The EU Deforestation Regulation, EUDR, requires operators placing certain commodities on the EU market to prove those goods are deforestation-free and legally produced, backed by geolocation data for the plot of land where the raw material was grown. Wood is one of the commodities in scope, and the compliance burden is real — which is why the question comes up in packaging conversations: does my pallet need a due diligence statement?
For most buyers, in most situations, the answer is no. The reasoning is worth understanding, because it saves a lot of unnecessary paperwork.
The packaging exclusion
Packaging used exclusively to support, protect or carry another product is outside the scope of EUDR from the moment it is used for that purpose. This covers both single-use and reusable packaging. In plain terms: a pallet carrying your goods is packaging, not a product being placed on the market, and the regulation treats it accordingly.
Three consequences follow that are worth knowing:
- Selling or renting used packaging material, such as second-hand pallets, does not trigger EUDR.
- Repairing a pallet triggers obligations only in respect of the new wood added, not the whole unit.
- Empty used packaging already used for that purpose and circulating in closed-loop systems sits outside the scope.
Where wooden packaging is placed on the market as a product in its own right — a manufacturer selling new pallets as goods — the position is different, and that obligation sits with the producer rather than with you as the user of the packaging.
Timing
The application date has moved more than once. As things stand, EUDR applies from 30 December 2026 for medium and large companies and for micro and small undertakings in the timber sector, with the remaining micro and small undertakings following on 30 June 2027. A simplification package published in 2026 adjusted several implementation details.
Given that history, treat any date you read — including the one in this paragraph — as needing a check against the current official position before you build a compliance plan around it.
What a responsible supplier should still be able to tell you
The scope exclusion is a legal position, not a licence to be vague about where timber comes from. Independently of EUDR, a packaging producer should be able to answer:
- Which countries and regions its timber is sourced from.
- Whether the supply is certified — FSC or PEFC chain of custody — and at what proportion.
- Whether the sawmills it buys from are subject to the EU Timber Regulation regime or its successor obligations.
Most of our timber comes from Lithuanian and regional Baltic forests, which are among the more tightly regulated and well-documented supply areas in Europe. If your own customers ask you sourcing questions — and in sectors like food, pharmaceuticals and automotive they increasingly do — that answer is often what they actually need, rather than an EUDR statement that the regulation does not require.
The practical advice
If someone in your supply chain is asking for an EUDR due diligence statement covering the pallets under your goods, it is worth checking whether the request is founded. Frequently it is a procurement template applied indiscriminately across every line item, and the answer is that packaging in use is excluded. Equally, if you are buying wooden packaging as goods for resale rather than to carry your own products, the analysis is different and you should take advice.
We are happy to document our timber sourcing for any customer that needs it. What we will not do is issue a statement implying a legal obligation applies where it does not — that helps nobody and muddies a compliance picture that is complicated enough already.
