Beware of important distinctions

Some product types/materials are only partially covered by the EUTR or they are only covered in certain circumstances. Below is a summary of areas where it is important to be clear on the exact distinctions and definitions used in the EUTR and the EU Combined Nomenclature.

Packaging

The EUTR covers "packing cases, boxes, crates, drums and similar packing, of wood; cable-drums of wood; pallets, box pallets and other load boards, of wood; pallet collars of wood". Essentially, this includes almost any wood-based packing material or transportation aids used to convey other products.

However, the EUTR only applies to packing material when a) it is sold as a product in its own right, or b) when the packaging gives the product its essential character, such as decorative gift boxes.

The EUTR does not apply to packaging which is "used exclusively as packing material to support, protect or carry another product placed on the market". For example, if you purchase products delivered within cardboard boxes or on pallets, then the packaging material normally isn't covered.

The Regulation also exempts packaging which is "specially shaped or fitted to contain a specific article or set of articles, suitable for long-term use and presented with the articles for which they are intended". Examples include camera cases, musical instrument cases, gun cases, and necklace cases.

Note: The customs clearance is important in determining which product is "placed on the EU market". If a material is customs cleared as packaging, then it is covered by the EUTR. But if you import a product X which is customs cleared as "X", then the packaging holding X is exempt.

Recovered / Waste products

Timber products are exempt from the Regulation if it can be documented that they are produced "from timber or timber products that have completed their lifecycle and would otherwise be disposed of as waste, as defined in Article 3(1) of Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste. One example is timber material deriving from the demolition of buildings located outside of the EU.

Printed matter

Books, brochures, and photos are exempt from the Regulation. This applies to any printed matter where the print itself constitutes the essential product. However, other types of paper or tissue are covered although they may carry print . Examples include facial tissue, toilet paper, packaging or stationery paper.

Bamboo products

Products made from solid bamboo, such as bamboo flooring, bamboo table tops and furniture parts are covered by the EUTR. However, the following product types are exempt:

1. Products made from plaited or woven bamboo.
2. Pulp and paper made from bamboo.
3. Seats (chairs, sofas, etc.) made from bamboo.

Furniture

Most furniture is covered by the EUTR. However, the following product groups are exempt:

1. Seats including sofas, chairs, etc. 
2. Furniture made from plaited/weaved bamboo.
3. Medical, surgical, dental or veterinary furniture.