Do brochures or books that are given to customers to explain the product but independent of the product delivery (sometimes free of charge) also fall under the EUDR? For example, brochures for trade fairs.
1 Answer
Anonymous User
Hi Charlotte,
Brochures or books given to customers to explain a product but distributed independently of the product delivery, such as at trade fairs, may fall under the EUDR depending on their classification. While packaging materials or user manuals accompanying shipments are explicitly excluded from the EUDR under Annex I, the regulation does not clearly exempt informational brochures distributed separately.
According to Article 2, paragraph 18, the regulation defines “placing on the market” as any commercial activity of providing a relevant product on the Union market, whether for payment or free of charge. This implies that the status of a brochure might depend on whether it is considered an independent product or merely ancillary informational material.
- If brochures are treated as standalone products, they would likely be subject to the EUDR unless they meet other criteria, such as being made from 100% recycled paper.
- If they are classified as non-relevant informational materials, even when distributed separately, they might not fall under EUDR scope.
Ultimately, the determination of whether such materials are covered by the EUDR depends on their classification as an independent product. Legal confirmation should be sought from a company’s legal department, as this is subject to interpretation and specific regulatory guidance.
Hope this helps!