EUDR for wooden pallets, crates and timber packaging: due diligence statements, reference numbers, deadlines

• Deadline 30 December 2026 – small timber businesses included. The postponement to June 2027 for micro and small companies expressly does not apply to timber products already covered by the old EU Timber Regulation (EUTR) – so not to sawn timber and pallets either.
• Only whoever first places the wood on the market files a due diligence statement. Anyone making pallets or crates from it is a "downstream operator" and records suppliers and customers.
• New pallets and crates sold as products are covered. Accompanying packaging, reusable load carriers in use and used pallets are excluded.
• Wood from Germany and the EU counts as "low risk". That simplifies the risk assessment, but the operator still needs the geolocation of the harvest plots.

Wood is one of seven relevant commodities under the Deforestation Regulation. Annex I lists the covered products by customs code – from roundwood (4403) and sawn timber (4407) to wooden packaging under 4415: packing cases, crates, drums, cable drums, flat pallets, box pallets and pallet collars.

Since Delegated Regulation (EU) 2026/2102 (in force since 18 September 2026), entry 4415 expressly excludes:

• used and second-hand products,
• single-use packaging used exclusively to support, protect or carry another product and presented with it,
• packaging clearly suitable for reuse from its first use for that purpose.

Also excluded is waste wood whose life cycle has ended and which would otherwise be waste. By-products from ongoing production, such as sawdust, are not covered by this exemption.

Since the reform by Regulation (EU) 2025/2650, the principle is effectively "first placer only": the due diligence statement is filed by the operator who first places the wood on the EU market or exports it. All later stages only pass on information. The former special rule for SMEs has been deleted – it is replaced by the new role of downstream operator, regardless of company size.

For operators – for example when importing sawn timber or finished pallets – due diligence follows six steps:

• 1. Collect information (Art. 9): description with trade name, common and scientific name of the tree species, quantity, country of production, geolocation of all harvest plots with harvest period, suppliers and customers, and evidence of legality and deforestation-free production.
• 2. Assess the risk (Art. 10): including country risk, supply-chain complexity and the risk of mixing with wood of unknown origin. Document it and review it at least annually.
• 3. Mitigate the risk (Art. 11): additional information, independent audits; non-SMEs also need a compliance officer.
• 4. File the due diligence statement: in the EU information system (TRACES) with the Annex II data – including customs code, quantity, country of production and geolocation.
• 5. Pass on the reference number: the system issues a reference number; it goes to the customer and, on import, must be available to customs before release for free circulation.
• 6. Keep records: statements and documents for 5 years.

Implementing Regulation (EU) 2025/1093 classifies Germany and all other EU member states as low-risk countries. Only Belarus, North Korea, Myanmar and Russia are currently classified as "high risk".

For wood from low-risk countries, simplified due diligence (Art. 13) applies: risk assessment and mitigation are not required – but only if the risk of mixing with wood of other origin is negligible and this can be demonstrated on request. The information requirement, geolocation and the due diligence statement remain. If there are indications of risk, full due diligence applies again.

Imports from third countries: anyone importing sawn timber or pallets into the EU is an operator with full due diligence obligations – including a full risk assessment, depending on the country of origin.

In practice the EUDR rarely fails on the form – it fails on traceability within your own operation. Three points are decisive:

• Goods receipt: record supplier, reference number or supplier details and quantity for each delivery – directly on the batch.
• Warehouse and production: if lots are mixed, the plots of all lots involved must be declared for the result. The Commission does not accept mass balance with wood of unknown origin.
• Dispatch and invoice: the information goes to the customer – so your customer can meet their obligations too.

• Repairs: for repaired pallets, only the newly added wood is covered by the EUDR – the repairer needs reference numbers for the new boards and blocks (Commission FAQ, EPAL).
• Pooled and reusable pallets: excluded from their first use as packaging; covered when first sold as new products.
• Exports: whoever exports products made from wood already covered by a statement is a downstream operator; no reference number is then needed at customs. Whoever exports wood for the first time needs a due diligence statement.
• Old stock: wood produced before 29 June 2023 and placed on the market from 30 December 2026 remains under the old EUTR until the end of 2029; from 31 December 2029 the EUDR rules apply to it as well.

Authorities check at least 1 % of operators each year for products from low-risk countries, 3 % for standard risk and 9 % for high risk. Penalties are severe: member states must provide for fines with a ceiling of at least 4 % of EU-wide annual turnover, plus confiscation of goods and revenues, exclusion from public procurement for up to 12 months and bans on placing products on the market.

In Germany, the implementing act was still a bill before the Bundestag at the date of this guide. It provides for state authorities for wood produced in Germany and the Federal Office for Agriculture and Food (BLE) for all other cases, along with fines and criminal provisions.

At its core the EUDR is a data problem: origin, batch, quantity and the path of the goods must match without gaps – from goods receipt to invoice. That is exactly where duveka EUDR comes in, inside Microsoft Dynamics 365 Business Central. See it live in the free EUDR webinar; the packaging side is covered in our guide PPWR for wooden pallets and export packaging.