European Deforestation Regulation EUDR
The European Deforestation Regulation (EUDR) is the EU’s latest legislative step to tackle deforestation and forest degradation linked to global supply chains. It applies to a range of commodities including timber, which is a key raw material for PGS Group’s pallet and packaging activities.
The regulation aims to ensure that products imported into, exported from, or produced and sold within the EU market are not associated with deforestation or forest degradation after January 1, 2021, and are legally produced in accordance with the laws of their country of origin.
The EUDR entered into force on 29 June 2023. Its obligations will apply directly across all EU Member States without national transposition. To allow businesses more time to prepare, the EU granted a 12-month extension, setting the compliance deadline for medium and large companies at 30 December 2025, with a further one-year postponement currently under discussion.
What is required?
To comply with the EUDR, companies must conduct and document due diligence on the origin and legality of in-scope commodities. This includes:
- Submitting a Due Diligence Statement;
- Declaring products are not sourced from land subject to deforestation and forest degradation after 1 January 2021;
- Ensuring products are in compliance with applicable laws.
This requirement applies per shipment, and is backed by strict traceability and risk management obligations.
Core Due Diligence Obligations
The EUDR sets out three essential obligations* for operators and traders:
- Information gathering: Collecting detailed information about the product, including geolocation coordinates of the harvesting plot, the commodity type, country of production, and supplier identity.
- Risk assessment: Evaluating whether the risk of deforestation or illegality is present, based on governance indicators, forest conversion data, and species-level risk factors.
- Risk mitigation: Taking adequate measures where a risk is identified, including supplier clarification, third-party audits, or exclusions.
*If sourced from a country classified as ‘low risk’ under Article 13, the last two obligations no longer apply.
PGS Group's Preparations
At PGS Group, we have an established Due Diligence System (DDS) developed initially under the EU Timber Regulation (EUTR). Our DDS was recently reviewed by the Belgian Federal Public Service for Public Health, who confirmed its compliance with EUTR obligations.
To prepare for the more stringent demands of the EUDR, we are now expanding our system in three ways:
- Updating our supplier data collection procedures;
- Adding plot-level traceability components;
- Reviewing and upgrading our internal risk indicators to align with the new regulation.
The work is ongoing, and we aim to ensure full operational readiness before the December 2025 deadline.
Supplier Declarations Current Practice and Future Alignment
As part of our existing sourcing process, we require suppliers to provide structured information on:
- The country and region of origin of the wood;
- The type of wood species supplied;
- A declaration confirming that the wood is not sourced from controversial origins (e.g. conflict timber, illegal logging);
- Willingness to provide additional information and agreement to a potential supplier audit.
This information helps us maintain a clear audit trail and verify that our purchases are responsibly sourced. While our current procedures already cover many EUDR elements, the addition of precise geolocation data per harvest plot will be the most significant change under the new regulation — and is currently being integrated into our supplier protocols.
Certifications and Internal Controls
We hold a PEFC multisite certificate (WOOD.BE-PEFC-COC-001631), which covers all our production entities and confirms that certified timber is sourced according to robust social, environmental, and legal criteria. The certificate is audited annually by an independent third party and aligns closely with the EUDR framework.
Beyond third-party certifications, PGS Group applies internal control procedures to safeguard compliance across its sites, including:
- Annual internal audits;
- Group-wide sourcing protocols;
- Supplier onboarding and screening.
“EUDR readiness is not a tick-the-box exercise—it’s about integrating traceability into real procurement decisions.” - Marie, Wood Procurement
Looking Ahead
As the EUDR takes effect, PGS will continue strengthening its procurement processes to ensure full and consistent compliance. We view this as an opportunity to bring further clarity to our supply chains and demonstrate our long-standing commitment to responsible sourcing.
For more information, watch our interview with Charlin, who oversees PEFC certification at group level. Visit our download page to access certification documents.
Contact
If you have any questions regarding the EUDR regulation and how PGS Group is preparing for compliance, don't hesitate to contact our CSR team on CSR@pgsgroup.com.
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