EUDR – Requirements for Deforestation-Free Supply Chains (EU Regulation 2023/1115)

Sustainability and responsible timber sourcing have been integral parts of our corporate philosophy for many years. TREYER PALETTEN is 100% PEFC-certified and holds, among other certifications, ISO 9001 and ISO 14001. We are also audited under SMETA-4 and assessed by EcoVadis.

With regard to EU Regulation 2023/1115 on deforestation-free supply chains (EUDR), which is scheduled to apply from 30 December 2026, we would like to provide an overview of the current situation.

The EUDR concerns the origin of the timber used and its traceability throughout the supply chain. In preparing for its implementation, we are guided by the applicable legal requirements, as well as the latest guidelines and FAQs published by the European Commission. Fortunately, significant simplifications have been adopted compared with the initial drafts of the EUDR.

The following aspects are particularly relevant:

1. Procurement of Sawn Timber

We source the sawn timber required for pallet production from timber suppliers and sawmills. As part of our EUDR preparations, we take into account the respective responsibilities of the parties involved in the supply chain and whether the timber purchased has already been subject to EUDR due diligence at an earlier stage of the supply chain. This is generally the case when boards or blocks are purchased from suppliers established within the European Union.

2. Manufacture of Wooden Pallets

According to the European Commission's current guidance, manufacturers of wooden pallets that process sawn timber already verified as compliant with the EUDR are generally classified as downstream operators.

In these cases, a new Due Diligence Statement (DDS) is generally not required for the pallets manufactured from this timber. Responsibility for the initial due diligence assessment rests with the relevant upstream operator.

3. Documentation and Traceability

We take into account the legal requirements for recording and retaining relevant information about our suppliers and commercial customers. This includes, in particular, the identification of business partners and, where applicable, the available reference numbers of upstream Due Diligence Statements.

The statutory retention period is at least five years.

4. Wooden Pallets Used as Transport Packaging

A further special consideration concerns the use of wooden pallets as transport packaging, i.e. pallets used to transport goods or loaded with goods.

According to the current guidance, wooden packaging used exclusively to protect, support or carry other goods and supplied together with those goods is generally excluded from the scope of the EUDR.

This means that shipping goods on wooden pallets does not, in itself, give rise to any additional specific EUDR obligations relating to this transport packaging.

Our Commitment

Our objective is to ensure reliable compliance with the applicable legal requirements while continuing to provide our customers with a secure, transparent and sustainable supply of wooden pallets.

Both we and our customers benefit from our many years of experience in timber sourcing, our established long-term partnerships with suppliers, our existing certification and quality management systems, and our active involvement in national and international industry associations.

We continue to monitor developments and further clarifications concerning the EUDR closely and will adapt our internal processes as necessary.