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Understanding the EU Deforestation Regulation (EUDR): 5 requirements for sustainable packaging

To address climate change, large-scale deforestation, and their harmful impacts on biodiversity, the European Union has introduced a new regulation aimed at protecting forests by fighting deforestation. The Regulation on Deforestation-free Products (EUDR) was enacted in June 2023 and was set to take effect on December 30, 2024 (though a postponement is under consideration – refer to the EUDR timeline). The regulation bans the import and sale within the EU of products linked to supply chains that contribute to deforestation or the degradation of global forest ecosystems. We dig into this regulation for you.

  1. The EUDR as a response to the climate and societal crisis
  2. The goals of the Regulation on Deforestation-free Products (EUDR)
  3. Why does the Deforestation Regulation impact packaging manufacturers?
  4. Top 5 requirements from the Deforestation Regulation
    1. Measure #1: Mandatory implementation of a due diligence system
    2. Measure #2: Submitting the online due diligence declaration
    3. Measure #3: Inspections and penalties
    4. Measure #4: Risk categorisation by country
    5. Measure #5: Establishment of the European Deforestation Observatory
  5. Key milestones of the EU regulation on deforestation and forest degradation  (EUDR)
  6. For further reading
  7. Glossary

The EUDR as a response to the climate and societal crisis

Deforestation is progressing at a troubling pace, with 420 million hectares of forests lost between 1990 and 2020. This process accounts for 11% of global greenhouse gas (GHG) emissions, further intensifying climate change. By eliminating crucial carbon sinks, deforestation not only raises GHG emissions but also erodes biodiversity. In addition to its environmental impact, forest destruction affects local communities, especially Indigenous peoples who depend on forests for their livelihoods.

The goals of the regulation on deforestation-free products (EUDR)

The EUDR sets out to accomplish three primary objectives to address deforestation and the deterioration of forest ecosystems:

Get rid of deforestation caused by imported goods

As of December 30, 2025, commodities like soy, cocoa, coffee, wood, rubber, palm oil, and livestock will be barred from being sold in the European Union if their production has contributed to deforestation.

Decrease Greenhouse Gas Emissions

The EUDR combats deforestation, helping to preserve carbon-capturing forests (carbon sinks) and aiding in the fight against climate change.

Safeguard biodiversity and indigenous populations

The EUDR seeks to protect forests, preserving natural habitats for numerous animal species and securing the livelihoods of local communities.

Member States have repeatedly expressed their concern about persistent deforestation and forest degradation. They have emphasised that since current policies and action at global level on conservation, restoration and sustainable management of forests do not suffice to halt deforestation, forest degradation and biodiversity loss, enhanced Union action is needed in order to contribute more effectively to the achievement of the Sustainable Development Goals (SDGs) under the 2030 Agenda for Sustainable Development.
Logo of the European Parliament who published the PPWR Regulation for packaging and packaging waste
European Parliament Excerpt from the EUDR project

Why does the Deforestation Regulation impact packaging manufacturers?

The European Deforestation Regulation targets 7 main products that have the biggest impact on forests: soy, palm oil, cocoa, coffee, wood, rubber and livestock.
For the packaging industry, including companies like Bong, this means new requirements for tracking raw materials and transparency in the supply chain. Packaging manufacturers need to work closely with their paper suppliers to trace the origin of paper and cardboard (which comes from wood) to ensure their supply chains are not linked to deforestation. They also need to meet the EUDR’s strict documentation requirements.
For those in the packaging sector, this means putting in more effort to:

  • Tightly monitor the sources of their raw materials to ensure their suppliers are not contributing to deforestation.
  • Provide clear and detailed proof to customers that the wood used in packaging production complies with the EUDR's sustainability criteria.

Bong has been committed to an ambitious CSR strategy for years, with a key focus on adopting a responsible purchasing policy. Over 99% of the paper used in our products—such as paper bags, gift bags, e-commerce bags—comes from sustainably managed forests and holds PEFCTM or FSC® certification. The European Deforestation Regulation (EUDR) aligns seamlessly with this commitment, reinforcing Bong’s dedication to sustainable practices and ensuring greater transparency in our supply chain.

Our sustainability approach
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Top 5 requirements from the Deforestation Regulation

The European Union’s Regulation on Deforestation and Forest Degradation (EUDR) introduces several key measures to ensure that products linked to deforestation are not imported or placed on the European market.

Measure #1: Mandatory implementation of a due diligence system

Article 8 of the EUDR mandates that operators implement a due diligence system to minimize the risks of deforestation associated with their products.
This due diligence declaration must include:

  • Gathering information, data, and documents
  • Conducting risk assessments
  • Implementing risk mitigation measures

Maintaining records

Operators are required to review their due diligence system annually and keep all related documentation, including records, measures, and procedures, for a minimum of five years. These documents must be available to the relevant authorities upon request.

1. Collection of information, data, and documents (mandatory)

As per Article 9 of the EUDR, operators must collect and share the following details:

  • A description of the product, including its type, commercial name, and the common and scientific names of the tree species used
  • The quantity of the product placed on the market
  • The country and/or production areas
  • GPS coordinates of all production sites and the production period
  • Contact details (name, postal address, and email) of suppliers involved in the product’s production, as well as the companies to which the product was supplied
  • Evidence proving that the product is “deforestation-free” and complies with the laws of the producing country

The European Commission intends to establish a database to evaluate countries based on the likelihood that they contribute to deforestation during the production of goods. If a product originates from a country classified as low-risk by the Commission (see Measure #4), operators can follow a simplified due diligence process. This process requires only the collection of the information listed above. If the product is from a higher-risk country, operators will also need to conduct risk assessments and mitigation actions, as detailed below.

2. Risk evaluation (applicable only to products from non-low-risk countries)

Article 10 outlines that if a product is not sourced from a country deemed low-risk by the European Commission, companies are required to evaluate the potential deforestation risks associated with their products. This evaluation considers several factors:

  • The risk level of the country of origin
  • The presence of forests and indigenous communities in the production area
  • Consultations with local communities
  • The extent of deforestation or forest degradation in the region
  • The credibility of the information used
  • The transparency and history of the operators
  • The complexity of the supply chains
  • The risk of contamination with products from deforested areas

3. Risk mitigation: steps to address remaining risks

If a risk assessment determines there is no threat, no further action is necessary. However, when risks are identified, businesses are required to take steps to reduce or eliminate them.

Under Article 11, companies must act to ensure their products are not associated with deforestation unless the risk has been deemed insignificant or nonexistent. Any identified risks must be addressed before the products can be sold or exported. Examples of such measures include:

  • Gathering additional data
  • Carrying out independent audits
  • Offering training and support to help suppliers adhere to compliance standards
Download the image in PDF format

Measure #2: Submitting the online due diligence declaration

Before introducing products to the EU market, and after completing the necessary information-gathering steps, operators and traders must file a due diligence declaration through an online platform managed by the European Commission. This centralised system will streamline the submission process for all declarations.The platform will enable:

  • Competent authorities and, after anonymisation, the general public to access traceability information easily.
  • Transmission of due diligence data to customs authorities, aiding in controls and enforcement of penalties.
Article 3 - Relevant commodities and relevant products shall not be placed or made available on the market or exported unless all the following conditions are fulfilled : a) they are deforestation-free; b) they have been produced in accordance with the relevant legislation of the country of production; and c) they are covered by a due diligence statement.
Logo of the European Parliament who published the PPWR Regulation for packaging and packaging waste
European Parliament Excerpt from the EUDR project

Measure #3: Inspections and penalties

The regulation establishes a robust system of inspections to ensure that products entering the European market comply with the rules, as detailed in Article 16 of the EUDR. Responsibility for conducting inspections and enforcing compliance lies with the competent authorities in each Member State. Businesses found to be non-compliant may face significant penalties.

Article 24 mandates that these penalties be effective, proportionate, and dissuasive, ensuring operators fulfill their due diligence obligations. Companies failing to take corrective action may be subject to:

  • Financial penalties
  • Confiscation of products or profits
  • Or even temporary bans from the market

Measure #4: Risk categorisation by country

Under Article 29 of the EUDR, the European Commission will classify countries into risk levels—low, standard, or high—based on the likelihood that their exports to the EU contribute to deforestation. This assessment considers factors such as deforestation and forest degradation rates, as well as the expansion of agricultural land for the seven key products linked to deforestation: soy, palm oil, cocoa, coffee, wood, rubber, and livestock.

The risk categorisation impacts due diligence obligations. For products sourced from low-risk countries, businesses can follow a simplified process that primarily involves gathering basic information.

Measure #5: Establishment of the European Deforestation Observatory

The EUDR calls for the creation of the EU Observatory to monitor deforestation, forest degradation, global forest cover changes, and the underlying causes. This Observatory will track and analyse global deforestation trends, serving as a central hub for data.

Leveraging advanced remote sensing tools, including those from the Copernicus program, the Observatory will provide accessible information to authorities, businesses, and consumers across Europe.

The European Union Deforestation Regulation (EUDR) was originally scheduled to apply from 30 December 2024. Smaller businesses, including micro-enterprises, were granted an additional six-month transition period, extending their compliance deadline to June 2025.

However, in December 2024, following concerns expressed by both Member States and economic operators, the European Parliament approved a first one-year postponement of the regulation’s implementation timeline. The revised dates were set as follows:

  • Medium and large companies would need to comply by December 30, 2025
  • Micro and small businesses would have until June 30, 2026

A further delay was later introduced to provide companies and supply chains with more time to strengthen their compliance frameworks and operational readiness. The application dates are now:

  • Medium and large companies would need to comply by December 30, 2026
  • Micro and small businesses would have until June 30, 2027

The European Deforestation and Forest Degradation Regulation (EUDR) represents a bold move by the European Union to safeguard global forests. At Bong, we view this as an opportunity to enhance our supply chains by incorporating more stringent environmental standards, aligning with the responsible purchasing goals outlined in our CSR report.
By prioritizing raw material traceability, we’re not only reinforcing our CSR commitments but also responding to the rising demand from customers for sustainable and transparent practices. Building on the earlier implementation of the PPWR regulation—discussed in this article—the EUDR reaffirms the EU’s commitment to reducing its environmental footprint and supporting a greener future.

Glossary:

  • Deforestation: The process of clearing or converting forests into land used for purposes other than forestry, particularly agricultural activities.
  • Key commodities: Products recognized by the EUDR as major contributors to global deforestation, such as soy, palm oil, livestock, cocoa, rubber, and wood.
  • Carbon sinks: Natural or man-made systems that capture and store carbon dioxide (CO₂) from the atmosphere, helping to mitigate greenhouse gas emissions. Forests, oceans, and soils are primary natural carbon sinks, absorbing CO₂ through processes like photosynthesis and other biological mechanisms.
  • SDGs (Sustainable Development Goals): A set of 17 global objectives aimed at eradicating poverty, protecting the environment, and promoting shared prosperity by 2030. These goals address a wide range of social, environmental, and economic challenges.

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