Businesses relying on pallets and packaging for transport are unlikely to face significant disruption under the EU Deforestation Regulation (EUDR), according to the European Federation of Wooden Pallet and Packaging Manufacturers (FEFPEB), which issued guidance confirming that materials, when used to carry goods, fall outside the scope of the rules. The EUDR, designed to prevent products linked to recent deforestation or forest degradation from entering the EU market, requires companies to prove that their goods are sustainably sourced. However, FEFPEB clarified that wood packaging is only subject to the regulation when sold as a standalone product — not when used in transport.
“As soon as the pallet or packaging is used to support, protect or carry another product, it is no longer covered by the EUDR, even if it is listed separately on the invoice of a product or when it is returned by a retailer to its supplier,” the organisation stated. “Once the concerned packaging becomes a packaging material used exclusively as packaging material to support, protect or carry a product, it is then not covered by the scope 27 of the Regulation.”
The guidance also confirms that pallet pooling systems and closed-loop exchanges — where pallets are rented or traded between companies — are exempt from EUDR requirements: “Similarly, empty packaging material already used for the first time to support, protect or carry another product, for instance when traded within a closed loop exchange system (i.e., pallets transferred from one company to another to be reused for transport) is not covered by the Regulation,” the FEFPEB said.
FEFPEB Secretary General Fons Ceelaert said the federation supports the regulation’s environmental goals but wants to ensure clarity for its members and customers: “FEFPEB’s membership and association pooling businesses are fully supportive of EUDR’s aims to protect forests around the world,” Ceelaert said. “We have produced this guidance to share with customers and the supply chain to give clarity on the implications of these regulations.”
EU Parliament Rejects the EUDR’s Risk System
The guidance comes after Wood Central revealed, last month, that the European Parliament voted to reject the benchmarking system, which categorised 190 different countries based on their risk of deforestation. Wood Central understands that the motion also stated that the EUDR’s inclusion of only three risk categories – low, standard, and high risk – was “insufficient to adequately differentiate between countries with vastly different levels of deforestation risk.”
It follows the EPP’s success last year in integrating a new “no-risk” category into Parliament’s negotiating position on the EUDR. However, the category did not make it into the agreement between Parliament and the European Council. That agreement, however, delayed the implementation of the law by a year, with the EUDR now becoming applicable for large companies in December 2025 and for micro- and small enterprises in June 2026. The Commission had proposed the delay, noting that “several global partners have repeatedly expressed concerns about their state of preparedness,” and adding that even within the EU, “the state of preparations amongst stakeholders in Europe is also uneven.”
- To learn more about the country benchmarking system, click here to read Wood Central’s exclusive interview with Marigold Walkins and Kerstin Canby from Forest Trends last month.
