Supplier Evaluation

EUDR Takes Effect on 30 December: A Due-Diligence Checklist for Buyers Sourcing Wooden Packaging from China

ChenBridge Insights · 7 min read

If you source wooden crates, pallets, or paper-based packaging from China for the EU market, a date belongs on your procurement calendar: 30 December 2026. That is when the EU Deforestation Regulation — EUDR, Regulation (EU) 2023/1115 — starts applying to large and medium-sized operators placing relevant products on the EU market.

Unlike packaging rules that target the pack itself — recyclability, chemical content, labelling — EUDR reaches two tiers up your supply chain. It asks where the wood was harvested. Not which province. The plot.

What EUDR covers — and the line most buyers get wrong

The regulation's product list (Annex I) includes HS 4415: packing cases, boxes, crates, drums and similar packings of wood; cable-drums of wood; pallets, box pallets and other load boards of wood; and pallet collars. For paper and paperboard, it covers pulp and paper of Chapters 47 and 48 (heading 4421) — except bamboo-based and recovered (waste and scrap) products.

But the single most misunderstood point is the carrier exemption: packing material used exclusively to support, protect or carry another product placed on the market is not covered. Wooden packaging sold as a product in its own right is. Get this distinction wrong in either direction and you pay for it — unnecessary due diligence on exempt packaging, or a shipment exposed because you assumed the rules didn't apply.

What "compliant" actually requires

Two conditions have to hold for every relevant product: it must be deforestation-free (no wood harvested from land deforested after 31 December 2020), and it must have been produced in accordance with the relevant legislation of the country of production.

Before placing the goods on the EU market, the operator must exercise due diligence and submit a Due Diligence Statement referencing plot-level geolocation for the harvest areas. Note where the legal duty sits: with the EU operator or importer. But every data point that statement needs — harvest location, species, production dates, legality evidence — comes from your supply chain.

Stacked timber with log ends facing out — the harvest plots behind wood like this are what EUDR traceability has to reach back to — Stacked timber, log ends facing out. Under EUDR, traceability has to reach back to the plot where the wood was harvested — not just the country, and not just the mill.

What's new: the September delegated act

Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, sharpened the packaging line considerably. Three changes matter for buyers:

Used and second-hand wood is out. Reclaimed timber built into new products no longer triggers traceability — the Commission explicitly didn't want to discourage circular practices.
Bamboo and rattan are out. Products made of them are excluded even under a timber heading — to the extent they are made of those materials. A product mixing bamboo with timber still needs due diligence on the timber.
Recycled fibre takes a different path. Packaging made entirely from recovered or recycled waste falls outside traceability-to-origin obligations. Virgin wood fibre does not.

Five questions to put to your Chinese supplier — now

"Is this item even in scope?" Carrier or product — settle the exemption question first, with your EU importer, before spending a euro on documentation.
"Where exactly was the fibre harvested?" Plot-level geolocation, species, and production dates. The country of conversion is not the answer.
"Can you evidence legal production?" Harvest rights, permits, and compliance with the production country's relevant legislation.
"Virgin or recovered?" The answer determines which documentation path you are on.
"Who is your fibre source?" Map the chain one tier further than you think you need to. An FSC or PEFC certificate supports the risk file, but it does not replace plot-level data or the Due Diligence Statement.

The bottleneck is not the form in Brussels

The Due Diligence Statement itself is paperwork. The hard part is whether a paper mill or timber supplier two tiers up your chain can produce harvest data it has never been asked for. With 30 December less than three months away, that is the conversation to start this week — building a new data chain takes longer than filling in a form.

This article is a buyer's briefing, not legal advice. Scope questions should be confirmed with your EU importer and legal counsel.