The EU Commission has clarified, as part of the revision of the Deforestation Regulation (EUDR), that certain packaging materials may be exempted from its scope. The adjustment is part of a package of measures to simplify regulation and also concerns the demarcation of which products are subject to due diligence obligations at all.
Despite this formal exception, the practical relevance for the packaging industry remains high, as packaging is often used in connection with regulated goods.
Packaging not the focus of regulation
The EUDR primarily targets commodities such as wood, palm oil, soya, or coffee, and products derived from them. Packaging is not treated as a distinct regulated product category in this context. Rather, the draft delegated act provides that certain packaging materials may be explicitly excluded from the scope.
This reduces the direct regulatory pressure on manufacturers of traditional packaging solutions, particularly if they are not themselves placed on the market as goods for sale but merely serve as wrapping.
Indirect duties along the supply chain
The real relevance arises along the supply chain. Companies that bring packaged goods onto the EU market must prove that the raw materials contained did not contribute to deforestation. Packaging can become part of the overall consideration if it itself is made of regulated materials such as wood or paper.
In such cases, it may be necessary to document the origin of the materials used in a traceable manner. Particularly with fibre-based packaging, this increases the demand for transparency and traceability.
Relief for small market participants
The Commission also stresses that the revised rules should, overall, lead to a significant reduction in administrative burdens. According to the Commission, annual compliance costs could fall by around 75 per cent.
Simplified procedures are provided, especially for small and medium-sized enterprises and first-time putters-on-the-market of raw materials, which indirectly also reduces the burden on smaller packaging actors.
Significance for the packaging industry
The packaging industry presents a mixed picture. On the one hand, many packaging materials are not directly regulated. On the other hand, there is increasing pressure to demonstrate transparent and deforestation-free supply chains, particularly for paper and wood-based materials.
Furthermore, it can be assumed that brand manufacturers and retailers will increasingly place demands on their packaging suppliers to secure their own EUDR obligations. This shifts responsibility partially along the value chain.
Source: EU Commission
