07. 30. 2026
Under Regulation (EU) 2023/1115 (EUDR), operators placing molded fibre packaging on the EU market from 30 December 2026 must submit a Due Diligence Statement to national authorities before each shipment. This statement confirms that the packaging supplier conducted due diligence proving the wood pulp was sourced legally, from traceable origins, and carries negligible deforestation risk. Buyers cannot place products on the EU market without a valid statement reference number linked to their customs declaration.
The EUDR Due Diligence Statement is a formal declaration submitted through the EU Information System confirming that an operator placing fibre-based packaging on the EU market has completed the three-step due diligence process required under Regulation (EU) 2023/1115. The regulation targets deforestation-linked commodities, including wood and wood products such as pulp and paper-based packaging. From 30 December 2026, all molded fibre packaging manufactured from virgin or recycled wood pulp falls within scope.
The statement functions as a compliance checkpoint. Before releasing goods from customs or placing them on the market, the operator – typically the brand importing packaging or the packaging supplier acting as operator – must submit the statement electronically. National competent authorities assign a unique reference number, which the operator includes in customs declarations. Without this reference, customs authorities refuse clearance.
The statement must contain specific data points: supplier identification (name, address, contact details), product description and volume, harvest location geolocation coordinates (latitude and longitude with six decimal precision for plots exceeding four hectares, polygon coordinates for smaller plots), the date or time range when the wood was harvested, and the risk classification outcome (negligible, low, standard, or high risk). For molded fibre packaging, the geolocation refers to the forest stands where the pulp fibre originated, not the packaging production facility.
Operators demonstrate negligible deforestation risk by proving the wood was harvested legally under applicable national and international law, was not sourced from recently deforested land (after 31 December 2020), and did not contribute to forest degradation or violate human rights including indigenous peoples' rights. The regulation distinguishes between low-risk sourcing regions (primarily EU member states classified as low-risk by the European Commission) and standard or high-risk regions, which require enhanced due diligence including third-party verification, satellite monitoring, and field audits.
For packaging buyers, the practical implication is straightforward: your supplier must provide either a complete Due Diligence Statement reference number for your shipment, or demonstrate they have completed due diligence and will submit the statement on your behalf. If your procurement contract designates you as the operator (for example, if you import directly), you hold legal responsibility for submitting the statement and conducting the underlying due diligence, which in turn requires your supplier to provide traceability data, geolocation coordinates, and legality documentation.
| Sourcing scenario | Geolocation precision requirement | Risk classification typical outcome | Third-party verification requirement |
|---|---|---|---|
| EU low-risk region pulp (FSC-certified) | Coordinates with 6 decimal precision per forest stand | Negligible risk | Not required (FSC chain-of-custody accepted) |
| EU low-risk region pulp (non-certified) | Coordinates with 6 decimal precision per forest stand | Low to negligible risk | Recommended for assurance, not mandatory |
| Third-country standard-risk pulp | Polygon coordinates for plots under 4 hectares, 6 decimal for larger | Standard risk | Mandatory – satellite monitoring, field audits, legality verification |
| Recycled pulp (100% post-consumer) | Exempted from geolocation if verifiable recycled content certification | Negligible risk (if certified recycled) | Recycled content certification required (e.g. RCS, GRS) |
Procurement teams sourcing molded fibre packaging from 30 December 2026 must verify supplier EUDR compliance before signing contracts or issuing purchase orders. Request evidence of the supplier's due diligence system: documented procedures for obtaining geolocation data from pulp mills, risk assessment methodology, and system integration with the EU Information System for statement submission. Suppliers unable to provide this documentation expose buyers to customs delays, shipment rejection, and regulatory penalties.
For buyers sourcing from suppliers outside the EU, clarify which party holds operator responsibility. If the contract designates the buyer as importer of record, the buyer becomes the operator and must submit the Due Diligence Statement using supplier-provided data. If the supplier ships on a DDP (Delivered Duty Paid) basis and handles customs clearance, the supplier acts as operator and submits the statement. Contracts must explicitly assign this responsibility and require the non-operating party to provide all necessary traceability data.
Buyers should prioritise suppliers sourcing pulp from EU low-risk regions. The European Commission publishes a country classification list under Article 29 of the regulation; most EU member states hold low-risk status, meaning simplified due diligence applies and third-party audits are not mandatory. Suppliers sourcing from non-EU regions classified as standard or high risk face significantly higher compliance costs (satellite monitoring, field audits, enhanced legality verification), which typically translate into higher packaging unit costs or extended lead times for documentation preparation.
Financial exposure is substantial. Non-compliance penalties under Article 23 reach up to 4% of the operator's total annual EU turnover, with customs authorities empowered to refuse clearance and seize non-compliant goods. For brands placing non-compliant packaging on the market, competent authorities may also prohibit market access for future shipments until compliance systems are demonstrated. Buyers must treat EUDR compliance as a contractual requirement with equivalent weight to quality specifications and delivery terms.
TRIDAS provides EUDR-compliant Due Diligence Statements per shipment under Regulation (EU) 2023/1115, with pulp sourced primarily from EU low-risk regions, ensuring negligible deforestation risk classification and simplified compliance for buyers. As an FSC-certified manufacturer, TRIDAS maintains chain-of-custody traceability linking finished packaging to forest stand geolocation coordinates provided by pulp suppliers, eliminating buyer exposure to third-party verification costs typical of non-EU sourcing. TRIDAS operates a single production facility in the Czech Republic, a low-risk EU region, and handles Due Diligence Statement submission for shipments where TRIDAS acts as operator, providing buyers with statement reference numbers for customs declarations.
