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  • The EU Deforestation Regulation (EUDR)

    Driving deforestation-free packaging

The European Union Deforestation Regulation (EUDR) is a new and significant law designed to ensure that products in the EU market do not contribute to global deforestation. As of December 30, 2025, all companies trading in specific materials and their derived products will need to prove they are deforestation-free. Now is the time to prepare, and we are ready to work with you.

Your partner in sustainable
labeling and packaging


Navigating the changes required by the EUDR will be a new challenge for the entire supply chain. As your labeling partner, we're here to provide clarity, simplify the complexities, and make sure the labeling materials you need meet all EUDR requirements.

Which products fall under the scope of EUDR?
 

The EUDR targets seven key commodities and a wide range of products derived from them:

  • Cattle

  • Cocoa

  • Coffee

  • Palm oil

  • Rubber

  • Soy

  • Wood

The end products the regulation applies to can be found (based on their Harmonized System code) in Annex I of the legislation.

For Avery Dennison, the regulation primarily impacts our paper-based products, which are derived from wood. Most of these fall under HS Code 48. They include:

Paper labels on paper liners

Paper labels on film liners

Rapid Roll products made with paper

 

 

Note that film-based labels are not within the scope of the regulation, even if they include a paper liner. Also, once a label is placed onto another product, it is no longer within scope of the EUDR.

EUDR Card Component

What is changing as a result of EUDR?

To be sold on the European market, EUDR-relevant products must now meet three clear conditions:


  • Deforestation-free: Materials must not have been sourced from land deforested after December 31, 2020.
  • Legally produced: Materials must be produced legally in their country of origin.
  • Documented: Materials must be backed by an official Due Diligence Statement (DDS) proving they meet the first two conditions.

If a company can’t provide the required information - within an official Due Diligence Statement - they must stop selling the product in or exporting it out of Europe.

EUDR Image

Steps you can take to comply with EUDR

To meet the new EUDR requirements, affected companies have to make
changes to their business processes, data collection, and stakeholder
communication. Below are some steps we’ve taken that you can also
consider when setting up your own compliance.

Understand your role

Companies first need to understand their role in the supply chain to define their obligations.
 

  • A First Operator (like Avery Dennison) is responsible for conducting the initial due diligence.
 
  • A Downstream non-SME (most of our customers) needs to confirm compliance with upstream suppliers. New systems, including IT solutions, are often helpful to manage the large volume of data required for EUDR compliance.

 

Adopt new processes and systems

To manage EUDR’s requirements, companies can look to adopt new processes and systems:
 

  • Due diligence systems: Companies are required to set up, maintain, and annually review an official due diligence system which includes the due diligence steps listed below. 
 
  • IT infrastructure: New IT solutions are useful in handling the large volume of highly specific data required to comply with EUDR.

Collect key data and conduct due diligence

Before a product can be placed on the EU market, companies have to perform due diligence. This involves three main steps:

  1. Information collection: Companies must gather specific information and documents to demonstrate compliance with EUDR. For first operators, this means collecting information from their supply chains, most importantly the geolocation of every plot of land where materials used in their products were produced (essential to confirm that it hasn’t been deforested after the cut-off date of December 31, 2020). For downstream companies, this means receiving reference and verification numbers from suppliers.
     

  2. Risk assessment: Using the collected information, first operators must conduct a risk assessment to evaluate the possibility of non-compliance in their supply chain. For downstream companies, this process is simplified; they can rely on due diligence done by companies upstream, but are still required to make sure their products are EUDR compliant.
     

  3. Risk reduction: If the risk assessment conducted by a first operator reveals a significant risk of non-compliance, the company should take action to reduce that risk. If the risk can’t be reduced to a negligible level, the product can’t be sold on the EU market or exported.

Communicate clearly up and down the supply chain

EUDR makes it impossible for companies to work alone. Closer and more transparent communication is needed up and down the supply chain:
 

  • Share information with suppliers: Companies should work closely with their suppliers to ensure they provide the data needed for due diligence. If a supplier fails to provide that data, it directly impacts the downstream company's ability to do business.
     
  • Share information with customers: Companies must now also share compliance information downstream, for example verification numbers needed for the DDS.

What you can expect from
Avery Dennison


We are proactively preparing to ensure full compliance with EUDR and support our customers through this transition. We are committed to meeting the regulatory requirements and equipping our downstream partners with all the data they need to meet their own obligations.

Comprehensive preparation

To achieve this, we have taken several steps to prepare, including collaborating closely with our suppliers to ensure everyone has the compliance information they need; developing a dedicated IT system to process Due Diligence Statements and manage the associated data; and developing robust internal processes for everything related to EUDR.

Compliance during the transition period

For a time after the deadline, you may receive products from us that fall under the scope of EUDR but which do not have a DDS. This will occur if the products were made from materials that were placed on the EU market before December 30, 2025. We are working on a solution to ensure that these products can be used without any compliance issues.

Clear and consistent information-sharing

For every shipment containing goods within the scope of EUDR, you will receive the necessary Reference and Verification numbers for the associated DDS from us. These will be delivered as a PDF attached to the Advance Shipping Notice and sent to the email of the relevant receiving parties, enabling you to seamlessly integrate them into your own compliance systems.

Reliable partnership

We’re committed to being a reliable partner and helping our customers better understand their EUDR obligations. We’re actively working to make sure we are compliant and can provide you with the data and support you need downstream. As we move closer to the December 30th deadline, we’ll share additional materials and guidance to support you in your preparations.

Have questions about EUDR?

Our detailed FAQ page is your go-to resource for specific, reliable information. Find the right answers for your business and ensure a smooth transition.

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EUDR FAQs

Stay updated



Keeping up with legislative changes and figuring out what you need to do can be a challenge, but we’re here to help. We’ll keep you updated as the regulation takes shape and work with you to develop packaging that supports the goals of the EUDR as well as your business.

Sustainability news

Sign up for sustainability news:

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Get in touch:

Got questions? Feel free to contact your local Avery Dennison representative or reach us through our contact page.

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UEDR

Get to know other regulations:

The EUDR is just one of many current and upcoming regulations driving sustainability in packaging within the EU.

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Additional resources

Article

The Packaging and Packaging Waste Regulation (PPWR)

The Packaging and Packaging Waste Regulation, which supports the EU’s goal to become climate neutral by 2050, became law in 2025. We discuss how it impacts your labeling choices.

Learn more
PPWR

Guide

Sustainable labeling solutions guide

We’ve pioneered a wide range of solutions that improve recyclability, enable packaging reuse, and reduce consumption of natural resources. View them all here.

Download the guide
Sustainable labeling solutions guide