EUDR Deforestation Regulation for Industrial Suppliers: Due Diligence Statements, Wood Packaging and Rubber
How does the EU Deforestation Regulation (EUDR 2023/1115) affect industrial machinery manufacturers and suppliers? Regulation (EU) 2023/1115 prohibits placing or exporting relevant commodities and products on the EU market unless they are deforestation-free (produced on land not deforested after 31 December 2020), legally produced under local laws, and covered by a registered Due Diligence Statement (DDS). While complete metal machines are not commodities in scope, industrial manufacturers are directly captured through: (1) natural rubber components (belts, seals, tires, hoses under CN code 4001) and (2) wooden pallets, crates, and packaging materials (under CN code 4415). Machinery builders importing or distributing these items must collect GPS coordinates of the land of harvest and submit DDS reference numbers into the EU TRACES information system.
Regulation (EU) 2023/1115 guide for machinery and equipment builders: natural rubber belts, wood packaging, GPS parcel traceability, and TRACES compliance.
Technical Specifications & Regulatory Comparison Matrix
| Industrial Item / Material | EU Combined Nomenclature (CN) Code | In Scope of EUDR? | Required Compliance Action |
|---|---|---|---|
| Natural Rubber Conveyor Belts & O-Rings | CN 4001 | YES (Core Commodity) | Full traceability with GPS polygon coordinates & DDS submission |
| Synthetic Rubber (EPDM, Viton, NBR) | CN 4002 | NO (Exempt) | Proof of synthetic petroleum origin; exemption statement |
| Wooden Pallets & Heavy Crates (Purchased for shipping) | CN 4415 | YES (Wood Commodity) | DDS reference from pallet supplier or self-submission in TRACES |
| Wooden Packaging Used Solely to Support Delivered Goods | CN 4415 (Used as packaging) | CONDITIONAL | Exempt if not placed on market as independent commercial commodity |
| Cardboard & Paper User Manuals / Boxes | CN 4819 | YES (Paper Products) | Must verify virgin wood pulp traceability back to harvest plot |
1. The 3 Pillars of EUDR Due Diligence
Industrial suppliers must implement a formal 3-step due diligence system: (1) Information Collection: gathering exact geolocation coordinates (polygons for plots >4 hectares) of all production plots, dates of production, and supplier identity; (2) Risk Assessment: evaluating country risk benchmarks, forest degradation risks, and armed conflict indicators; (3) Risk Mitigation: independent auditing, satellite monitoring verification, and supplier engagement.