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The line that decides your position: product or wrapping?

Everything for a packaging maker turns on one question — is the box the thing you are selling, or is it holding the thing you are selling? Both HS headings sit in Annex I because they are wood-derived. [Reg. 2023/1115, Annex I] HS 4415 covers wooden cases, boxes, crates, drums, pallets, box pallets and pallet collars; HS 4819 covers cartons, boxes and cases of paper or paperboard. When you manufacture pallets or fold cartons and sell them to a logistics firm, a food producer or a retailer, that empty pallet or carton is the relevant product placed on the market — and the obligation is yours.

The other case is the Commission's own carve-out. Its guidance treats packing material presented with goods inside it, and used exclusively to support, protect or carry another product, as outside scope — because it is not being placed on the market as a product in its own right. [Reg. 2023/1115, Art. 2(18)] So the pallet under your own outbound shipment, and the corrugated box protecting a customer's order, are not the product — the goods inside are.

The draft May 2026 act would write the carve-out in — but it is not law yet

On 4 May 2026 the Commission published a draft delegated act amending Annex I. Among its proposed horizontal exemptions is one for single-use and reusable packing materials — the transport-and-protection packaging described above — regardless of what they are made of. [Commission EUDR implementation page] Read carefully: this proposal would codify the “wrapping is out of scope” position that the Commission already applies in guidance. It does not exempt packaging sold as a product.

And it is a draft. The consultation closed on 1 June 2026; as at 10 July 2026 the act is not adopted, not in the Official Journal and not in force, and the final text can still change. [Commission EUDR implementation page] So if you sell packaging, do not treat any part of your product line as exempt on the strength of a proposal — the exemption on the table is for packaging used as wrapping, not for packaging sold as goods, and it is not yet a rule.

Which role are you? (Usually the operator)

• You make packaging from wood or board you buy in, and sell it in the EU. If you are the first to place that finished pallet or carton on the EU market, you are the operator: you run due diligence on the timber content and file the Due Diligence Statement before it is placed or exported. [Reg. 2023/1115, Art. 4(2)]
• You import finished packaging into the EU to resell. The EU importer is the operator and files the DDS before customs clearance. A non-EU maker that sells to you is not the operator — you are, and you need its origin data. [Reg. 2023/1115, Art. 5 (as amended by Reg. 2025/2650)]
• You buy already-placed packaging within the EU and resell it. You are downstream: you collect and keep the DDS reference numbers, and if you are a non-SME you also register in the information system. [Reg. 2023/1115, Art. 5 (as amended by Reg. 2025/2650)]

Which deadline: mind the timber exception

Wooden packaging is timber, and that changes the clock. Medium and large operators apply from 30 December 2026. [Reg. 2023/1115, Art. 38 (as amended by Reg. 2025/2650)] The point for small makers: a micro or small operator that was already covered by the old EU Timber Regulation does not get the later 30 June 2027 date — the timber case pulls it back to 30 December 2026. [Reg. 2023/1115, Art. 38 (as amended by Reg. 2025/2650)] If your packaging is paper/board only and you were never a Timber Regulation operator, and you meet the SME size test (under 50 employees and ≤€10m turnover, SME status set by 31 December 2024), the 30 June 2027 date may be open to you. Check which applies before you plan.

What to ask your board and timber supplier for

For the packaging you place on the market, you need the origin data behind the wood fibre. For each supply, request: [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• Plot geolocation — coordinates, and polygons for plots over 4 hectares.
• Harvest/production dates for the timber or pulpwood.
• Country of production (which sets the risk tier).
• Legality evidence for the country of origin.
• The DDS reference number, where your supplier is the operator that filed it.

What this determines — and what it doesn't

Screening your packaging tells you which products are in scope, whether you are the operator, your deadline (watch the timber exception) and the documentary obligations you owe. It does not verify that the forest behind your board or your pallets is deforestation-free — that depends on the geolocation-plus-evidence your fibre suppliers provide and any satellite check. And it does not stand your product line down on the strength of a draft exemption that is not yet law.

General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free. Confirm your classification with counsel before relying on it for a market-access decision.

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