EUDR postponed to December 2025: what it means for wooden pallets, crates and strapped exports

Until a few days before Christmas 2024, the EU Deforestation Regulation (EUDR) was due to apply its main obligations on 30 December 2024. It will not. Regulation (EU) 2024/3234, dated 19 December 2024 and published in the Official Journal on 23 December 2024, gives operators and traders an additional year.

For businesses that buy or use wooden pallets and crates, and the strap and closures that go with them, the delay is a chance to settle a practical question: when is wood packaging inside the regulation, and when is it outside?

What the December 2024 amendment changed

Comparing the text of Regulation (EU) 2024/3234 with the original Regulation (EU) 2023/1115 gives this picture:

Item	Before the amendment	After the amendment
Main obligations (Articles 3 to 13, 16 to 24, 26, 31 and 32)	From 30 December 2024	From 30 December 2025
Operators established as micro or small undertakings by 31 December 2020 (except for products covered by the EU Timber Regulation annex)	From 30 June 2025	From 30 June 2026
Commission list of low-risk and high-risk countries	No later than 30 December 2024	No later than 30 June 2025
Repeal of the EU Timber Regulation (No 995/2010)	With effect from 30 December 2024	With effect from 30 December 2025

The recitals of the amending regulation note that most provisions of the EUDR had been due to apply from 30 December 2024. The amendment entered into force on the third day after publication. Parliament adopted its position on 17 December 2024 and the Council its decision on 18 December 2024, as the regulation’s footnotes record.

The substance of the EUDR did not change. Products in scope still need to be deforestation-free, produced in accordance with the relevant legislation of the country of production, and covered by a due diligence statement.

When wood packaging is in scope

Annex I of Regulation (EU) 2023/1115 lists the relevant products derived from wood. One entry is HS heading 4415: packing cases, boxes, crates, drums and similar packings of wood, cable drums, pallets, box pallets and other load boards, and pallet collars. The entry carries an important qualification: it does not include packing material used exclusively as packing material to support, protect or carry another product placed on the market.

In practice, that gives two situations:

• The pallet or crate is the product. A pallet manufacturer or importer placing new pallets on the EU market, or a distributor selling crates, is dealing with a relevant product.
• The pallet or crate is carrying something else. A manufacturer shipping machinery on a pallet, or stone in a strapped crate, is using wood as packing material for another product. That packing material falls within the exclusion in the Annex I entry.

The same physical pallet can therefore be in scope when you buy it and outside scope when it leaves your site carrying your goods. Who carries the obligations for purchased pallets and crates depends on who places them on the EU market. If you import new pallets or crates yourself, you may be the operator for them.

Paper-based packaging and strap

Annex I also includes pulp and paper of chapters 47 and 48 of the Combined Nomenclature, except bamboo-based and recovered products. Paperboard edge protectors and slip sheets bought as products may therefore be relevant products in their own right, depending on their classification. Ask your supplier how they classify the items you buy.

Strap is a different matter. The EUDR’s relevant commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood. PET strap, polyester woven strap, steel strap, wire buckles, sheet metal clips and steel seals are not made from these commodities, so the strapping itself is not what the regulation targets. The practical effect for a strapping buyer comes through the wooden and paper items used alongside it.

Using the extra year

The delay does not remove the work, it spreads it out. For packaging buyers and exporters, a sensible plan for 2025 looks like this:

• List your wood and paper packaging items by type and supplier, separating items bought as products from packaging that only travels with your goods.
• Ask suppliers about their EUDR approach for pallets, crates, edge protectors and slip sheets placed on the EU market.
• Keep ISPM 15 separate. Phytosanitary treatment and marking of wood packaging for export is a different requirement from EUDR due diligence; meeting one does not answer the other.
• Check your status. Whether you are an operator, a trader or neither depends on what you place on the market. Take advice if the answer is unclear.
• Keep packaging specifications current. When a crate design or supplier changes, update the record that shows which items are packaging and which are products.

Teams planning crate projects can combine this with the handover approach in our Southern Europe crate project guide.

Strapping still has to do its job

Whatever the regulatory position of the timber, the strap and closures on a crate or pallet still decide whether it arrives intact. A crate closed with woven strap and galvanized wire buckles, or a bundle on steel strap with steel strapping seals, should be specified as a system. Send your crate or pallet details through the enquiry page to discuss components for your application.