The manufacturers' federation clarifies the scope of the European Union's deforestation rules ahead of their introduction in 2025.
The European Federation of Wooden Pallet and Packaging Manufacturers (FEFPEB) has announced that the forthcoming EU Deforestation Regulation (EUDR) will not significantly affect customers who use wooden pallets and packaging for transport.
“Companies that use pallets and packaging for transport are unlikely to face significant disruption under the European Union Deforestation Regulation (EUDR),” acknowledges the European Federation of Wooden Pallet and Packaging Manufacturers (FEFPEB). The federation has drawn up guidelines confirming that materials used to carry goods fall outside the scope of the rules. The EUDR, which is designed to keep products linked to recent deforestation or forest degradation out of the European Union market, requires companies to demonstrate that their goods have been sourced sustainably. FEFPEB clarified, however, that the regulation applies to wooden packaging only when it is sold as a separate product, rather than used for transport.
“As soon as a pallet or packaging is used to support, protect or carry another product, it is no longer covered by the rules set out by Europe, even if it is itemised separately on the product invoice or if a retailer returns it to the supplier,” the organisation said. “Where the packaging in question becomes packaging material used solely to support, protect or carry a product, the provisions of the Regulation do not apply to it.”
The guidelines also confirm that pallet pooling systems and closed-loop exchange, where pallets are hired or traded between companies, are exempt from EUDR requirements: “Similarly, empty packaging material that has already been used once to support, protect or carry another product, for example where it is traded in a closed-loop system (i.e. pallets passed from one company to another for re-use in transport), does not fall within the scope of the Regulation,” FEFPEB representatives stressed.
The federation's Secretary General, Fons Ceelaert, stressed that the organisation supports the regulation's environmental aims and wants to make sure its members and customers understand them: “FEFPEB's members and the associations that bring companies together fully support the EUDR's aims of protecting forests around the world. We have produced this guidance to explain the situation to customers and to give the whole supply chain clarity about the regulation's impact.”
European Parliament rejects the EUDR risk system
The guidelines were drawn up after, in July this year, the European Parliament voted against the benchmarking system that placed 190 countries into categories according to their deforestation risk. The proposal states explicitly that the three risk categories set out in the EUDR – low, standard and high – are “insufficient to differentiate properly between countries with very different deforestation risks”.
In 2024, Peter Liese, a German Member of the European Parliament (MEP) and the EPP's spokesman on environmental matters, led the campaign against the immediate introduction of the EUDR. This follows the EPP's success last year in incorporating a new “no risk” category into Parliament's negotiating position on the EU's rules on responsible timber sourcing. That category was not included in the agreement reached between Parliament and the European Council. The agreement would, however, postpone implementation of the law by a year; as things stand, the European Union directive would have to be applied by large companies from December 2025 and by micro and small enterprises from June 2026. The Commission proposed postponing implementation, noting that “several partners around the world have repeatedly expressed concerns about their readiness”. It also stressed that even within the European Union “the state of readiness among stakeholders is uneven”.