EU Compliance & Market Access
Environmental Product Compliance
Environmental rules attached to what you sell — origin traceability, packaging obligations, and green claims law.
Regulation (EU) 2023/1115
EUDR — EU Deforestation Regulation
Requires operators and traders to ensure regulated commodities and derived products sold in the EU have not contributed to deforestation or forest degradation after 31 December 2020.
- In force
- 29 June 2023. Application, after two postponements (Reg. 2024/3234, then Reg. 2025/2650 of December 2025): 30 December 2026 for large and medium operators; 30 June 2027 for micro and small enterprises.
- Regulated commodities
- Cattle, cocoa, coffee, palm oil, soya, wood, rubber — plus derived products containing or made from these commodities.
- Thailand exposure
- Palm oil (ingredient in some pet foods and treats), rubber (pet accessories, toys).
- Due diligence obligations
- Collect geolocation data of production plots, assess deforestation risk, mitigate risk, submit due diligence statements via EU information system.
- Penalties
- Minimum 4% of annual EU turnover for non-compliance.
Regulation (EU) 2025/40
Packaging & Circularity — PPWR
The Packaging and Packaging Waste Regulation replaces Directive 94/62/EC and sets binding targets for recyclability, recycled content, and packaging minimisation.
- Adopted
- January 2025. Phase-in: most requirements apply from 2030, some from 2035.
- Recyclability
- All packaging must be recyclable by 2030. Recyclability assessed against harmonised EU criteria.
- Recycled content — plastics
- 10–35% by 2030 depending on packaging type; 25–65% by 2040.
- Packaging minimisation
- Empty space in grouped and transport packaging must not exceed 50%.
- Labelling
- Mandatory QR code linking to recycling information; harmonised recyclability labelling across EU member states.
- Pet food relevance
- Pouches, trays, tins, and treat bags are all in scope. Multi-layer flexible packaging faces recyclability challenges under harmonised criteria.
Directive (EU) 2024/825 · Green Claims Directive (proposed)
Green Claims
Two instruments tackle greenwashing — the Empowering Consumers Directive bans specific misleading claims now; the Green Claims Directive will require pre-verified substantiation.
- Directive 2024/825
- Empowering Consumers Directive. In force March 2024, transposition by March 2026. Bans generic claims — "environmentally friendly", "eco", "green", "carbon neutral" — without substantiation. Bans carbon offset-based neutrality claims. Bans sustainability labels not based on approved schemes.
- Green Claims Directive
- Proposed (COM/2023/166). Requires explicit, verifiable, third-party verified environmental claims before use. Status: under negotiation as of 2024.
- Relevance for pet retail
- "Sustainable sourcing", "responsibly sourced", "ocean-friendly" claims on packaging and marketing must be substantiated.
- Substantiation requirement
- Claims must be based on recognised scientific evidence, cover the full lifecycle where relevant, and be verified by an accredited third party.
Country risk intelligence
View sourcing country risk profiles →Worked example, current state
EUDR in practice: a palm-oil chain into the EU
The regulation is now fixed in shape and date. After the December 2025 amendment, obligations bind large and medium operators from 30 December 2026 and micro and small enterprises from 30 June 2027, and the Commission's May 2026 review stated it will not propose further changes to the legal text[1][2]. What an importer of palm-derived ingredients files is concrete: a due-diligence statement in the EU Information System (running on TRACES since December 2024) carrying the geolocation coordinates of every production plot and evidence the product is deforestation-free after 31 December 2020 and legally produced[3]. The 2025 amendment took real weight off repeat shippers: one annual statement can cover multiple shipments, and downstream traders no longer file their own statements, they retain the upstream reference numbers[1].
The country benchmarking, adopted May 2025, put Indonesia, Malaysia and Brazil, the producer countries that matter for palm and soy, in the STANDARD risk class (3 percent minimum check rate); only Belarus, Myanmar, North Korea and Russia are high-risk[4]. For a buyer, standard risk means the full due-diligence burden stands: the classification softens the inspection rate, not the geolocation requirement. The first review of the list is due during 2026, so the classes can still move.
The verification gap is the practical problem: a statement is self-declared, and the plot coordinates are only as good as the supplier's mapping. That is where supplier-side evidence, mill lists, plot polygons, certification audit trails, becomes the thing an EU buyer actually needs from Southeast Asian suppliers before the December 2026 date, and it is checkable in advance.
[1] European Commission, Access2Markets: Delay until December 2026 and other developments in the implementation of the EUDR (December 2025).
[2] European Commission, COM(2026) 191 final: EUDR simplification review report (4 May 2026).
[3] European Commission, Green Forum: The Information System of the Deforestation Regulation.
[4] European Commission, Green Forum: Country classification list (adopted 22 May 2025).