Packaging, pallets and recycled timber under the EUDR: what is actually in scope

Arguments about pallets, cartons, reclaimed timber and paper inserts usually start from the wrong place. Under the EUDR, scope is driven by the Combined Nomenclature code in Annex I, plus what the material actually is and how it is used. Two carve-outs, the packaging exclusion and the recycled material exclusion, are real, but they are often stretched far beyond what the text allows.

Why the scope question keeps coming up

The EUDR applies from 30 December 2026 and there is no de minimis threshold. A container of low value pallets can sit just as firmly inside the regulation as a shipment of tropical sawn timber. Volume, value and frequency do not change the position.

That catches importers who are used to commercial distinctions instead of customs classification. People talk about "packaging", "samples" or "reclaimed wood" as though the product name decides the answer. It does not. Annex I lists relevant products by Combined Nomenclature code. If the code is listed, the product starts in scope unless a specific exclusion applies.

The practical effect is that two companies can import physically similar wood items and end up with different EUDR treatment because one item is being imported as packaging accompanying another product, while the other is being imported as a product in its own right. Customs classification and use matter more than the sales description.

Where the wood list actually stops

For wood, Annex I covers chapter 44 goods from 4401 to 4421. It also captures ex chapter 47 for wood pulp, ex chapter 48 for paper and paperboard products, selected wooden furniture codes under ex 9401 and 9403, and prefabricated wooden buildings under 9406 10.

The furniture entries are narrower than many operators assume. Only the listed wooden furniture codes and parts are included. The same applies to pulp and paper. The regulation does not pull in every paper article on the customs tariff, only the listed ex chapter 48 entries.

Printed matter under chapter 49 is no longer listed. Books, newspapers, brochures, catalogues, printed labels and similar printed matter are therefore outside the Annex I product list. That change removed a source of confusion for importers dealing with manuals and marketing inserts.

Bamboo-based goods are out of scope because bamboo is treated as a non-wood forest product. The exception is where the product still contains regulated wood material. A bamboo surface over an MDF or chipboard core still leaves the wood component inside scope.

The packaging carve-out and how far it reaches

Entry 4415 covers packing cases, crates, drums, pallets, pallet collars and similar wood packaging. It also carries an express exclusion for packing material used exclusively to support, protect or carry another product placed on the market. The Commission FAQ goes further and states that packaging used exclusively for that purpose is not a relevant product regardless of its HS code.

That means a pallet delivering ceramic tiles, machinery or food products is generally outside scope while it is acting purely as transport packaging. The same logic applies to secondary and tertiary packaging around a delivered pallet load. The exemption follows the packaging function, not just the pallet code.

The December 2025 amendment widened the carve-out again. Single use packing presented with another product is excluded. Reusable packing becomes excluded from the moment it is actually used for that purpose. Used packaging and second-hand wood products are also excluded from the wood entries. The Commission specifically confirmed that pallets circulating in a closed-loop exchange system between companies fall outside scope once they have entered that reuse cycle.

For paper and pulp products, the same amendment excluded correspondence, marketing material and information materials accompanying another product or supplied free of charge. A manual inside a machine crate is out. Point-of-sale leaflets delivered with goods are out. The treatment depends on the item accompanying another product rather than entering the market independently.

Where the packaging argument breaks

The carve-out stops working when the packaging itself becomes the product being placed on the market. Empty pallets imported for resale, hired pallet fleets entering the EU market, or standalone wooden boxes sold as products in their own right remain in scope. Due diligence still applies in those cases.

A wooden presentation box can also pull the item back into scope where the packaging gives the combined product its essential character. Importers often try to treat these items as ordinary transport packaging when they are actually part of the commercial product.

The same distinction matters for printed material. A leaflet supplied free of charge alongside another product is excluded. The identical leaflet imported and sold as a commercial paper product in its own right remains within the paper entries of Annex I if the CN code is listed.

• Empty pallets or crates imported for resale as goods.
• Gift boxes treated as part of the retail product.
• Pallets bought in and later sold onward separately.
• Standalone paper inserts or catalogues imported as products.

One other point gets missed regularly. The packaging exemption covers the pallet or carton itself. It does not exempt the timber standing on it. If the imported goods are relevant products, the DDS obligation still applies to those goods even where the transport packaging falls outside scope.

Recycled and recovered material, precisely

The EUDR excludes goods produced entirely from material that has completed its lifecycle and would otherwise have been discarded as waste. Fully recycled fibre products and genuinely recovered timber can therefore sit outside scope if the material meets that test.

The exclusion does not extend to manufacturing by-products where the original process never involved waste material. Sawmill chips, sawdust, shavings, offcuts and pellets made from them remain in scope because they come from processing virgin wood rather than recovered waste streams. This catches operators who assume every residue product qualifies as recycled.

Mixed products are another common problem. If a paper or panel product contains both recovered fibre and virgin fibre, the whole product remains in scope. Due diligence then follows the virgin fibre component and its source plots. The recycled percentage does not create a partial exemption.

Importers should ask suppliers for written evidence showing recycled content status and how the material stream qualifies. Keep the same level of documentary support you would keep for a DDS. If a supplier cannot clearly explain whether the input material was waste or simply a production residue, treat the product carefully before relying on an exemption.

What to do with this before 30 December 2026

Start with the product master. Match each item against its Combined Nomenclature code and the Annex I entries. Then record the scope decision and the reason for it. If the product is treated as exempt packaging or fully recycled material, note the factual basis and retain supplier evidence.

Hold exemption records the same way you would hold due diligence records. Authorities will still expect operators to justify why a product was excluded. Records and evidence must be retained for five years. Penalties under the regulation can reach at least 4% of EU turnover, alongside confiscation of goods and exclusion from public procurement.

For products that remain in scope, the DDS must be filed in TRACES before the goods are placed on the market or exported. Geolocation requirements still apply to the virgin source plots. A polygon is required for plots above 4 hectares, while a single point is allowed at 4 hectares or below. The JRC Global Forest Cover map is often used as an initial screening reference.

Small and micro operators get a delayed application date of 30 June 2027, but that delay does not reach products already covered by the old EU Timber Regulation annex. Timber, pulp and paper were already there, so most wood packaging, pulp and paper supply chains do not benefit from the later start date.

goEUDR prepares supplier data and files DDS submissions in TRACES for timber importers. Every filing is reviewed and signed off by a human before submission.

This article is general information only and does not constitute legal advice.