Blackberry Pallet – EUDR Applicability Statement (Packaging Exemption)

This statement is provided to support Customer inquiries regarding EU Regulation 2023/1115 on deforestation-free products (EUDR), and to clarify its applicability to Blackberry Pallet LLC’s operations and products.

Per Blackberry Pallet’s (“Blackberry”) understanding of Regulation (EU) 2023/1115 on deforestation-free products, dated 26/12/2024, and in accordance with the following:

Article 2(2) states: ‘Relevant products’ means products listed in Annex I that contain, have been fed with, or have been made using relevant commodities.
Annex I CN 4415 includes: Packing cases, boxes, crates, drums and similar packings, of wood; cable-drums of wood; pallets, box pallets and other load boards, of wood; pallet collars of wood (not including packing material used exclusively as packing material to support, protect or carry another product placed on the market).

Blackberry’s hardwood pallets are sold within the United States to U.S.-based customers, in accordance with all applicable laws and regulations — including compliance with ISPM 15 for customers who may ship their goods to non-U.S. markets. Blackberry’s pallets are neither sold nor brokered for sale in foreign markets.

The Customer's purchase and use of pallets supplied by Blackberry falls under the exemption provided by CN 4415, which excludes “packing material used exclusively as packing material to support, protect or carry another product placed on the market.”

Blackberry pallets are used by the Customer solely for palletizing their goods — to support and protect items during storage, and to carry them during transportation to end recipients. As such, EUDR compliance requirements do not apply to Blackberry’s hardwood pallets under the CN 4415 packaging material exemption.

Sample Question 1: “The relevant products do not contribute to deforestation or forest degradation: Yes or No”

As these pallets are exempt from EUDR requirements when used exclusively as packaging (per Annex I CN 4415), the specific deforestation-free verification and certification under EUDR is Not Applicable (N/A) to the pallets themselves. The regulation does not mandate this check for packaging in this context.

Independently, Blackberry values responsible stewardship of natural resources and the prevention of deforestation and forest degradation. As part of our vertical integration within the Turman Group, the lumber used in Blackberry pallets is sourced internally, with a well-documented track record of sustainable forestry practices. We can therefore confirm: No, Blackberry pallets do not contribute to deforestation or forest degradation.

Sample Question 2: “The relevant products have been produced in accordance with the relevant legislation of the country of production: Yes or No”

While specific legality verification under EUDR is Not Applicable (N/A) due to the CN 4415 exemption, we confirm: Yes, the pallets are produced using materials sourced and manufactured in compliance with applicable legislation in the country of production (United States).

Sample Question 3: “The relevant products are covered by a due diligence statement: Yes or No”

As the pallets are exempt (per Annex I CN 4415) when used solely as packaging for the Customer’s palletized goods, a Due Diligence Statement specific to Blackberry pallets is Not Applicable (N/A). Under EUDR, the DDS obligation applies to the actual goods being placed on the EU market — not the transport packaging. Any applicable DDS would be submitted by the Customer for their products.

Reference:

Regulation (EU) 2023/1115 on deforestation-free products: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231461

Reviewed/Reassessed:

4/28/2025 – Remains valid after reviewing:

Commission Delegated Regulation (EU) 2025/XXXX amending Annex I of Regulation (EU) 2023/1115 (EUDR)
Commission Guidance Document C(2025) 2485 final, clarifying obligations and confirming packaging material exemptions.