EUDR: Your Questions About Individual Products & Goods
- Arne Mielken
- Mar 25
- 5 min read
Many are unsure if their products fall under EUDR, including mixed and internal-use items. Our blog series answers your product specific questions.
Many market participants are uncertain about whether their products fall under the scope of the EUDR. This includes not only finished goods but also "mixed products" and items used solely within a company. If you’ve been wondering whether your specific products are subject to the EUDR’s requirements, this blog will address those concerns. We’ll explore common queries and provide real-world examples to clarify the situation. Stay tuned for this essential post.
Questions we answer in this post:
Is recycled paper exempt from the EUDR due diligence requirements?
100% recycled material is exempt from the EUDR. What proof must I provide to demonstrate that the product is indeed made entirely of recycled material? What if suppliers misdeclare their products?
Do wood products purchased within the EU require supplier documents, or must the supplier issue and provide any documentation to us as customers?
Is it correct that for composite products containing multiple relevant raw materials or products (e.g., a wooden kitchen chair with cattle leather upholstery, CN code 9401), the market participant placing these products on the EU market only needs to conduct due diligence on the primary raw material and its (derived) products that are relevant under the EUDR? That is, in this example, the relevant raw material would be wood?
If a product relevant under the EUDR is purchased and processed into a non-EUDR-relevant product and then sold, is it still subject to due diligence requirements?
Are all wood-based products relevant? Does a wooden pencil fall under the regulation's requirements or not?
QUESTION: Is recycled paper exempt from the EUDR due diligence requirements?
Yes, as long as it is a 100% recycled product. Specifically, the regulation does not apply to goods made exclusively from materials whose lifecycle has ended and which would otherwise be disposed of as waste according to Article 3(1) of Directive 2008/98/EC (Annex I EUDR). Therefore, recycled materials are not subject to obligations under the regulation. However, if the product contains any (even minimal) amount of non-recycled material, it falls under the requirements of the regulation. In such cases, due diligence obligations must be met, and the non-recycled materials must be traceable to their origin through geolocation.
Want to read more?
Subscribe to customsmanager.info to keep reading this exclusive post.
