Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
The EUDR and the PPWR can apply to the same import, but they regulate different things. The EU Deforestation Regulation (EUDR) controls whether products made from commodities such as wood, cocoa or coffee are deforestation-free and legal, through a due diligence statement filed before they are placed on the market. The Packaging and Packaging Waste Regulation (PPWR) controls the packaging itself: how it is designed, documented, labelled and financed at end of life. The PPWR has applied generally since 12 August 2026, and the EUDR applies from 30 December 2026 to operators and to downstream operators and traders of any size, and from 30 June 2027 to micro and small operators established as such by 31 December 2024 and natural persons, except for timber products listed in the Annex to the EU Timber Regulation. Importers of packaged goods need a plan for both.
This guide compares the two regulations, shows where they overlap and suggests how to collect supplier data once instead of twice.
30 December
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Two regulations, one shipment
The EUDR, Regulation (EU) 2023/1115, covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, and the products made from them listed in its Annex I. Products may only be placed on the EU market or exported if they are deforestation-free, meaning produced on land not deforested after 31 December 2020, produced in line with the laws of the country of production, and covered by a due diligence statement submitted through the EU information system. Under the amendment adopted in December 2025, operators must comply from 30 December 2026. Micro and small operators established as such by 31 December 2024, and natural persons, have until 30 June 2027, except for timber products listed in the Annex to the EU Timber Regulation. Downstream operators and traders of any size must comply from 30 December 2026.
The PPWR, Regulation (EU) 2025/40, sets directly applicable EU rules for packaging. It entered into force on 11 February 2025 and has applied generally since 12 August 2026, with many requirements phased in later. Packaging placed on the market before 12 August 2026 can remain on the market.
EUDR | PPWR | |
|---|---|---|
What is regulated | Seven commodities and the listed products made from them | Packaging and packaging waste |
Who is responsible | Operators who place relevant products on the EU market or export them, and downstream operators and traders | Manufacturers, importers and distributors of packaging, and producers for extended producer responsibility (EPR) |
Main obligation | Due diligence and a due diligence statement before placing on the market | Packaging that conforms to the requirements, with documentation, labelling and EPR |
What an importer must do | File a due diligence statement as the operator | Make sure the non-EU manufacturer has complied, and show the importer's name and postal address on the packaging |
Key dates | 30 December 2026; 30 June 2027 for micro and small operators established as such by 31 December 2024, and natural persons (except EUTR Annex timber) | 12 August 2026 general application; many requirements from 2030 |
Records | Five years | Five years for single-use packaging, ten years for reusable packaging |
Under the PPWR, an importer is a person established in the EU that places packaging from a third country on the market. A manufacturer makes packaging or a packaged product, and a producer, the role that carries EPR obligations, can be a manufacturer, importer or distributor. The Commission’s FAQ describes the producer as the operator that fills the packaging. Under the EUDR, Member States must set maximum fines for companies of at least 4% of their total annual EU-wide turnover.
Where they overlap: paper, cardboard and wood packaging
Wood-based packaging is where the two regimes meet. Cardboard boxes, wooden cases and pallets are packaging under the PPWR, and some of them are also listed products under the EUDR.
The EUDR does not cover packaging that only does a packaging job. The original Annex I excluded “packing material used exclusively as packing material to support, protect or carry another product placed on the market”. Commission Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, reworded this exclusion. It now covers single-use packing material and packing containers used exclusively to support, protect or carry another product, and reusable packaging that is clearly suitable for repeated use, from the moment it is used for that purpose. Our summary of the Annex I amendment lists the other changes.
Two examples show the difference:
- A carton protecting imported ceramic tableware is outside the EUDR, because it only protects another product. It is still packaging under the PPWR.
- A shipment of new pallets or empty cartons sold as goods in their own right is not covered by the packaging exclusion, so the EUDR can apply. As packaging placed on the market, it also falls under the PPWR.
Customs declarations use document codes to show which EUDR situation applies. In September 2026 the Commission announced updated EUDR TARIC guidance that covers packing materials and packing containers under specific conditions. Check the current codes with your customs broker before your first declarations.
Where they don’t overlap
- Different products. The PPWR covers plastic, glass and metal packaging, which the EUDR does not touch. The EUDR covers the product inside the packaging, such as coffee, cocoa or furniture.
- Different questions. The EUDR asks where a commodity was produced and whether that land was deforested. The PPWR asks how packaging is designed, what it contains and how it is labelled and recovered.
- Different data. The EUDR needs plot geolocation and evidence of legal production. The PPWR needs technical documentation, an EU declaration of conformity from the manufacturer, and EPR registration and reporting.
- Different timelines. EUDR obligations apply from 30 December 2026, and from 30 June 2027 for micro and small operators established as such by 31 December 2024 and natural persons, except for timber products listed in the Annex to the EU Timber Regulation. PPWR limits on PFAS in food-contact packaging have applied since 12 August 2026, while minimisation, recyclability criteria, a 50% maximum empty space ratio for transport, grouped and e-commerce packaging, recycled content in plastic packaging and reuse targets start from 1 January 2030 or later, depending on implementing and delegated acts.
How to avoid double work
Both regulations depend on supplier data, and many of the same suppliers will be asked for both. A few habits reduce the effort:
- One supplier data request. Combine EUDR questions (origin, geolocation, legality) and packaging questions (materials, manufacturer details, declarations of conformity) in one request per supplier.
- Shared product master data. Keep one record per product with its CN code, the commodities it contains and its packaging components. Both assessments start from the same record.
- Clear roles. You can be the operator under the EUDR and the importer or producer under the PPWR for the same shipment. Record which role applies to which product.
- One calendar. Track 30 December 2026 for the EUDR alongside the PPWR’s staged dates.
For a step-by-step EUDR plan, use our EUDR countdown checklist. If you also report under the CSRD, see how the EUDR and CSRD overlap.
EUDR role
Operator, trader or downstream operator? The EUDR Obligations Checker identifies your role and whether you must file a due diligence statement, in under two minutes and without sign-up.
CBAM: the third import rule
Importers searching for the EUDR and the PPWR often meet a third regime: the Carbon Border Adjustment Mechanism (CBAM), Regulation (EU) 2023/956. CBAM is not about deforestation or packaging. It puts a carbon price on imports of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, and its definitive regime has applied since 1 January 2026. Importers must be authorised CBAM declarants before importing, unless they stay below an annual threshold of 50 tonnes net mass, which applies to the goods other than electricity and hydrogen. CBAM certificates go on sale from 1 February 2027, and the first annual declaration, covering 2026, is due by 30 September 2027.
How EUDR Passport helps
EUDR Passport covers the EUDR side of an import. It collects supplier and plot data, checks plot geolocation against forest cover and deforestation data, helps resolve flagged issues and files unlimited due diligence statements to TRACES, with records kept for five years. Suppliers take part at no cost. Downstream operators and traders can monitor their suppliers and check upstream reference numbers instead of filing. EUDR Passport does not cover the PPWR or CBAM.
Looking for EUDR software? EUDR Passport costs from €90 per product profile per year, and setting up your account and inviting suppliers costs nothing.
This article is general information, not legal advice. Sources: Regulation (EU) 2023/1115; Regulation (EU) 2025/2650; Delegated Regulation (EU) 2026/2102; Regulation (EU) 2025/40; European Commission, PPWR FAQ (August 2026); European Commission, PPWR implementation; European Commission, EUDR TARIC update; Regulation (EU) 2025/2083; European Commission, CBAM.
Frequently asked questions
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. It sets EU-wide rules on how packaging is designed, documented, labelled and financed at end of life, and applies directly in every Member State.
Generally not when the packaging only supports, protects or carries another product. Wood and paper packaging sold as goods in its own right can be in scope. Delegated Regulation (EU) 2026/2102 reworded the exclusion for single-use and reusable packaging from 18 September 2026.
It entered into force on 11 February 2025 and has applied generally since 12 August 2026. Many requirements, such as minimisation, recyclability and recycled content, apply from 1 January 2030 or later.
The legal obligations are separate, but the work does not have to be. One supplier data request and shared product master data can feed both assessments.
No. CBAM puts a carbon price on imports of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. It applies alongside the EUDR, with different products, data and deadlines.
30 DECEMBER 2026
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