EUDR from December 30, 2026: why cardboard becomes your newest paperwork headache

There is an EU regulation you probably do not have on your radar, but it will hit your procurement from 30 December 2026. The EU Deforestation Regulation (Regulation 2023/1115), EUDR for short. Where PPWR is about circular packaging, EUDR is about one thing: making sure no product on the European market has contributed to deforestation or forest degradation after 31 December 2020.

Sounds logical. Sounds distant from your webshop. Until you read that cardboard, paper and wooden pallets fall under it as soon as you buy them as empty packaging to ship your orders in.

What falls under EUDR

EUDR covers seven commodities historically tied to deforestation: wood, soy, palm oil, coffee, cocoa, rubber and cattle. Plus most products derived from them. For packaging the nuance matters. Per the EUDR packaging guidance:

• Packaging solely used to support, protect or carry another product placed on the market is exempt, regardless of code.
• The identical cardboard box, when sold empty as a product in its own right (e.g. a pallet of empty boxes you buy to fill yourself), is in scope.
• Empty cardboard packaging imported into the EU for filling here is fully in scope.

For most webshops that means: the cardboard you buy to pack your orders in falls under EUDR requirements. Printed products (books, newspapers, magazines, brochures, maps) were removed from scope under Regulation 2025/2650, so those are not in your paper stream.

The rule was originally due end of 2024 and got delayed twice. Confirmed timeline per EUR-Lex: 30 December 2026 for medium and large companies, 30 June 2027 for micro and small. For "downstream" operators (webshops buying packaging already compliantly placed on the market), there is a simplification: no full due diligence of their own, but do record and keep the DDS reference from the supplier for five years.

So what do you have to do

The heavy lifting sits with the party that first places the wood-based product on the EU market — in practice your packaging supplier or their paper mill. They have to file a Due Diligence Statement (DDS) with plot-level geo-coordinates, chain transparency, proof there has been no deforestation after 31 December 2020, and a risk assessment, uploaded to the EU TRACES system. Background and required fields in the DDS explainer by Coolset.

For you as a webshop buyer, it mostly means: request DDS references and supplier information from your packaging supplier, record and keep them for five years. Doable — provided your supplier has their chain in order. If you buy from multiple suppliers or via intermediaries you still get an admin flow. Fines for non-compliance are steep: up to 4% of annual EU turnover (Article 25 of the regulation). Six weeks before the deadline we publish a concrete checklist and supplier email template in our EUDR final call.

What happens if you just stick with cardboard

Three things, in this order.

One, higher purchase price. Your packaging supplier has to map the full supply chain. That costs money and it gets passed on. Expect price pressure in the first years after the start date.

Two, more complex sourcing. For every new supplier you now want to see an EUDR track record before signing. That lengthens your procurement time and rules out smaller suppliers with insufficient compliance capacity.

Three, chain risk. If your supplier's documentation is off, their supply may stall — and with it your box inventory. Upstream compliance problems become downstream delivery problems.

How stone paper sits outside

Stone paper is made of calcium carbonate (ground quarry waste) plus a small amount of recycled HDPE as binder. No wood, no fibre, no tree. That puts stone paper outside EUDR scope. No DDS in the chain, no TRACES, no plot-level chain analysis.

Practically: no EUDR admin around your primary shipping packaging. You buy your Stonepackers and that is it. No annual re-check of plot coordinates. Your compliance file is one line shorter.

On environmental performance stone paper also wins — how that plays out in an LCA versus FSC cardboard and recycled cardboard we work out in our LCA comparison.

The elephant in the room

Nobody is saying all cardboard is bad. FSC-certified cardboard from sustainably managed European forests is fine material, and EUDR is precisely designed to reward that kind of management. But for webshops running hundreds of shipments a day, the admin chain around EUDR compliance is a real cost — even where it sits mainly with your supplier, because you pay it back in the purchase price.

The choice is not cardboard-or-not. The choice is: how much of my packaging mix do I want out of EUDR scope, and how much administrative overhead do I accept for the rest. In our pooling-partner comparison we place Stonepacker next to PP alternatives (RePack, Paardekooper, Circular Shipping) which are equally outside EUDR scope.

What we suggest

Start with your primary shipping packaging. Box or envelope, that is the biggest volume in your mix and where the largest compliance load sits. Make it tree-free or pool-based. Keep FSC cardboard for secondary packaging, labels and internal use.

For the TCO calculation, the rule of thumb is: above ~300 shipments per week, reusable flips positive quickly. Below that, the conversation is different.

Request a Stonepacker sample and you have runway to test the flow before the EUDR deadline actually lands. Samples ship free within three business days, and Roel replies personally.

EUDR is not a problem that goes away with a spreadsheet. It is a new baseline. The question is whether next year you make it a bottleneck or a selling point.