EUDR and packaging: When are packaging, displays and instructions covered by the regulation?

Executive Summary

The EUDR will apply to large and medium-sized companies from December 30, 2026 and places special requirements on wood and paper-based products such as packaging and POS displays. Whether such materials are affected depends on whether they are placed on the market as stand-alone products and fall under Annex I. Pure protective or carrier packaging, on the other hand, is generally exempt, regardless of the customs tariff number.

Traditional printed products such as catalogs or instructions for use are no longer within the scope of application, as printed products (HS 49) have been removed from the Annex. Anyone importing or providing relevant products as independent goods must provide evidence of legality and freedom from deforestation and submit a due diligence declaration in the EU information system.

To which products does the EUDR apply?

The EUDR is intended to ensure that certain raw materials and products made from them do not contribute to deforestation or forest degradation when placed on the market within the EU. The obligations will apply to large and medium-sized companies from December 30, 2026. For micro and small enterprises, generally from June 30, 2027 (with exceptions, for example for certain actors already covered by the EUTR). Only the raw materials defined in the regulation and the relevant products made from them in accordance with Annex I (CN/tariff codes) are affected. Companies must fulfill due diligence obligations, assess risks and prove that the products concerned are legal and deforestation-free.

What the EUDR regulates and what it does not

The EU Deforestation Regulation applies to a clearly defined list of raw materials and products(Annex I), which is based on EU customs tariff numbers (CN/HS). In particular, it covers products made from cattle, wood, cocoa, coffee, soy, oil palm and rubber, as well as certain products made from these, which are listed in Annex I.

At the same time, the scope of application has recently changed noticeably: Certain printed products ("ex 49") have been removed from Annex I. This means that classic printed products (e.g. many brochures or printed products as such) are no longer the typical "scope trigger" under the EUDR.

→ As a guide, the safest way to classify them is therefore via Annex I + CN Code, supplemented by the FAQ clarifications of the European Commission, which are updated regularly.

Packaging as a special case

Packaging is a special case within the framework of the EUDR and is often difficult to classify in practice. Whether they actually fall under the regulation depends not only on whether they are traded as independent products, but above all on their function in the specific flow of goods: Is the packaging placed on the market as a product "in its own right" (standalone/empty) or is it used exclusively to support, protect or carry another product?

According to the current FAQ/Guidance line:

• Packaging material that is used exclusively as packaging for another product is not covered by the EUDR, regardless of the CN/HS code under which it is classified (including paper/cardboard packaging).
• However, packaging is relevant to EUDR if it is imported, provided or exported as a separate good (e.g. empty folding cartons/carrier bags, label rolls or other packaging components that are procured separately and traded as articles).

It remains particularly tricky with service packaging and POS displays. If these are produced and procured separately and placed on the market as independent goods, they may be subject to EUDR, depending on the material and classification in Annex I.

A key point in the assessment is therefore the combination of customs tariff number (CN/TARIC), function assignment and the question of whether the packaging material is provided standalone or exclusively as packaging for another product. In addition, it is worth taking a look at the current FAQs of the European Commission, which are updated regularly.

Are instructions and user manuals subject to EUDR?

Paper-based product and user instructions accompany almost every technical or electrical device. Many companies are therefore wondering whether these accompanying materials, often regarded as an inconspicuous part of the final packaging, can be covered separately by the EUDR. Correct classification is crucial in order to avoid legal risks due to incorrect classification.

Paper-based instructions - what currently applies?

Many instructions, installation instructions or warranty cards are made of printed paper and therefore generally count as printed products. For the EUDR, however, the decisive factor is whether a product is included as a "relevant product" in Annex I and is placed on the market as an independent product. In this context, the legal framework has recently changed: Printed products ("ex 49") are no longer the typical connecting factor for EUDR, meaning that classic printed products such as brochures, leaflets or manuals should no longer be classified as subject to EUDR across the board.

Nevertheless, it is worth taking a proper inventory: as soon as documents are procured or placed on the market as separate goods (e.g. large print runs as merchandise, separately imported documentation packages), classification should continue to be based on Annex I and the specific customs tariff classification. The decisive factor here is not so much the "printed image", but whether the product falls under a covered product category and appears as a separate article in the movement of goods.

Check exception: Is it "correspondence"?

The EUDR also contains an exception for "correspondence". This refers to items that are used exclusively for communication, such as personally addressed letters, notifications or comparable business correspondence. Such consignments are not considered as "placing on the market" of a relevant product and are therefore generally not subject to EUDR.

In practice, however, this remains a marginal case: most inserts (e.g. standard instructions, warranty cards, assembly instructions) are not individually addressed, but mass-produced goods. At the same time, the framework has recently changed: Printed products ("ex 49") are no longer the typical scope link, meaning that these materials are now much less likely to be EUDR-relevant "on their own".

However, the logic of the individual case is important: If a "correspondence" consignment itself contains a relevant product (e.g. a recorded wood/paper product as goods), a declaration of due diligence may still be required for this - the exception does not automatically protect the relevant content.

Sales packaging, displays and POS materials

Not only secondary packaging, but also POS (point of sale) materials, sales displays and marketing materials are traded across borders as part of modern goods logistics. The extent to which these fall under the EUDR depends on their material composition, their function and their individual tariff classification.

Sales packaging - what does it include?

We encounter sales packaging every day: from folding cartons for food to shipping boxes and elaborate gift boxes. In the customs tariff, packaging made of paper, cardboard and paperboard is often classified under 4819 (e.g. folding boxes, cartons, carrier bags). However, the decisive factor for the EUDR is not just the goods code, but how the packaging is used and provided in the actual flow of goods.

However, packaging becomes EUDR-relevant if it is placed on the market, imported or distributed as a separate product (standalone/empty) - for example, if a company procures or sells empty folding boxes, gift boxes or packaging components as its own items. In these cases, precise tariff classification and comparison with Annex I as well as the corresponding documentation of the supply chain are key to avoiding risks such as retention of goods or compliance violations.

POS displays and advertising materials made of paper

POS materials - i.e. marketing materials at the point of sale such as stands, window displays, shelf wobblers or cardboard landscapes - are becoming increasingly important in the retail sector. Many are made from printed cardboard, sturdy corrugated cardboard or wood.

Whether these products fall under the EUDR depends on two points in particular:

1. Are they marketed as standalone products?
2. Do they fall under a product category listed in Annex I with their specific classification?

A recent clarification is important here: materials that are used exclusively to support, protect or carry other products are not considered "relevant products" - regardless of the CN code. This can play a role for certain POS solutions in particular, if they are functionally more likely to be classified as a carrier/packaging solution.

In practice, POS displays made of paper/cardboard are often listed under product codes from Chapter 48 (e.g. "other articles of paper and paperboard" such as 4823, depending on the specific design). Advertising prints as a separate product category (Chapter 49, e.g. 4911), on the other hand, are no longer the typical scope link, as printed products ("ex 49") have been removed from Annex I.

Catalogs, brochures and assembly instructions

Not only packaging, but also inserts, information materials and technical accompanying documents cause uncertainty in practice. However, the decisive factor is that the EUDR is linked to "relevant products" in accordance with Annex I (CN/customs tariff codes) and the framework here has recently changed. Printed products ("ex 49") are no longer part of Annex I, which is why classic printed products are now generally not to be treated as independent EUDR-relevant goods.

Catalogs and advertising brochures

Catalogs, brochures and advertising brochures are often classified under 4911. This classification has long been a frequent trigger for EUDR discussions. Currently, however, it is no longer the relevant "scope trigger", as printed products ("ex 49") have been removed from the annex.

Assembly instructions

In practice, assembly instructions, assembly aids or technical drawings are usually also classic print products. This also applies here: As purely printed documents, they are typically no longer the central EUDR use case.

Also important for delivery practice: Documents that are only enclosed with a delivery of goods (e.g. standard instructions in a box) are regularly covered by the accompanying material/packaging exemption as long as they are not marketed as independent goods or traded separately.

What about digital documentation?

Digital documentation (PDF, online manual, QR code link) is not covered by the EUDR - the regulation is aimed at physically relevant products. Consistent digitalization can therefore help to reduce complexity in the accompanying material.

In the case of physical data carriers (e.g. USB sticks), as before, it is not the data record that is relevant, but only whether paper or wood components included in the specific flow of goods are placed on the market as independent products.

Recommendations for companies

The classification and implementation of EUDR obligations is challenging, especially for companies with complex or international supply chains. A proper risk analysis and effective internal processes are key for manufacturers, importers and distributors. It is important to note that the EUDR is linked to "relevant products" in accordance with Annex I (CN/customs tariff codes) and the framework has recently changed in certain areas (e.g. deletion of printed products "ex 49").

Which areas are affected?

Particularly relevant are companies that import, manufacture, store or market wood or paper-based products as standalone goods, such as packaging/packaging components, labels, POS displays or certain paper/cardboard products, provided they fall under Annex I.

At the same time, a key clarification from the FAQs applies: materials that are used exclusively to support, protect or carry another product (support/protect/carry) are not to be treated as a "relevant product" - regardless of the CN/HS Code. In practice, this applies to many typical shipping and sales packaging as well as accompanying materials that only "accompany" the product.

Establish internal testing processes

Companies should establish a clear inspection process that systematically evaluates all affected items, ideally integrated into existing quality, customs or audit routines. Three inspection steps have proven themselves in practice:

1. Classification (CN/TARIC code + material)
2. Function allocation (standalone product or only support/protect/carry)
3. Comparison with Annex I and documentation of the decision.

DDS & information system: implementation is now a data process

For relevant products, companies must prepare the due diligence information in such a way that it can be converted into a due diligence statement (DDS). This includes information such as product/CN code, quantity, country of production and - depending on the product - geolocation data.
Submission and administration is carried out via the European Commission's information system, which is already live.

Expand supplier documentation

Many companies are dependent on information from their suppliers. Therefore, customers should request and regularly update EUDR-relevant evidence in a standardized manner - especially where items are procured and placed on the market standalone (e.g. empty packaging, POS material as goods, labels). The core is a standardized data set that maps the DDS obligations (including geolocation where applicable).

Excursus: Chain of custody certificates

Chain-of-custody certificates (CoC) prove the complete traceability of a raw material - such as wood or paper - along the entire supply chain, from its origin to the finished product. They confirm that the material comes from a certified, legal source and has not been mixed with non-certified raw materials during processing and trade. In the context of the EUDR, chain of custody certificates help to fulfill the required duty of proof and due diligence, even if they alone do not automatically guarantee full legal compliance.

Conclusion

Not everything made of wood or paper is automatically covered by EUDR. The decisive factors are Annex I, the correct CN/TARIC classification and the functional context: If the material is used exclusively as protective or carrier packaging, it is generally not covered. Classic printed products (HS 49) are also no longer within the scope of application.

Companies should now check all standalone imported or distributed wood and paper products against Annex I and set up data and evidence in such a way that they can be transferred to a DDS. The remaining lead time until December 30, 2026 should be used consistently; those who prepare early will reduce compliance risks and avoid supply disruptions.