate data entry and maintain a single source of truth across your supply chain.
With regulatory landscapes evolving, TraceX continuously pushes live updates and alerts to your dashboard, ensuring your compliance framework always matches the latest EU expectations.
Benefit: Stay proactive instead of scrambling to react to new rules.
Understanding EUDR packaging rules isn’t just about staying compliant—it’s about avoiding costly missteps and building trust with buyers and auditors. Here’s what every stakeholder should know, with some fresh angles and answers to common questions:
If you’re shipping food, beverages, or goods inside typical boxes, sleeves, or pallets, you do not need to file a DDS for the packaging itself, as long as that packaging is only supporting or protecting the product.
Focus your compliance efforts on the contents (e.g., cocoa, palm oil) rather than spending time and money chasing data for standard packaging materials.
Customer Question:
“Do I need geolocation data for every paper box?”
Answer: No. If the packaging is part of your product shipment, EUDR doesn’t consider it a separate relevant product.
If your core business is selling empty cartons, sleeves, or pallets as standalone products, you must treat them as relevant commodities under EUDR. That means gathering plot-level data for the wood or paper pulp and submitting a DDS before export or EU placement.
This is an opportunity, demonstrating traceable, deforestation-free packaging can become a powerful selling point to sustainability-focused buyers.
Customer Question:
“We supply empty boxes to a UK distributor—do we need compliance?”
Answer: Yes. Because the packaging itself is the product, it falls under EUDR obligations.
Supply chain and compliance teams should proactively document whether packaging is used as a container for other goods or sold separately. Clear classification reduces audit friction and shows buyers and regulators you know exactly where your risk lies.
In many companies, packaging is an overlooked compliance gap. Mapping how packaging is procured and sold builds resilience and confidence with EU partners.
Customer Question:
“How do we prove packaging isn’t a relevant product?”
Answer: Maintain clear records—purchase orders, invoices, and product specs—that show the packaging is classified jointly with the goods under customs Rule 5(b).
By knowing when packaging is exempt and when it isn’t, you can save time, focus on real risks, and even turn compliance into a competitive edge.
For box and pallet makers, the EUDR Regulations for Packaging are not just a legal hurdle—they’re an opportunity. When your cartons, sleeves, or pallets are sold as standalone products, proving deforestation-free sourcing and submitting a proper DDS isn’t optional; it’s your ticket to trusted partnerships with EU buyers. By investing in traceability and digital compliance tools now, you can stay ahead of regulatory changes, build credibility with global retailers, and position your business as a preferred, future-ready supplier.
Want to dive deeper into staying EUDRready?
Explore our expert blogs on
Why digitizing the paper supply chain drives compliance and efficiency
How to navigate EUDR HSN codes with confidence.
Packaging material used exclusively as packaging material to support, protect or carry another product placed on the market is not a relevant product within the meaning of Annex I of the Regulation, regardless of the HS code under which they fall.
While recycled paper and board products often contain a small amount of virgin pulp or pre-consumer recycled material for strength, the EUDR does not apply to goods made entirely from recycled materials that would otherwise be discarded as waste.
Forest degradation under the Regulation means the conversion of certain types of forests into other kinds of forests or other wooded land. Sustainable forest management systems can be employed and encouraged, provided they do not lead to a conversion that meets the degradation definition.
