EUDR: what the EU deforestation rules mean for your packaging

EUDR, the EU Deforestation Regulation, is the rule that says commodities linked to deforestation can no longer be placed on the EU market. Most of the coverage has focused on cocoa, coffee, soy, palm oil and cattle, but wood is on the list too, and that pulls in paper, cardboard and corrugated packaging. If you export goods to the EU, the box around your product is in scope, not just the product inside it.

What the regulation actually requires

Anyone placing relevant goods on the EU market must show three things at once:

• Deforestation-free: the fibre must come from land that was not deforested after 31 December 2020.
• Legally produced: harvesting must comply with the laws of the country of production, covering land use, labour and trade rules.
• Traceable to the plot: you need geolocation data for the land the wood was harvested from, not just a country name.

Those three elements are wrapped up in a due diligence statement, which is submitted before the goods enter or leave the EU. Operators keep the underlying records for five years, and enforcement authorities can ask to see them.

How this differs from FSC

This is the question we get asked most. FSC® certification is a voluntary scheme, and it is genuinely useful evidence: it demonstrates responsible forest management and gives you an audited chain of custody back through the supply chain. But FSC on its own is not automatic EUDR compliance. EUDR asks for specific geolocation data and a legal declaration, so certification supports your due diligence rather than replacing it.

Businesses buying certified board are starting from a much better place. The records already exist, the mills are used to being audited, and the information you need is usually one request away.

Who actually carries the obligation

The duty sits with the operator placing the goods on the EU market. For a UK business shipping into the EU, that is often your importer or EU-based customer, which is exactly why they are increasingly asking you for supply chain evidence. Larger buyers are pushing requests down the chain to their packaging suppliers, and the ones who cannot answer are being replaced. Even where you have no direct legal obligation, being able to answer quickly is now a commercial advantage.

Practical steps to take now

• Map your fibre-based packaging. List every corrugated box, mailer, paper tape, label backing and pallet you use, and note which of them travel into the EU.
• Ask your suppliers for chain-of-custody certificate numbers, mill details and confirmation of EUDR readiness, in writing.
• Keep the records with the SKU. Filing evidence by product rather than by invoice makes customer questionnaires far quicker to answer.
• Watch your non-obvious wood items. Wooden pallets, crates and dunnage are in scope as well as the box.
• Consolidate suppliers. Fewer sources of board means fewer chains of custody to evidence.

Where we fit in

We supply FSC® certified corrugated board under licence code C214479, manufacture to size in Unit 3 on our Letchworth site, and operate a BRCGS Storage & Distribution certificated warehouse. That means we can give you certificate copies, material specifications and supplier documentation for the packaging you buy from us, the paperwork your EU customers are asking for.

If a customer has sent you a deforestation or supply chain questionnaire and you're not sure how to answer the packaging section, send it over and we'll help you fill in our part.