EUDR and Greyboard Files: Why Recycled Board Is Out of Scope

What EUDR is, and where greyboard sits

EUDR greyboard questions come up in almost every European enquiry we handle now, and the short answer is reassuring for anyone buying recycled board. The EU Deforestation Regulation, Regulation (EU) 2023/1115, is a European Union law that requires certain commodities and the products made from them to be deforestation-free and legally produced before they can be placed on the EU market or exported from it. It is a due diligence obligation rather than a certificate: no EUDR certificate exists, and no certificate can be bought. Greyboard, the recycled paperboard most filing products are built from, runs through a specific exclusion in the regulation, and that exclusion is why a greyboard file made from recovered waste paper sits outside the scope. This page explains what the regulation covers, where the boundary runs for paper and board, and what a buyer should still have on file.

The seven commodities behind the regulation

EUDR covers seven commodity groups: cattle, cocoa, coffee, oil palm, rubber, soya and wood. A product is in scope when it falls under one of those groups and appears in the list of goods in Annex I of the regulation, which is written in Combined Nomenclature codes rather than in product names. Wood is the group that matters to a stationery buyer, and it reaches further than most people expect: it covers sawn timber and plywood, and it also covers pulp, paper, printed products and a set of paperboard articles used in offices.

Which paper and board products are in scope

Annex I lists pulp and paper of Chapters 47 and 48 of the Combined Nomenclature, with an explicit exception for bamboo-based products and for recovered (waste and scrap) products. It also lists CN 4819, which covers cartons, boxes and articles of paperboard of a kind used in offices, including box files and letter trays. That entry matters because it catches some filing products by name: a box file placed on the market as a product in its own right is a relevant product, while the same box used purely as packaging to carry another product is not.

The recovered material carve-out

Annex I carries a general exclusion, and the wording is worth reading closely: the regulation does not apply to goods produced entirely from material that has completed its lifecycle and would otherwise have been discarded as waste, as waste is defined in Article 3(1) of the Waste Framework Directive 2008/98/EC. Recital 40 of the regulation explains the intent, which is that recycled material should be encouraged and that pulling it into the scope would place a disproportionate burden on operators.

The same idea appears twice for our industry. The pulp and paper entry in Annex I excludes recovered (waste and scrap) products, and the general exclusion covers goods made entirely from lifecycle-completed material. Household waste paper, retail waste paper, print shop off-cuts and converting scrap all fit that description: they would otherwise be discarded as waste.

One word in the exclusion does the heavy lifting, and it is the word entirely. A board made entirely from recovered waste paper is outside the regulation. A board whose furnish mixes recovered fibre with virgin pulp is not: the product becomes subject to the requirements, and the virgin share has to be traced back to the plot of origin by geolocation.

By-products sit on the other side of the line. A by-product of a manufacturing process is generally in scope, because it never became waste. Mill broke that is repulped inside the same mill is the clearest example — it is part of that mill's own pulp flow rather than a recycling input. Converting scrap that leaves the plant to be repulped elsewhere has completed its lifecycle and is treated as recovered material.

Why greyboard is normally a recycled board

Greyboard, also sold as grey board, chipboard or book board, is a multi-ply paperboard built up from recovered waste paper. That is what gives it the grey colour and the density that make it useful: a book cover, a box file, a lever arch file cover, a ring binder board and a game board all need a flat, stiff panel that can be cut, printed, wrapped and glued without warping. We build filing products on greyboard from 1.0mm to 3.0mm, and the boards we buy come from mills that run on recovered fibre rather than on virgin pulp. Removing the need for virgin fibre is the reason greyboard is one of the most recycled materials in the stationery supply chain.

Our position on greyboard files

Our greyboard is made from recovered waste paper, so the board itself is not a relevant product under EUDR and no due diligence statement is required for it. Buyers in Germany, the Netherlands, Italy and Poland have asked us the same question, and the answer is the same for every EU market: the material is outside the scope because it is produced entirely from recovered fibre. What we supply with an order is the evidence a buyer needs to document that position: the recovered fibre basis of the board, the mill it came from, and the board grade and thickness on the specification sheet. Our FSC chain-of-custody certification covers the board we buy, and we pass the certificate details down the supply chain where a customer needs them for their own file.

The position changes on a product that carries a virgin component. A greyboard file with a virgin-fibre printed wrap, a virgin paper spine tape or a virgin board slipcase has virgin material inside the relevant product, and that ply may fall in scope. Where an order includes a component like that, we flag it at sampling rather than leaving a customer to discover it at customs.

What a buyer should collect for the file

A customer importing into the EU keeps the same records for a greyboard product whether EUDR applies or not, because the burden of proof is on the importer. We recommend keeping the following with each shipment:

• A supplier declaration naming the mill and confirming the board is made from recovered waste paper
• The recovered fibre percentage, and a statement on whether any virgin fibre enters the furnish
• Board grade, thickness in millimetres and weight per shipment
• Certificate details for any chain-of-custody claim attached to the board
• Records kept for at least 5 years, which is the retention period the regulation sets

Timeline: where the deadlines stand today

The application date has moved twice. The original date of 30 December 2024 was pushed back a year in late 2024, and a second amendment in December 2025 moved it again: large and medium operators now face 30 December 2026, and micro and small operators outside the timber sector have until 30 June 2027. The same revision lightened the burden on companies further down the chain, so a downstream operator that buys a product already covered by an upstream statement generally only has to hold the reference number.

Dates in this area have moved before, so check the Commission's current guidance rather than any summary, including this one. For a recycled board order the practical effect is the same: the material is outside the scope, and the paperwork that proves it is what matters.

Questions buyers ask

Is a greyboard file in scope of EUDR?

If it is made entirely from recovered waste paper, no. The board is not a relevant product, so no due diligence statement applies to it. If the file contains a virgin-fibre component, that component may be in scope.

Does a recycled board need an EUDR certificate?

No. EUDR is not a certification scheme and no EUDR certificate exists. Compliance is shown through due diligence records and, where required, a due diligence statement filed in the EU information system.

What paperwork proves a board is out of scope?

A mill declaration confirming recovered waste paper as the furnish, the recovered content, the board grade and thickness, and the chain-of-custody certificate details where a claim is attached. Keep them with the shipment records for 5 years.

What if the board contains a small percentage of virgin fibre?

Then the product is subject to the regulation, and the virgin material has to be traced to the plot of origin with geolocation. The recovered share carries no obligations.

Does packaging count?

Packaging used purely to support or protect another product is not a relevant product, whatever code it falls under. A paperboard article sold as a product in its own right, such as a box file, is treated differently.

When do the obligations start?

Large and medium operators: 30 December 2026. Micro and small operators outside the timber sector: 30 June 2027. Check the Commission's latest guidance, as the dates have already been amended twice.