Printers and packaging converters ask the same question: is my box in scope? The answer depends on whether the packaging is the product or only carries one.
Summary
Annex I lists ‘pulp and paper of Chapters 47 and 48’ of the Combined Nomenclature, with the exception of bamboo-based and recovered products. Heading HS 4819, cartons, boxes, cases and bags of paper or paperboard, is not named separately but falls within Chapter 48. A box that is sold as the product is therefore in scope.
Three rules set the limits. Regulation (EU) 2025/2650 deleted the Chapter 49 line for printed books, newspapers and other printed products from Annex I. The Commission guidance notice states that HS 4819 packing used only to support, protect or carry another product is not covered, while packing placed on the market as a product in its own right is. Annex I itself writes the packing exclusion only into heading 4415 (wooden packing); for paper the exclusion comes from the Commission guidance.
Single-use packing presented with the goods is outside the scope while it is used for that purpose, and so is reusable packing, such as pallets, from the moment it is used to carry another product. Containers that give a product its essential character stay in scope.
HS 4819 boxes and bags as a product
A folding carton, a corrugated box or a paper bag that you manufacture and sell empty is the product. The customer buys the packaging itself. In that case the converter or importer is the operator or a downstream operator for HS 4819, depending on where the paperboard was first placed on the market.
The statement then needs the geolocation of the plots that produced the wood fibre, going back through the pulp mill and the paper mill to the forest.
What is excluded: transport packaging and CN 49 printed matter
Packing material or containers under HS 4819 that are used to support, protect or carry another product are not covered. The same applies to wooden packing under heading 4415, where Annex I itself carries the note. A carton sold empty, as the product, is covered. The test is how the item is placed on the market, not what it is made of.
For printed matter, the line ‘ex 49 Printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper’ was deleted from Annex I. Printed items that fell under that line are therefore no longer relevant products. Paper that is not printed matter, such as blank boxes and bags, is not affected.
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Single-use, reusable and essential-character packing
The guidance separates single-use packing, which is outside the scope when it is used exclusively to carry another product presented with it, from packing clearly suitable for repeated use, which is outside the scope from the moment it is used for that purpose onwards. Pallets are the example given.
Ordinary packaging presented with the goods and of a kind normally used for such goods is classified with the goods under General Rule 5(b) of the Combined Nomenclature, which puts it outside the scope. A container with an essential character of its own is classified separately and stays in scope. The guidance notes that these finer distinctions concern only a small share of goods.
BOM lineage for printers and converters
A printer or converter turns purchased board into many finished items. To make a statement possible, each finished batch must lead back to the input batches and from there to plots. We record this as a tree: a finished batch points to its parent batch, and each raw batch is linked to its plots.
Keep the bill of materials per production order. When one order uses board from two mills, both input batches appear in the lineage, with the quantity taken from each.
Why mass balance does not work
Mass balance means mixing volumes that meet the requirements with volumes that do not in one stock, and reporting only the qualifying share on paper. The statement must give the geolocation of all plots where the commodities in the product were produced (Article 9(1)(d)), and a mixed stock cannot show that. We therefore forbid mass balance in the platform: every batch must be linked to its exact plots.
Packaging scope at a glance
| Article | Rule | Applies to | Date rule |
|---|---|---|---|
| Annex I | Pulp and paper of Chapters 47 and 48 (except bamboo-based and recovered products), which covers HS 4819, are relevant products. | Producers, importers and converters | From the application date that applies to the company. |
| Annex I | Wooden packing (HS 4415) used only to carry another product is excluded. No equivalent note for Chapter 48. | Producers and users of wooden packing | From the application date that applies to the company. |
| Annex I (Reg. 2025/2650) | The Chapter 49 line for printed products was deleted from Annex I. | Printers and publishers | From the application date that applies to the company. |
| Commission guidance 7(a) | HS 4819 packing used only to support, protect or carry another product is not covered; packing placed on the market as a product is covered. | Packaging converters and their customers | From the application date that applies to the company. |
| 9 | Each batch is traceable to its plots; no mass balance. | All operators | From the application date that applies to the company. |
HS/CN codes in the packaging chain
| HS/CN heading | Product | In scope | Basis |
|---|---|---|---|
| HS 4819 | Cartons, boxes, cases and bags of paper or paperboard, sold as the product | Yes | Annex I |
| HS 4819 | Packing used only to support, protect or carry another product | No | Commission guidance 7(a) |
| HS 4415 | Wooden packing used only to carry another product | No | Annex I note to heading 4415 |
| CN 49 | Printed books, newspapers, leaflets | No (line deleted) | Regulation 2025/2650, Art. 1(26) |
| HS 48 | Paper and paperboard of Chapter 48, except bamboo-based and recovered products | Yes | Annex I |
Exemptions
Two exclusions come up most often in the packaging chain.
- Packing material or containers used exclusively to support, protect or carry another product: wooden packing (HS 4415) by the Annex I note, paper packing (HS 4819) by the Commission guidance. Packing sold as the product is not covered by this exclusion.
- Printed products of the deleted Chapter 49 line: books, newspapers, pictures and other products of the printing industry (for example leaflets and printed inserts, if they are classified in Chapter 49; confirm the classification with customs).
Acts that can change the scope
We have not verified the adoption status of these acts.
- Delegated act on the product scope of Annex I, draft published in May 2026.
Frequently asked questions
Is a paper box under HS 4819 covered?
A box or bag sold as the product is covered: it falls within Chapter 48, which Annex I lists. Cartons, boxes and bags under HS 4819 used only to support, protect or carry another product are not covered, according to the Commission guidance notice (C/2026/3896). Annex I itself writes the packing exclusion only for wooden packing (HS 4415).
Are printed books and leaflets covered?
The printed products of the Chapter 49 line (books, newspapers, pictures and other printing-industry products) are no longer in Annex I: Regulation (EU) 2025/2650 deleted that line.
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Sources
- Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on deforestation-free products (EUDR), OJ L 150, 9.6.2023. Read in the Official Journal text on 10 November 2026.
- Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115 (application dates, downstream operators, simplified declaration, scope). Read in the Official Journal text on 10 November 2026.
- Commission Notice: Guidance document for Regulation (EU) 2023/1115 (C/2026/3896, OJ 20 July 2026; earlier C/2024/6789), section 7(a) on packing and packaging materials. Commission interpretation, not the text of the Regulation.
- Legal commentary and Commission guidance as reported by law firms (EY, Linklaters, VinciWorks, Lexgo), read on 10 November 2026. Indicative only.
Facts last checked against the Official Journal text on 10 November 2026.
This page is general information, not legal advice. It reflects the Official Journal text of Regulation (EU) 2023/1115 as amended and Commission guidance as read on 10 November 2026; items marked as expected are not confirmed. Obligations depend on your role, product and Member State. Check the current official text on EUR-Lex.