The European Deforestation Regulation (EUDR) marks a significant shift in how companies manage the sustainability of their wood-derived materials. For the cosmetics sector, this directly affects the cardboard, paper, and pulp used in boxes, labels, envelopes, inserts, and other packaging components.
Although the mandatory application of the regulation begins at the end of 2025, anticipating and organizing traceability from now on is key. This allows for compliance with legal requirements, reduces the risk of sanctions or customs blockages, and strengthens the brand's reputation with consumers and distributors who value sustainability.
This article details what the EUDR requires, how to structure a due diligence system, what tools to use, and how to communicate compliance transparently, with examples applicable to the cosmetic sector.
Scope of the EUDR for Cosmetic Packaging
The EUDR regulates seven forest and agricultural commodities: soy, palm oil, timber, cocoa, coffee, rubber, and cattle. For cosmetic packaging, the critical commodity is timber and all its derivatives:
- Cardboard used in cases, product boxes, envelopes, and secondary packaging.
- Paper for labels, brochures, and marketing inserts.
- Cellulose used in pads, fillers, or protective inserts.
Key Definitions According to EUDR:
- Legal product: raw material obtained in accordance with the national legislation of the country of origin, including property rights, exploitation permits, and environmental compliance.
- Deforestation-free product: one that comes from areas that have not suffered loss of primary or secondary forest, nor conversion of natural ecosystems since 2020 (reference date established by the regulations).
This implies that each supplier and batch must be able to demonstrate, with verifiable evidence, the legality and responsible origin of the wood.
Actors Involved in the Supply Chain
The EUDR applies to all actors involved in the wood materials supply chain:
- Producers and converters: companies that transform forest raw materials into paper or cardboard.
- Importers: companies that introduce products or materials from outside the EU.
- Cosmetic brands, laboratories, and distributors: that use paper or cardboard packaging as part of their final product.
Although the regulation establishes more flexible deadlines for micro-enterprises, all companies must have a documented due diligence system by December 30, 2025.
Due Diligence Principles
The EUDR establishes that all companies must implement a due diligence system based on three main pillars: geographical identification, risk assessment, and mitigation measures.
Geographic Identification
Each batch of material must be associated with precise GPS coordinates of the plot or forest concession of origin. This allows verification that the wood comes from legal and non-deforested areas.
Practical recommendations:
- Use a unique batch code that connects supplier, certification, and coordinates.
- Validate the information with GIS tools and deforestation APIs.
- Record the extraction date and volume of each batch to ensure complete traceability.
Risk Assessment
Not all providers or countries present the same level of risk. The assessment must consider:
- Country risk: legal stability, inspection mechanisms, deforestation index, and environmental compliance.
- Supplier risk: compliance history, previous certifications, audits, and reputation.
- Product risk: type of material (virgin or recycled), batch mixing, and complexity of the transformation chain.
A recommended practice is to use a semi-quantitative methodology, assigning risk scores (low, medium, high) and recording evidence to justify the rating.
Mitigation Measures
When a risk that cannot be ruled out is detected:
- Request external audits from the supplier.
- Require complementary certifications such as FSC Controlled Wood or PEFC Chain of Custody.
- Replace suppliers who cannot demonstrate reliable traceability.
- Continuously monitor suppliers and update records at least once a year.
Certifications and Necessary Documentation
FSC and PEFC certifications remain relevant, but not sufficient to comply with the EUDR. Additional documentation is required to demonstrate:
- Exact geographical origin of each batch.
- Digital record of the chain of custody from the forest to the final product.
- Updated supplier declarations confirming legal compliance and absence of deforestation.
- Evidence of mitigation measures implemented for identified risks.
Non-compliance can lead to sanctions and trade restrictions within the EU, as well as damage to the brand's reputation.
Supply Chain Organization
For the due diligence system to function effectively, it is recommended:
- Complete supplier mapping: packaging, paper/cardboard manufacturers, and distributors.
- Request for geolocated information for each batch of raw material.
- Risk assessment considering country, supplier, and material type.
- Verification of current certifications, including validity dates and associated audits.
- Centralization of information in a digital system that allows for the generation of complete EUDR declarations.
- Periodic review of all data, ensuring updated coordinates, certifications, and mitigation measures.
This approach turns due diligence into a continuous process, not a one-off formality.
Recommended Digital Tools
The use of technology is fundamental to streamline the collection, validation, and storage of information:
- Blockchain: to guarantee the integrity and traceability of batches.
- Satellite maps and deforestation APIs: to validate coordinates and real-time forest status.
- Document management software: to integrate certificates, supplier declarations, and audits.
These tools are especially useful for cosmetic companies with multiple suppliers and products, reducing errors and improving internal control efficiency.
Technical Indicators for Risk Control
Some key indicators that facilitate due diligence management in cosmetics:
Strategic Impact of Compliance
While implementing the EUDR generates initial costs in data collection, audits, and digital systems, it also offers strategic benefits:
- Legal certainty against inspections, sanctions, or customs seizures.
- Preferential access to clients and distributors who demand traceability.
- Improved reputation and trust with consumers concerned about sustainability.
- Alignment with European sustainability strategies, such as PPWR and 2030 objectives.
Transparent Communication to Clients and Consumers
Compliance information must be verifiable and concrete, avoiding vague messages like "100% sustainable." Examples of adequate communication:
- “Our cardboard packaging is traceable to specific coordinates, complying with EUDR regulations.”
- “We have documentation confirming the legality of the raw material and the absence of deforestation.”
The EUDR transforms the sustainability standards for cosmetic packaging. Now, it is not enough to use recycled or certified materials, but it is necessary to be able to demonstrate with concrete evidence the responsible origin of the raw material.
Brands that begin organizing their traceability and documentation today will be ready to comply with regulations, reduce legal risks, and turn transparency into a competitive advantage with European consumers and distributors.