FAQ - EUDR | Avery Dennison

Regulation on Deforestation-free Products (EUDR)

Frequently Asked Questions

Understanding EUDR

Q: What is the EUDR?

A: The European Union Deforestation Regulation (EUDR) is a new law designed to ensure that a range of products, including those made from wood and rubber, are not contributing to deforestation or forest degradation. The goal is to promote the consumption of "deforestation-free" products and reduce the EU's impact on global deforestation.

Q: Does the EUDR apply to my business?

A: If your business places paper-based label materials or other relevant products on the EU market, it will be affected. The regulation generally applies to operators and traders who place, make available or export these products to or from the EU market. This includes label converters and brands that use these materials.

Q: What are the key requirements of the EUDR?

A: The EUDR requires that all relevant products placed on the EU market comply with three core conditions:

Deforestation-free: The products must be produced on land that was not subject to deforestation or forest degradation after Dec. 31, 2020.
Legally produced: The products must comply with all relevant laws of the country of production, including land use rights, labor rights and environmental protection.
Covered by a declaration: Before a product can be placed on the EU market, the operator who first places it on the market must submit a Due Diligence Statement (DDS). Under the simplifications, micro and small primary operators established in countries or parts thereof classified as low risk may instead make a one‑time simplified declaration, which replaces repeated DDS filings.

Q: What is a Due Diligence Statement (DDS)?

A: Think of the DDS as a passport for your product. It's a formal declaration that you have conducted all the necessary checks and verifications to ensure your product is deforestation-free and legally produced. It must contain specific information, including around the product's origin (e.g., geolocations), its Harmonized System (HS) code as well as additional information about the product and the company submitting the statement. This information is submitted to the online EU portal, TRACES, before the products can enter the market.

Q: How is Avery Dennison preparing for the EUDR?

A: Avery Dennison is committed to ensuring a smooth transition for our customers. Here’s what we are doing:

We’re actively mapping our supply chain for paper-based materials to gather all required information.
We’re working with our non-EU suppliers to collect geolocation data for all relevant materials.
When necessary, we will provide you with the reference numbers.

Navigating EUDR

Q: Are all paper-containing goods I receive from Avery Dennison covered by the EUDR?

A: Not all products are in scope. For Avery Dennison, paper is the primary material covered by the EUDR. However, the regulation applies only to specific products identified by their Harmonized System (HS) code. A product with a paper component, like a paper label, is in scope, but a film label is not, even if it has a paper liner. We’re creating an internal product list to clearly identify which products are covered, so you will have the necessary documentation for in-scope products you buy from us.

Q: What is Avery Dennison's role under the EUDR?

A: Avery Dennison can have one of two roles:

As a “first operator”: We’re the first company to place a product on the EU market. In this role, we handle all the due diligence steps — data collection, risk assessment and legal checks — to create and submit the Due Diligence Statement (DDS).
As a “downstream operator”: This means we’re a company that receives products for which the due diligence has already been performed. In this case, we only obtain the DDS reference number from our supplier and keep it on file if that supplier is a first operator.

Q: When will Avery Dennison customers be receiving EUDR numbers from Avery Dennison?

A: You will only need to receive and store EUDR numbers when Avery Dennsion acts as the first operator for those products. This means that for a majority of products, you will not be receiving EUDR numbers from us.

Q: What are the new EUDR deadlines for my business?

A: Your compliance deadline depends on your company's size, based on the EU's Accounting Directive. The key dates are:

Medium-sized and large companies (all products): The EUDR applies from Dec. 30, 2026.
Micro and small enterprise companies (paper products): The EUDR applies from Dec. 30, 2026.
Micro and small enterprise companies (cacao, coffee, palm oil, cattle, rubber and soy products): The EUDR applies from June 30, 2027.

This classification is based on your individual company’s metrics, not a larger group or parent company you might belong to.

Small and micro enterprise

Q: What companies are considered small and micro under the EUDR?

A: According to the EU's Accounting Directive, a company is considered a micro or small enterprise if it meets at least two of the following three criteria:

Less than 50 employees
Net turnover of less than €10,000,000
Balance sheet total of less than €5,000,000

Q: What specific obligations are waived for micro and small primary operators?

A: To simplify your process, if you qualify as a micro or small primary operator in a low‑risk country or region, you are not required to submit a DDS for each placement/export; instead, you may make a one‑time simplified declaration. Core due‑diligence duties remain, but documentation and update requirements are streamlined:

Per‑consignment DDS filings: Risk assessment and record‑keeping are performed through the one‑time simplified declaration and maintained on a proportionate basis.
Certain detailed reporting and record-keeping obligations that larger operators must maintain.

Q: Who can use the one-time simplified declaration and how is it submitted?

A: If you qualify as a micro or small primary operator in a low‑risk country or region, the EUDR provides a one‑time simplified declaration option. In general:

Submit a one-time simplified declaration: Use the information system (Article 33) to register before placing products on the market or exporting them.
Obtain a declaration identifier: Once your one-time declaration is submitted, use the system’s reference in your subsequent EUDR filings/records as applicable.
Update as needed: While the declaration is a one-time requirement, you should update it if there are major changes to your business information.

Q: What information do I need to provide in the declaration?

A: Annex III sets out the specific declaration requirements. However, if this information is already available in an existing Union or Member State database, you may not be required to submit it again — provided the Member State links that data to the central system.

Q: Are there different rules for geolocation data for small operators?

A: Yes. Instead of providing precise geographic coordinates (latitude and longitude) for every plot of land as required in Article 9:

You may provide the postal address of all plots of land.
Alternatively, you can provide the postal address of the establishment where the relevant commodities were produced.

Q: Are samples or products made from recycled materials in scope of the EUDR?

A: The scope of the EUDR can differ for these types of products:

Samples: The Commission has proposed excluding negligible‑value/quantity samples used only to obtain orders — and items used solely for testing — from the EUDR’s scope (pending adoption).
Recycled materials: Products made 100% from recycled materials (end-of-lifecycle waste) are not within the scope of the EUDR. However, if any virgin material is added, the product then falls within the scope, and the virgin material must have an attached Due Diligence Statement (DDS).

Q: Do existing certifications like FSC mean automatic EUDR compliance?

A: No, certifications such as FSC, SFI or PEFC do not automatically mean compliance with the EUDR. However, these certifications can support your efforts around the EUDR — for instance, by being part of your Due Diligence System, demonstrating supply chain involvement and mitigating risks associated with local laws or supply chain complexity.

Q: We're exporting an EUDR product. What are our obligations?

A: Under the current simplifications, there are now two scenarios:

Downstream operators exporting products already covered by an operator’s DDS do not submit a new DDS for export.
First operators must submit a DDS via the Union information system before placing on the EU market or exporting and use the DDS reference where customs formalities require it.

Q: We're re-importing a good that was previously in the EU. How does this affect us?

A: Due to the simplification around exports requiring EUDR numbers, there’s no clear guideline around this process. The European Commission has indicated that it will publish guidance to address re-imports.

Q: Where can I get more information?

A: For more details on the EUDR, please refer to the official EU Commission website. For specific questions on Avery Dennison products and our compliance efforts, please contact your Avery Dennison representative.

Note: This FAQ provides general information on the EUDR. It does not constitute legal advice.

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
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Regulation on Deforestation-free Products (EUDR)

Frequently Asked Questions