The EU Deforestation Regulation and paper packaging imports
Does the EUDR cover honeycomb paper and other paper packaging? Scope, the 30 December 2026 date, the recycled fibre exemption and what importers must ask.
Most people think of the EU Deforestation Regulation as a rule for coffee, cocoa and palm oil.
It also covers wood. And paper is made from wood.
Honeycomb paper sold to an EU buyer as a product in its own right, such as rolls for an ecommerce packing table, is in scope of the EUDR. Paper of Chapter 48 is listed in Annex I. The same paper used only to protect other goods that it travels with is out of scope, and so is paper made entirely from recovered waste paper. For paper, the rules apply from 30 December 2026 to large and small operators alike, and the EU importer files the due diligence statement, using information it must get from the supplier.
This is one of the most changed laws I have followed. It has been amended three times since 2023, and the latest change came out in September 2026.
So treat this as my reading as a supplier, written in October 2026. It is not legal advice, and an EU importer should confirm the details with its own adviser.
Which texts apply today?
The base law is Regulation (EU) 2023/1115 (European Parliament and Council, Official Journal L 150, 9 June 2023). Three acts have changed it:
- Regulation (EU) 2024/3234 (Official Journal, 23 December 2024) delayed it by 12 months.
- Regulation (EU) 2025/2650 (Official Journal, 23 December 2025) delayed it by 12 more months and simplified the duties of downstream businesses.
- Commission Delegated Regulation (EU) 2026/2102 (Official Journal, 17 September 2026) rewrote the product list in Annex I, including the paper entry and the packaging wording.
The Commission keeps a summary page on the regulation on deforestation-free products (European Commission, DG Environment, checked 5 October 2026), and a long FAQ, now version 5 of April 2026.
When does it start for paper?
On 30 December 2026, for everyone selling paper.
Article 38(2), as amended in 2025, applies the main obligations from 30 December 2026. Article 38(3) gives micro and small operators until 30 June 2027, but it excludes products that were covered by the old EU Timber Regulation. Paper of Chapters 47 and 48 was covered by that regulation. The Commission's own page says the same thing in plain words: micro and small operators already covered by the Timber Regulation start on 30 December 2026.
So a small EU distributor of honeycomb paper does not get the extra six months.
I would plan as if the deadline is this December. Because it is.
Is honeycomb paper in scope?
It depends on how it reaches the EU market. The new Annex I entry covers "articles of paper pulp, of paper or of paperboard" under Chapter 48, with several exclusions.
| Situation | In scope? | Why |
|---|---|---|
| Honeycomb rolls imported into the EU to resell or to use in packing | Yes | Paper sold as a product in its own right |
| Honeycomb sheets or mailers imported as products | Yes | Same reason |
| Goods exported to the EU already wrapped in honeycomb paper, such as vases from India | No, for the wrap | Packing material used only to support, protect or carry another product is excluded |
| Paper made entirely from recovered waste paper | No | Annex I excludes recovered (waste and scrap) products |
| Paper with any virgin fibre | Yes, for the virgin share | That fibre must be traced to the plot where the wood was harvested |
| Used or second-hand paper products | No | Excluded in the new Annex I entry |
Recital 16 of the 2026 delegated act explains the packaging rule. Packing materials placed on the market as products on their own are in scope. They fall outside it when they are used to support, protect or carry another product. FAQ 2.5 adds a useful test: what matters is whether customs would classify the packaging together with the goods, not whether both appear on one invoice.
This is why the same roll can be in scope for one buyer and out of scope for another.
What about recycled fibre?
Paper made entirely from material that has completed its life and would otherwise be waste is outside the EUDR. That sentence is in the introduction to Annex I.
FAQ 2.8 explains the catch. Most recycled paper contains a small share of virgin pulp or pre-consumer scrap to strengthen the fibre. If the product contains non-recycled material, that material is in scope and must be traced back to its plot of origin through geolocation.
I want to be careful here.
This touches our own paper, and we have an interest in the answer. Our usual FSC claim on honeycomb is FSC Recycled, which under FSC rules means the fibre comes exclusively from reclaimed sources. FSC counts both pre-consumer and post-consumer material as reclaimed. The EUDR uses a different test, and I have not found an official answer on exactly how every kind of pre-consumer scrap is treated under the new 2026 wording.
So do not assume that an FSC Recycled claim settles the EUDR question. Ask your supplier what share of the fibre is post-consumer waste paper, what share is pre-consumer, and whether there is any virgin pulp. Our guide to FSC labels explains the FSC side.
Who does what?
The EU operator carries the duty.
The supplier outside the EU provides the information. That is where we come in.
FAQ 1.30 says plainly that the Regulation has no legal obligations for non-EU countries. The operator is the person who first places the product on the EU market, which for an import is usually the importer who releases the goods for free circulation. Before doing so, the operator must submit a due diligence statement through the EU information system (Article 4).
The 2025 amendment removed the duty for downstream operators and traders to submit their own statements. Larger ones must still register in the information system, and the first one after the operator keeps the statement reference numbers. So the burden now sits mainly with the first EU business in the chain.
Article 9 sets out what the operator must collect. For paper, an EU importer will usually ask the supplier for:
- A product description, including the common and scientific names of the wood species in any virgin fibre.
- The quantity, in net kilograms.
- The country of production, meaning where the wood was harvested.
- The geolocation of every plot where the wood was harvested, with the date or time range of harvest.
- The name and address of the supplier.
- Evidence that the wood is deforestation-free after the cut-off date of 31 December 2020 and was produced legally in the country of harvest.
- The share of recycled and virgin fibre, so the recycled part can be excluded.
FAQ 1.27 says that if the operator cannot get this information, it must not place the product on the market. That is the practical risk for a buyer: a container that is legal on paper but cannot be sold.
Does India's low-risk rating help?
It helps. But less than people think.
Commission Implementing Regulation (EU) 2025/1093 (Official Journal, 23 May 2025) lists India among the low-risk countries. Under Article 13, an operator buying from low-risk countries can use simplified due diligence. It does not need to carry out the risk assessment and mitigation steps.
But two things stay the same. The information in Article 9, including geolocation, is still needed. And the low-risk rating follows the country where the wood was harvested, not the country where the paper was made. Kraft paper made in India from imported virgin pulp takes the rating of the country the pulp wood came from.
A checklist for EU importers of paper packaging
- Decide which of your products are in scope, using the table above. Rolls and sheets bought as products usually are.
- Ask each paper supplier for the fibre composition in writing: post-consumer, pre-consumer and virgin shares.
- For any virgin share, ask for species, country of harvest, geolocation and harvest dates.
- Confirm who in your company will submit the due diligence statement, and register in the information system.
- Keep the reference number of each statement with the shipment records.
- Repeat the request whenever the supplier changes its paper source.
Under Article 25, the maximum fine that member states set must be at least 4% of the operator's EU-wide annual turnover. This is not a file to leave for 29 December.
Where we stand
We do not have every answer ready for every buyer, and I will not pretend we do. The rules changed again in September 2026, and the questions on pre-consumer fibre are still being worked out across the paper trade.
What I can promise is this. We will give you a written answer on the fibre composition of the honeycomb paper we quote. We will also tell you plainly what we can and cannot provide for your due diligence statement. If you also need help with the EU packaging law, see our guide to PPWR and honeycomb paper, and for customs and documents, our guide to importing honeycomb paper into the EU.
Send your EUDR questionnaire with your enquiry through the contact page.
We would much rather answer it before the order than after the container reaches the port.
Questions buyers ask
Does an Indian exporter need to register in the EUDR information system?
No. The Commission's FAQ says the Regulation has no legal obligations for non-EU countries. The EU importer files the due diligence statement. But the importer cannot do that without information from you, so in practice the work reaches the supplier.
Is FSC certification enough for EUDR?
I would not treat it as enough. FSC helps with information about where fibre came from, but the EUDR duty sits with the EU operator, and it asks for specific items such as geolocation of the plots where the wood was harvested.
India is a low-risk country. Does that mean no due diligence?
No. Low risk allows simplified due diligence, which skips the risk assessment and mitigation steps. The information gathering, including geolocation, still applies. And the country that counts is where the wood was harvested, not where the paper was made.
