First things first, so you only have to read the rest if you’re interested: As a customer of an ARCA-certified business, the EU Deforestation Regulation does not require you to take any action. No need to request proof, no need to record reference numbers, and no need to keep documentation on file. The following sections explain why this is the case.
What it’s about and when it starts
The EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) requires proof for certain raw materials and products that they were not produced on land deforested after December 31, 2020. This includes wood and wood products, and thus also pallets, crates, boxes, and cable drums, provided their customs tariff code is listed in Annex I of the Regulation.
The effective date has been postponed twice. According to Amending Regulation (EU) 2025/2650, the following applies: large and medium-sized enterprises as of December 30, 2026, and micro and small enterprises as of June 30, 2027. The extended deadline applies only to companies that were already established as micro or small enterprises as of December 31, 2024.
The same amending regulation has significantly clarified the obligations along the supply chain. This is precisely where it is determined who must provide what documentation for wood packaging.
Where ARCA Fits in the Supply Chain
The EUDR does not base obligations on whether a company is a manufacturer or a distributor. It bases them on the position in the supply chain—specifically, only on the first two positions.
ARCA companies do not import wood. They source sawn timber and panel materials from sawmills and panel manufacturers. An ARCA company is therefore neither the first operator to place the product on the market nor its first downstream operator, but rather one step further down the chain.
EUDR obligations end before the ARCA company
no EUDR obligation
no EUDR obligation
No action required here
As a customer, you are one step further down the chain. At this point in the chain, the regulation no longer imposes any obligations.
First-Touch and the Plus-One Rule
Since the amendment of December 2025, only the first operator to place a product on the market is required to submit a due diligence statement: the company that first makes a relevant raw material or product available on the Union market or exports it from the Union. The BLE refers to this as the first-touch principle.
Downstream operators do not submit their own due diligence statement. Instead, they obtain the reference number of the first-placer-on-the-market’s statement and keep it on file. This obligation applies only to the first downstream market participant—the so-called “plus-one” rule. The requirement to pass the information along the entire supply chain, as mandated by the original version, no longer applies.
Downstream market participants and distributors, incidentally, have the same obligations. In addition to their position in the supply chain, a company’s size is relevant for its classification: micro, small, medium-sized enterprise, or non-SME, measured by total assets, net revenue, and number of employees in accordance with Directive 2013/34/EU.
For ARCA businesses, this means specifically: They do not receive any EUDR information from their upstream suppliers because the regulation no longer requires it at this stage. Consequently, they also do not pass any such information on to their customers. There is nothing to request here and nothing to file.
Packaging with Goods or Packaging as Goods
The second distinction is independent of the first and is often the more important one for exporters. Packaging materials and containers that serve exclusively to support, protect, or transport another product, and that are supplied or exported together with that product, are exempt from the EUDR. For packaging that is clearly suitable for repeated use, the exemption applies from the point at which it is intended for that purpose and for subsequent use.
The exemption therefore does not depend on the product, but on the transaction. The same pallet may be exempt in one shipment but not in the next.
| Transaction | EUDR-relevant? | Why |
|---|---|---|
| Wooden crate, exported together with the machine packed inside | No | Serves exclusively to protect and transport the machine and is presented with it |
| Pallet, exported loaded with goods | No, depending on the specific case | The specific goods and their customs tariff classification are decisive |
| New pallet, sold or exported empty as a standalone product | Yes | Subsequent use as a transport aid does not justify the exception |
| Used pallet, reused as a transport aid | No, as of this use | Reusable packaging is covered as of its use for this purpose |
| Empty wooden crate, exported as a standalone product | Yes | No accompanying product, so no packaging process |
The same logic applies to cable drums: they are exported together with the wound cable, but not when empty as a separate product.
This distinction determines which code is used in a customs declaration. It does not change the position of ARCA companies in the supply chain—and therefore does not change yours either.
