EUDR and wood packaging: pallets, cases and due diligence obligations

The real question is not “is wood covered?”: it is. It is: “is this packaging placed on the market as a product, or does it only serve to transport goods?”. This use test decides everything, and it is what structures this report, linked to our complete guide to the EUDR.

In brief

Why wood packaging falls within the scope of the EUDR

The EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood, as well as products derived from them or containing them, provided they are listed in Annex I. For the wood sector, this annex is based on the customs nomenclature: the Harmonised System (HS, Harmonized System) and its European version, the Combined Nomenclature (CN, 8-digit code).

Reading Annex I of the EUDR: HS codes, CN codes and heading 4415

Annex I of the EUDR covers in particular:

• HS chapter 44 (wood, wood charcoal, articles of wood), including heading 4415: packing cases, boxes, crates, drums, cable-drums, pallets, box pallets and pallet collars;
• pulp and paper (chapters 47 and 48), with exceptions for bamboo and recovered products;
• certain wooden seats and furniture (ex 9401, 9403 30 to 9403 60, 9403 91);
• prefabricated wooden buildings (9406 10).

Heading 4415 is therefore the entry point for wooden pallets and cases. But being listed in Annex I is not enough: it is the use, and the way the packaging is placed on the market, that decides.

The exclusion clause that changes everything

Under entry 4415, Annex I explicitly excludes packing material “used exclusively as packing material to support, protect or carry another product placed on the market”. In operational terms:

• a pallet that carries goods delivered to a customer is not, in that use, an EUDR product;
• a pallet sold empty as goods is, on the other hand, potentially in scope.

The same packaging can therefore change status depending on the flow. Qualification is not decided at the level of the product catalogue, but at the level of each transaction.

“[…] not including packing material used exclusively as packing material to support, protect or carry another product placed on the market”Regulation (EU) 2023/1115, Annex I, heading 4415 · consolidated text, EUR-Lex

Exact scope: transport packaging, presentation packaging and special cases

The decisive test: placing on the market or mere packaging function

The regulation applies when a relevant product is placed on the market of the Union (first making available for distribution, consumption or use, in the course of a commercial activity) or exported. For packaging, the Commission's guidance document distinguishes two situations:

• out of scope: packaging used exclusively to support, protect or carry another product, presented with that product. This exclusion applies whatever the HS code of the packaging, and even if the product carried is not itself covered by the EUDR;
• in scope: packaging placed on the market as a product in its own right (for example an empty pallet or case that is sold), as well as a container that gives the packed product its essential character (typical case of the decorative gift box sold with its contents).

Transport packaging or presentation packaging?

In practice, Packaging teams often think in two families: transport packaging (pallets, cases, crates, pallet collars) and presentation packaging (sleeve, gift box, box intended for the consumer). The regulation does not use exactly these categories: it applies the use test and the essential character criterion. The table below maps one to the other.

Reused and deposit-based pallets and closed-loop systems

Reusable pallets are the most frequent case - and the most misunderstood. Two principles settle the matter:

1. Suitability for reuse does not, on its own, create inclusion. Packaging clearly intended for repeated use falls outside the scope as soon as it is used to support, protect or carry another product and is presented with it.
2. Returning empty packaging into a reuse loop is not a new placing on the market. The Commission's FAQ takes the example of a closed-loop system for pallets: packaging already used for that purpose and returned to be reused does not become, merely by being returned, a product to be declared.

However, if the pallet is supplied as a stand-alone product (purchase/sale of empty pallets, provision to a customer) before its packaging use, it may remain in scope. The useful reflex: document the nature of the flow - a deposit or pooling service is described by a contract and rotation tracking, not by an invoice for goods.

What the regulation does not cover - and what must not be wrongly excluded

The following remain outside the due diligence scope, in their packaging function:

• pallets, cases and crates used exclusively to support, protect or carry another product and presented with it;
• used, second-hand or waste-derived packaging, for which Delegated Act (EU) 2026/2102 introduced targeted exclusions, including for packing materials.

But beware of over-exclusion. The exclusion relates to the packaging function, not to the material. As soon as wooden packaging is sold as a product (unit sale, invoiced provision, import for resale), the full EUDR analysis must be applied again.

Classifying the flows decides which ones must be subject to due diligence.

Practical obligations for the buyer and for the exporter

The regulation distinguishes three roles. What you have to do depends on your position in the chain, the qualification of the flow and your size.

The buyer or importer placing the product on the market (operator)

If you place a wooden pallet or case on the market as a product (buying and reselling empty pallets, importing for own use or resale), you are an operator within the meaning of the regulation and you must:

• exercise due diligence before placing on the market (Article 8);
• collect the required information (Article 9): product description, quantity, country of production, geolocation of the plots, date or period of harvest, supplier identity, evidence of legality;
• carry out a risk assessment (Article 10) and then, if necessary, risk mitigation measures (Article 11);
• submit a due diligence statement (DDS, Due Diligence Statement), which is the statement evidencing that due diligence has been exercised, in the EUDR information system hosted in TRACES;
• keep the statement and its supporting documents for at least five years.

If the pallet is only transport packaging accompanying goods, it falls outside the scope: no DDS is required for the pallet as such. At customs, this case is declared with code Y190 (packaging used exclusively to support, protect or carry another product).

The exporter

On export, the operator is in principle the declared exporter. Two cases arise:

• you export goods on pallets or in cases: packaging used exclusively as packaging is not covered, but the exported products are if they are listed in Annex I - the DDS then covers those products, not their packaging;
• you export pallets or cases sold as products: you are in scope and must apply the same due diligence as on import.

The downstream operator and the trader

The 2025 simplification concentrated due diligence on the first operator placing the product on the Union market. Downstream operators and traders do not repeat the due diligence and, as a general rule, no longer submit a DDS, but they retain:

• traceability: identification of direct suppliers and of professional customers;
• obtaining and keeping the applicable DDS reference;
• registration in the information system for non-SMEs;
• the obligation to inform the authorities and their customers in the event of new information on a risk.

Information to collect from the pallet supplier

If wooden packaging falls within the scope, the quality of the file depends entirely on what you ask your supplier for. Here is the framework to cover.

Recommended collection method:

1. Segment suppliers and flows (purchased pallets vs deposit-based pallets, imported wood vs European wood).
2. Standardise a questionnaire and the expected formats, including the required geographic format.
3. Open a dedicated channel: a supplier portal avoids collection by email and lets you track who has filled in what.
4. Check on receipt: completeness, geographic consistency, validity of the geo file, consistency of batches.
5. Version each dataset: a corrected geolocation must be kept in the history.

Geolocation of the plots of origin: points and polygons

Geolocation is the most technical point of the regulation and the one that most often causes supplier files to fail. It concerns the plots where the wood was harvested, not the factory where the pallets are made.

Three clarifications that avoid the most frequent rejections:

• the threshold is “more than 4 hectares”: a plot of exactly 4 hectares can be declared with a point;
• a polygon must follow the actual boundaries of the plot, not a central point with a radius;
• the order expected in GeoJSON is longitude, latitude, and the polygon ring must be closed.

How the EUDR fits with the other requirements applicable to wood packaging

Wooden packaging is subject to several bodies of rules that do not overlap. Confusing them is the most frequent source of error.

ISPM 15: a phytosanitary prerequisite, not EUDR evidence

ISPM 15 applies to wood packaging material used in international trade (pallets, cases, dunnage boards). In practice, the wood must be debarked and have undergone an approved treatment - heat treatment (HT) requires the core of the wood to reach the temperature and duration defined by the standard - and then bear a legible, non-transferable ISPM 15 mark, with the IPPC symbol, the country code and the number of the approved operator. This mark attests to phytosanitary compliance: it says nothing about forest origin or the absence of deforestation.

PPWR: reuse is a separate issue

The PPWR (Regulation (EU) 2025/40) applies from 12 August 2026. Among other things, it sets reuse targets for certain categories of transport packaging, including pallets, with a gradual ramp-up from 2030. Key point: being physically reusable is not enough to count as reusable packaging - it must be designed for several rotations and used in a re-use system. But this PPWR requirement is separate from the EUDR: packaging can count towards PPWR targets while remaining outside the scope of the EUDR, and vice versa.

FSC, PEFC: useful, but not sufficient

The FSC (Forest Stewardship Council) and PEFC (Programme for the Endorsement of Forest Certification) are forest certification schemes. The Commission's guidance document recognises their usefulness in risk assessment, but points out that certification does not replace due diligence and does not automatically prove zero deforestation. Treat it as one element among others, not as a free pass.

Common mistakes

1. Concluding “pallet = out of scope” as a matter of principle. Status depends on the flow: a pallet sold empty is a product.
2. Concluding “code 4415 = in scope” as a matter of principle. Exclusive packaging use takes the pallet out of scope.
3. Confusing ISPM 15 and the EUDR. A phytosanitary mark is not evidence of forest origin.
4. Confusing the PPWR and the EUDR. Recyclable reuse says nothing about deforestation.
5. Believing that FSC or PEFC certification is enough. It contributes to the file, it does not replace it.
6. Not documenting the use of the packaging. Without a record of the flow, the exclusion cannot be justified during an inspection.
7. Forgetting pallets bought empty and then transferred. This is precisely the case that tips into scope.
8. Dealing with the pallet issue after the date of application. Collecting supplier data takes weeks: start it ahead of time.

Checklist: operational steps

• To check, flow by flow
• Make an inventory of all wooden packaging used or purchased: pallets, cases, crates, pallet collars.
• Qualify each flow: transport packaging accompanying goods, or a product placed on the market.
• Confirm the 8-digit CN codes with the customs teams.
• Clarify your role (operator, downstream operator, trader) and your size.
• For flows in scope: launch data collection (product, origin, geolocation, legality, batch).
• Check the GeoJSON format of the geometries (polygons above 4 ha, points below).
• Request and archive the ISPM 15 marks and treatment evidence for imported pallets.
• Document reuse or deposit loops (contract, rotation tracking, return).
• Secure the retrieval of the DDS reference from the upstream supplier.
• Version the evidence and plan for retention of at least five years.
• Include EUDR clauses in pallet supplier contracts.

Next steps

Three decisions shape the issue: qualify each flow (transport packaging or product), secure supplier data for flows in scope, and document the use of reused or deposit-based pallets to justify the exclusion in the event of an inspection.

For the complete step-by-step method, rely on our EUDR compliance guide.

This guide extends the approach described in our complete EUDR guide: the difficulty is not understanding the text, but holding together supplier data, product data and documentary evidence.