EUDR and Hardwood Pallets: What It Means for Blackberry Customers
- Joe H
- May 20
- 3 min read
Due to recent customer inquiries, we've taken a deep dive into the European Union Deforestation Regulation (EUDR) and how it relates to Blackberry Pallet's hardwood pallets. Here's what we found:
What Is EUDR?
The EUDR (EU Regulation 2023/1115) aims to prevent deforestation and forest degradation by placing requirements on certain products entering or leaving the EU market. These requirements include supply chain traceability, geolocation of harvest areas, and legal compliance in the country of origin for wood and several other commodities. These requirements are scheduled to take effect in December of this year.
What Products Are Covered?
The EUDR applies to products linked to deforestation, including those made from wood, soy, cocoa, palm oil, coffee, rubber, and cattle. It covers both raw materials and many finished goods that are placed on or exported from the EU market. The regulation’s Annex I outlines the specific product categories subject to compliance. Among these are:
Solid wood
Plywood and veneer
Wood furniture
Wooden pallets and packaging
However, there is a key distinction:
Annex I HS 4415 includes an exemption for packaging material “used exclusively as packing material to support, protect or carry another product placed on the market.”
This means that wooden pallets used solely to transport other products — such as pallets used by manufacturers, distributors, or exporters to move their goods — are not considered relevant products under the regulation
When Does EUDR Apply to Hardwood Pallets?
The regulation applies only when pallets themselves are the product being sold into the EU market. If a pallet is used as part of a packaging system—to move, support, or protect other goods—it is explicitly exempt from EUDR requirements.
This is confirmed in the European Commission’s April 2025 guidance document:
"HS code 4415 covers: ‘Packing cases, boxes, crates, drums and similar packings, of wood; cabledrums of wood; pallets, box pallets and other load boards, of wood; pallet collars of wood.’" It goes on to say, "[These items] used exclusively as packing material to support, protect or carry another product placed on the market are not covered by EUDR."
— Commission Guidance Document C(2025) 2485 final
What This Means for Blackberry Pallet Customers
Blackberry Pallet manufacturers new hardwood pallets that are:
Sold within the U.S. to domestic customers
Used exclusively to support and transport other products
Not placed on the EU market as standalone goods
As such, our pallets fall under the packaging exemption defined in Annex I HS 4415. We’ve reviewed the regulation and confirmed that EUDR compliance requirements do not apply to our products in this context.
For customers who are placing their own products on the EU market and using wood pallets as part of their export packaging, the responsibility for EUDR compliance lies with the importer or product owner for their products — not the pallet manufacturer and their pallets.
This assessment of EUDR's applicability to wooden pallets used as packaging material is based on the current reading of the EUDR regulation, and EU-provided clarification and guidance as of May 1, 2025. We will continue to monitor for further changes to the EUDR and guidance and provide updates accordingly.
Blackberry Pallet's Commitment
While the EUDR does not apply to our products due to their use as packaging, Blackberry Pallet remains committed to responsible practices across our supply chain. As a vertically integrated part of the Turman Group family of companies, we source our lumber internally—from operations backed by over five decades of certified, sustainable forestry and environmental stewardship.
We’re proud to build every pallet on a foundation of quality materials and responsible resource use—whether regulations require it or not.
For a reliable partner ready to support your
EUDR compliance or sustainability goals, Contact Us Today
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