European Union Deforestation Regulation (EUDR) explained:
As a leading provider of sustainable packaging solutions, we fully support the European Union’s commitment to halting deforestation and promoting responsible sourcing through the European Union Deforestation Regulation (EUDR).
To help our customers navigate the new rules shaping the future of packaging and supply chains in the EU, we have outlined the latest information on the EUDR — its importance, objectives, and how it will affect the process companies’ source, trace, and report on key commodities.
We are committed to supporting our customers through these changes by offering compliant, sustainable packaging solutions and expert guidance on regulatory requirements.
Please note this information does not constitute legal advice. This is a general summary of the EUDR based on information accessed by DS Smith. Customers should refer to publicly available information shared by relevant EU and national authorities and take advice on their own position as necessary.
What is EUDR?
The European Union Deforestation Regulation (EUDR) is a new regulation that applies to our industry and will be effective from 30th December 2025. It aims to combat deforestation and forest degradation by ensuring that products placed and made available on or exported from the EU market have not caused damage to forests.
What timeline is DS Smith working to for EUDR compliance?
DS Smith is working to comply with EUDR by the deadline set by the legislation, which means we will be compliant no later than 30 December 2025.
To understand the timeline of application for your business or to know more about EUDR guidelines please visit Regulation on Deforestation-free Products
What is in scope for EUDR?
Commodities in scope are cattle, wood, rubber, coffee, cocoa, soy and palm oil. For DS Smith, the principal in scope products include anything that contains virgin fibre, which includes (but is not limited to) paper, packaging solutions, point of sale, wood chips and pallets. The regulation does not apply to goods if they are produced entirely from a material that has completed its lifecycle and would otherwise have been discarded as waste. Out of scope items include: 100% recycled products; old corrugated containers; waste fibre; paper for recycling; and packaging machinery.
Is packing material in scope for EUDR when used to support, protect or carry another product placed on the Union market?
When DS Smith places a packaging product onto the Union market it will be in scope. When a DS Smith packaging product is used by a customer to support, protect or carry another product the packaging itself is not in scope.
Are pallets in-scope for EUDR?
When DS Smith makes a packaging product made from virgin fibres available on the European Union market, it is in-scope of EUDR and therefore DS Smith must carry out the necessary due diligence and provide a Due Diligence Statement to the relevant customer.
When a packaging product such as a pallet, is used as a packaging material to carry, protect or support another product it is not covered under the scope of the regulation.
Once packaging has been used to support, protect or carry another product, if it is subsequently sold as a stand alone product, it is not subject to EUDR. EUDR does not apply to used packaging when it is sold or rented.
It is important to note if packaging is repaired with in-scope materials, these must comply with EUDR and due diligence must be carried out on the new relevant products used for the repair.
What evidence will DS Smith provide to demonstrate EUDR compliance?
DS Smith will collect information, documents and data from relevant suppliers within its supply chain to demonstrate EUDR compliance, principally through the provision of Due Diligence Statements for in-scope products, which will be uploaded to the EU Traces Information System as required pursuant to the regulation. In addition, DS Smith will publicly report annually on its due diligence system, as required by the regulation.
Do certifications like FSC, SFI or PEFC and legislations like PPWR meet EUDR requirements?
Whilst these certifications go some way to indicating a products sustainability credentials, they do not in and of themselves indicate compliance with EUDR.
EUDR, Forest Stewardship Council (FSC®), Program for Endorsement of Forest Certification (PEFC) and Sustainable Forest Initiative (SFI) are complementary initiatives with a shared goal of fighting illegal logging, preventing deforestation and degradation, as well as promoting sustainable sourcing.
PPWR and EUDR are both part of the EU's Green Deal but address different aspects of environmental impact. EUDR targets deforestation and PPWR focus on reducing packaging waste and improving recyclability and reuse. Both regulations are complimentary, but PPWR compliance does not indicate compliance with EUDR.
DS Smith will continue FSC certification of its papers, packaging and sites and PPWR compliance. In addition, PEFC and SFI certifications will be considered by the business as and where appropriate.
Will DS Smith be proving customers who are traders with due diligence statements?
For all in-scope deliveries to all customers who are traders, DS Smith will be providing a Due diligence statement and verification number on the delivery documentation. Your obligations as a trader will be dependent on the specific context in which you are going on to supply your customers. Please refer to the regulation and where needed seek external counsel.
How does EUDR apply to products that are shipped prior to the deadline but used or delivered after the deadline?
If an in-scope product is placed on the EU market prior to 30th December 2025, the product does not have to meet the regulatory requirements of EUDR.
Placed on the market is defined by the regulation as occurring when an operator makes a relevant product available on the EU market (1) for distribution, consumption or use, (2) for the first time, and (3) in the course of its commercial activity.
If following the commencement of the substantive provisions of EUDR on 30th December 2025, the same product is then traded within the EU, i.e. made available on the EU market, the obligations of the trader are limited to gathering adequately conclusive and verifiable evidence to provide that the relevant commodity or product was originally placed on the EU market before entry into application of EUDR (i.e. before 30 December 2025).
Making Available on the EU market is defined by the regulation as any supply of a relevant product for distribution, consumption or use on the EU market in the course of commercial activity, whether in return for payment or free of charge.
If you have further questions, please contact your DS Smith representative who can help with getting answers from our compliance experts.