EU: Commission Guidance on Deforestation Regulation  

In June 2025, the Global Reporting Initiative (GRI) announced the launch of new climate change and energy The European Commission has published a notice providing clarifications and guidance on certain aspects of Regulation (EU) 2023/1115 on Deforestation-Free Products (EUDR). 

In particular, the notice clarifies the circumstances under which packing does not fall under the scope of the EUDR:  

  • Packing material classified under HS code 4819 (“Cartons, boxes, cases, bags and other packing containers, of paper, paperboard, cellulose wadding or webs of cellulose fibres; box files, letter trays, and similar articles, of paper or paperboard of a kind used in offices, shops or the like”) is not covered by the EUDR when is used to “support, protect or carry” another product.  
  • Articles under HS code 4415 (“Packing cases, boxes, crates, drums and similar packings, of wood; cable-drums of wood; pallets, box pallets and other load boards, of wood; pallet collars of wood”) are not covered by EUDR when they are used exclusively as packing material to support, protect or carry another product placed on the market.  
  • Both of the aforementioned categories of goods are covered by the EUDR when they are placed on the market or exported as products in their own right, rather than as packing for another product.  

In addition, the notice clarifies the role of certifications and third-party verification schemes, noting that “while such schemes can be used in the risk assessment procedure under Article 10, they cannot substitute the operator’s responsibility as regards due diligence further to Article 8. This means that the use of such schemes does not imply a ‘green lane,’ since the operator is still required to exercise due diligence and is held liable if it fails to comply with the due diligence requirements of the EUDR.” 

This article originally appeared on inc.nutfruit.org.

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