Regulations for Packaging as Per EUDR: Practical Instances for Box and Pallet Producers
In the ever-evolving landscape of international trade, understanding the EU Deforestation Regulation (EUDR) is crucial for businesses dealing with packaging materials. Here's a breakdown of the key points to help you navigate this complex regulatory environment.
Firstly, it's important to note that packaging materials sold as standalone products, such as cartons, pallets, or printed sleeves, are subject to EUDR. This means that companies must submit a Due Diligence Statement (DDS) and provide geolocation data for raw materials. However, packaging used solely to support, protect, or carry another product is exempt under Rule 5(b) of the Combined Nomenclature.
For instance, 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. Similarly, chocolate bars in paper sleeves are classified together with the chocolate and do not require a separate DDS.
On the other hand, empty corrugated boxes or specialty cartons shipped directly to EU customers must meet EUDR requirements. Reused or rented pallets are exempt from EUDR obligations.
Custom-printed paper sleeves or inserts, when shipped independently to EU buyers for future use, are considered forest-risk commodities under EUDR. Packaging manufacturers should focus their due diligence resources on the actual commodities, not their transport materials.
The EU Packaging and Packaging Waste Regulation (PPWR), effective from February 11, 2025, applies to companies offering packaging materials such as paper cartons, printed ribbons, or wooden pallets as standalone products on the EU market. These companies must comply with requirements for recyclability by 2030, reduced packaging waste, and mandates like a minimum 40% reuse quota for transport packaging from 2030.
Recycled paperboard or cartons made entirely from material that has completed its lifecycle and would otherwise be discarded are exempt from DDS. Recycled content in packaging materials is exempt from EUDR, but any virgin fiber must be traceable. Virgin fiber in packaging materials must be traceable with a DDS.
Our modern solutions can help simplify this process. Products like ours collect supplier data and autogenerate Due Diligence Statements (DDS) in EUTRACES-ready formats. They also continuously push live updates and alerts to your dashboard, ensuring your compliance framework always matches the latest EU expectations. Moreover, our product integrates seamlessly with ERP systems like SAP, Oracle, or Microsoft Dynamics.
For packaging manufacturers selling empty cartons, sleeves, or pallets as standalone products, proving traceable, deforestation-free packaging can become a powerful selling point to sustainability-focused buyers. When packaging is sold independently, it must meet full EUDR traceability and reporting requirements. New wooden pallets exported as a product must have documented origin and legality.
In conclusion, understanding the EU Deforestation Regulation (EUDR) and its implications for packaging is essential for businesses operating in the EU market. By staying informed and adhering to these regulations, companies can ensure their packaging practices are sustainable, traceable, and compliant with EU expectations.
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