I\’m in publishing, childrens books. Mainly produced in China.
As I understand transport packaging is excluded from EUDR. For childrensbooks often a paper-band or waver seals (made of paper) are being used to keep the books closed. Are these paper-bands and waver seals considered as part of the product? And as such we need EUDR compliance for these items. Or are these items considered as transport packaging?
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Anonymous User
This is addressed in question 2.5 of the EU Commission’s FAQs. Here are two relevant excerpts:
- “Packaging materials used exclusively as packaging material to support, protect or carry another product placed on the EU market is not a relevant product within the meaning of Annex I of the Regulation, regardless of the HS code under which they fall.“
- “If any of the concerned packaging is placed on the EU market or exported as a product in its own right (i.e. standalone packaging), rather than as packaging for another product, it is covered by the Regulation and therefore due diligence requirements apply.“
According to the FAQs, packaging material used to support, protect or carry a product is not covered by the regulation. Unless it is imported as a separate product, for example when packaging material is reordered.
In addition, section 7 a) of the European Commission’s guidelines provides a more detailed definition of ‘packaging and packaging materials’.
It is important to note that the FAQs and guidelines are not legally binding in cases of doubt.