EUDR in 78 days: what UK packaging, print and display suppliers need to do
EUDR - The short answer
The EU Deforestation Regulation (EUDR) applies from 30 December 2026 for large and medium operators, and for micro and small operators already covered by the EU Timber Regulation. If you supply paper, board, packaging, displays or timber products to customers selling into the EU, they will ask you to prove where your materials came from— and FSC certification, while helpful, is not enough on its own.
That leaves 78 days.
The businesses that start now keep their EU customers. The ones that start in December spend Christmas explaining themselves.
EUDR - Will the date move again?
No.
EUDR has already been postponed twice. The second postponement, agreed in December 2025, moved the main application date to 30 December 2026 and asked the European Commission to review the rules for simplification.
That review was published on 4 May 2026. It brought updated guidance, a revised product scope and Information System upgrades. It did not move the date. The Commission was explicit: there will be no further postponement.
Plan for 30 December 2026. Treat any further change as a bonus, not a strategy.
What is in scope after the December 2025 changes?
EUDR covers seven commodities — cattle, cocoa, coffee, oil palm, rubber, soya and wood — and a long list of products made from them. For our sectors, wood is the one that matters, because it runs through paper, board and timber.
The December 2025 amendment changed the picture for print and paper.
Out of scope
Printed products under Chapter 49 of the customs tariff — books, newspapers, brochures, printed advertising and greeting cards.
Packaging used solely to support, protect or carry another product.
Still in scope
Paper and board under Chapter 48 — cartons, boxes, labels, notebooks, diaries, gift wrap, paper bags and paper tableware.
Empty packaging sold as a product in its own right.
Wood products — furniture, display fixtures, frames, garden products and kitchenware.
So a printed brochure is out. The carton it ships in, if you sell that carton as a product, is in. A greeting card is out. The gift bag next to it on the shelf is in.
That is why the first job is always product by product, code by code.
Which date applies to you?
Your date depends on your size, your sector and the product.
30 December 2026 — large and medium operators and traders, and micro and small operators already covered by the EU Timber Regulation.
30 June 2027 — other micro and small operators.
30 December 2027 — products newly added to the scope of the regulation.
Your role matters too. Under EUDR, the business that first places a product on the EU market — the operator — carries the core due diligence duty. The December 2025 changes focused responsibility there.
If you are a UK business selling to an EU customer, that customer is usually the operator. EUDR may not apply to your own UK sales. But your customer cannot complete their due diligence without information from you.
Your legal position may differ from your customer's. Your commercial position doesn't. They need your data either way.
And the stakes are real. For the most serious breaches, Member States must set maximum fines of at least 4% of a company's total annual EU turnover, alongside confiscation of goods and exclusion from public contracts.
Why FSC is not enough
FSC is valuable. It tells a buyer that a forest is responsibly managed and that the material has moved through a certified chain of custody.
EUDR asks different questions:
Where exactly was it grown? The geolocation of every plot of land where the wood was harvested — not just the country.
Was that land deforested after 31 December 2020? The regulation's cut-off date.
Was it produced legally? Under the laws of the country of harvest.
Has due diligence been done? And has a due diligence statement been submitted through the EU Information System?
The Commission's own guidance is clear: certification schemes can support a risk assessment. They do not replace an operator's due diligence.
We see this every week. One of the UK retail display manufacturers we work with already held FSC certification and B Corp status. They still needed an EUDR programme, because neither answers the geolocation and due diligence questions.
FSC is a strong foundation. Build on it. Don't rely on it.
Five steps to take this month
1. Map your products to commodity codes
List every product you sell into the EU, or to customers who do. Match each to its tariff code. Mark it in or out. This one exercise often removes half the worry — and focuses the rest.
2. Confirm your role, product by product
Are you the operator placing the product on the EU market? A trader? Or a UK supplier whose EU customer is the operator? Write it down. It decides what you must do and what you must provide.
3. Ask your suppliers for what you actually need
Don't send a 40-question form. For each in-scope product, ask for the due diligence statement reference numbers from upstream, or the geolocation of the plots of harvest, plus evidence of legality. Start with your top five paper, board and timber suppliers.
4. Log every answer against the order
Keep a simple record: product, order, supplier, evidence received, date checked, gaps outstanding. Chase the gaps. This record is what your customer — and an authority — will want to see.
5. Name one owner, and tell your customers
Not a committee. One person. Then send your key EU customers a short readiness note before they chase you. A clear plan is often enough to protect the account while the detail is completed.
How CSR Consultants helps
We specialise in packaging, print, display and coatings. EUDR is not a side topic for us. It is live work.
We are currently delivering EUDR programmes for a UK retail display manufacturer and a UK partyware wholesaler supplying the high street and Europe.
Here is what that looks like in practice:
Applicability review — your products mapped against the codes, with a clear in-scope and out-of-scope list.
Role and date confirmation — what applies to you, and what your customers need from you.
Supplier requests that get answered — short, specific templates for your mills and merchants.
A due diligence process your team can run — evidence log, risk checks and a routine for every new order.
Customer communication — a readiness note and evidence pack for your EU buyers.
We work on fixed fees, agreed upfront, in clear phases. And we do as much of the heavy lifting as possible, so your team doesn't have to.
Want our one-page EUDR Readiness Checklist? Get in touch, or book a 20-minute call. We'll tell you plainly what applies to your business and what doesn't.
FAQ
When does EUDR apply?
From 30 December 2026 for large and medium operators and traders, and for micro and small operators already covered by the EU Timber Regulation. Other micro and small operators have until 30 June 2027. Products newly added to scope apply from 30 December 2027.
Are greeting cards and printed products in scope?
No. Since the December 2025 amendment, printed products under Chapter 49 — including books, newspapers, brochures, printed advertising and greeting cards — are outside EUDR. Paper and board products under Chapter 48, such as gift wrap, gift bags, notebooks and paper tableware, remain in scope.
Is packaging in scope?
It depends how it is supplied. Packaging used solely to support, protect or carry another product is not in scope in its own right. Empty packaging sold as a product — cartons, boxes or bags sold to a customer — is in scope.
Does EUDR apply to UK businesses?
EUDR applies to products placed on, made available on, or exported from the EU market. It does not regulate sales within Great Britain. But UK suppliers to EU customers will be asked for the information their customers need to complete due diligence.
Is FSC certification enough for EUDR?
No. FSC can support a risk assessment, but EUDR requires geolocation of the plots of harvest, evidence that the land was not deforested after 31 December 2020, evidence of legal production and a due diligence statement. Certification does not replace due diligence.
What happens if a business does not comply?
Member States must set effective penalties. For the most serious breaches, maximum fines must be at least 4% of the company's total annual EU turnover, alongside confiscation of products and temporary exclusion from public procurement.
What is the EUDR cut-off date?
31 December 2020. Relevant commodities must not come from land deforested after that date, or, for wood, from forest degradation after that date.
This article is general guidance based on the regulation and Commission guidance as at 13 October 2026. It is not legal advice. Check your own products and role before acting.
Be Credible. Be Competitive. Be Responsible.
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