Key takeaways
- EUDR dried fruit import 2026 planning hinges on one fact most buyers miss: the EU Deforestation Regulation (EUDR) covers seven named commodities — cattle, cocoa, coffee, oil palm, rubber, soya, and wood — so a plain dried apricot, fig, or sultana is not in scope, but palm-oil coatings, glazing agents, and shared logistics can pull a finished snack line back under it. You have to check ingredients and packaging, not just the fruit.
- The Packaging & Packaging Waste Regulation (PPWR — Regulation (EU) 2025/40) applies to every dried-fruit consignment regardless of EUDR, because all packaging placed on the EU market is in scope. Its general application date is 12 August 2026, with further obligations phasing in through 2030 and beyond.
- EUDR's headline obligations — a Due Diligence Statement (DDS) with plot-level geolocation filed in the EU information system — now apply to large operators from 30 December 2026 (and to micro and small enterprises from 30 June 2027) following a second postponement adopted in late 2025. Always re-confirm the current date before you commit a clause to a contract.
- A 2026-ready importer needs two parallel files: an EUDR file (commodity screening, geolocation, DDS reference flow) and a PPWR file (material declaration, recyclability, recycled-content and minimisation evidence). This guide gives you a checklist for both.
- Arovela supplies geothermally-dried fruit and natural snacks from a Sındırgı (Balıkesir) facility with a warehouse in Solingen, Germany, runs on ISO 22000, ISO 9001, and ISO 27001 documentation, and provides a per-batch Certificate of Analysis (COA) — a traceability-ready base for the supplier-data work both regulations demand.
Introduction: two regulations, one shipment, one 2026 deadline window
For an EU dried-fruit importer, 2026 is the year two very different sustainability regulations land on the same pallet. The EUDR dried fruit import 2026 question — "does the deforestation law apply to my apricots?" — is mostly about ingredients and supply-chain data. The PPWR question — "is my bag, box, and case legal to place on the EU market?" — is about packaging. They are governed by separate legal texts, separate authorities, and separate evidence files, yet they arrive together and both reward suppliers who already keep clean, traceable records.
This article is deliberately narrow. It is written for buyers, category managers, and quality leads importing dried fruit and natural snacks into the EU, and it focuses on the dried-fruit-specific reading of EUDR plus the practical PPWR packaging checklist. For the full, commodity-by-commodity treatment of the deforestation rules across herbs, oils, and dried fruit, read our broader explainer on EUDR compliance for natural products — this post assumes that background and does not repeat it. For the wider policy context that ties EUDR, PPWR, CSRD, and CBAM together, see our EU Green Deal supplier guide.
A note on dates before we start: both regulations have moving timelines. EUDR has been postponed twice, and PPWR phases obligations in over many years. Where this guide states a date, treat it as the position as of mid-2026 and verify the live date on the official source before drafting a contract clause or a customer commitment.
Does EUDR apply to dried fruit? The honest answer
This is the first question to settle, because it determines whether you build an EUDR file at all for a given SKU — and the answer is more nuanced than either "no, fruit is exempt" or "yes, everything is covered."
The seven commodities — and why most dried fruit sits outside them
EUDR (Regulation (EU) 2023/1115) regulates a closed list of seven relevant commodities: cattle, cocoa, coffee, oil palm, rubber, soya, and wood, plus the products derived from them that are listed by CN (Combined Nomenclature) code in Annex I of the regulation. According to the European Commission's own implementation guidance on traceability and geolocation for commodities subject to the EUDR, the obligation attaches to those commodities and their listed derivatives — not to agricultural products in general.
A dried apricot, fig, sultana, mulberry, or date — sold as plain dried fruit — is not one of the seven commodities and is not a listed derivative of them. On a strict reading, a consignment of plain Turkish dried apricots is outside EUDR's substantive obligations. That is genuinely good news for the core dried-fruit trade, and it is the single most important fact for a 2026 sourcing plan.
Where dried-fruit lines get pulled back in
The trap is the finished product, not the fruit. Several common scenarios can put a dried-fruit or snack SKU back inside scope:
- Palm-oil ingredients. Oil palm is one of the seven commodities. If your dried fruit or fruit-and-nut snack is coated, fried, or glazed using palm oil or a palm-derived agent, that palm fraction can be an in-scope input requiring its own due diligence — even though the fruit itself is exempt.
- Cocoa and coffee coatings or inclusions. A chocolate-coated dried fruit, a cocoa-dusted snack, or a coffee-infused product brings cocoa or coffee — both in-scope commodities — into the recipe.
- Soya-based ingredients. Soya lecithin, soya protein, or soya oil used as a processing aid or binder is a soya derivative and can trigger the obligation.
- Wood and paper contact materials. Where wooden or certain paper-based components fall under the regulation's product scope, the packaging or pallet — not the food — can be the in-scope item.
So the practical rule for a dried-fruit importer is: screen the full bill of materials, not just the fruit. A plain product is very likely outside EUDR; a compound or coated product needs a line-by-line check against Annex I.
| Dried-fruit SKU type | Typical EUDR status (verify per recipe) | Why | | --- | --- | --- | | Plain dried apricot / fig / sultana / mulberry | Generally out of scope | Not one of the seven commodities or their derivatives | | Date with stone or pitted, unprocessed | Generally out of scope | Fruit only; no in-scope input | | Dried fruit fried/coated in palm oil | Palm fraction in scope | Oil palm is a listed commodity | | Chocolate- or cocoa-coated dried fruit | Cocoa fraction in scope | Cocoa is a listed commodity | | Snack mix with soya lecithin/protein | Soya fraction in scope | Soya derivative | | Product shipped on/with in-scope wood packaging | Packaging may be in scope | Wood is a listed commodity |
This is the dividing line that the broader EU market-entry regulatory guide frames at category level; here we apply it specifically to a dried-fruit basket.
EUDR obligations when an ingredient is in scope
If your screening flags an in-scope fraction (most often palm or cocoa in a coated snack), the same three obligations apply as for any EUDR commodity. They are summarised below specifically for a dried-fruit importer acting as the operator — the party first placing the goods on the EU market.
- Deforestation-free. The in-scope input must originate from land not subject to deforestation or forest degradation after 31 December 2020.
- Legality. Production must comply with the relevant laws of the country of production (land use, environment, labour and human rights, anti-corruption, trade and customs).
- Due Diligence Statement (DDS) with geolocation. Before placing the goods on the market, the operator files a DDS in the EU information system (the EUDR module of TRACES), including the geolocation coordinates of every plot of land where the in-scope commodity was produced, plus a risk assessment. A DDS reference number is then generated and travels downstream.
The DDS data requirement is demanding: per the Commission's Information System for the Deforestation Regulation, operators and traders submit electronic statements that include commodity and product detail (CN codes, descriptions, quantities, scientific and common names) and plot-level geolocation with harvest information. For a palm-oil coating, that means tracing the oil back to producing plots — which is precisely why the supplier-data relationship matters more than any single document.
EUDR application dates — hedged, because they have moved twice
Original EUDR application was set for late 2024, then postponed by one year, and then postponed again in late 2025. As the position stands in mid-2026, the main obligations apply to large operators and traders from 30 December 2026, and to micro and small enterprises from 30 June 2027. Because this date has already shifted twice, do not hard-code it into a long-term contract without re-checking the current legal text and the Commission's implementation pages first. The European Commission's deforestation-regulation pages and the EU's official journal (EUR-Lex) are the authoritative sources for the live date.
PPWR: the packaging rules that apply to every dried-fruit shipment
Here is the part that catches importers who decided EUDR did not apply to their plain fruit and stopped reading: PPWR applies regardless. The Packaging & Packaging Waste Regulation governs packaging, not the food inside it, so it reaches every dried-fruit pouch, retail carton, bulk bag, and shipping case placed on the EU market.
What PPWR is and when it applies
Regulation (EU) 2025/40 (PPWR) entered into force in early 2025 and applies from 12 August 2026, replacing the long-standing Packaging Directive across all 27 member states with a directly applicable regulation. Critically, PPWR is not a single switch: it is a rolling series of obligations, with the general framework applying from August 2026 and specific targets — recyclability performance grades, recycled-content minimums, and reuse goals — phasing in through 2030 and out to 2040. The European Commission published implementation guidance and an FAQ in 2026 to support uniform interpretation; you can follow the live status on the Commission's packaging waste pages.
What PPWR asks of a dried-fruit importer
The obligations most relevant to dried fruit and natural snacks are:
- Recyclability by design. Packaging must be designed for recycling, and from defined dates will be graded by recyclability performance. Multi-material laminate pouches — common in dried fruit for moisture and oxygen barrier — are the highest-risk format and need early review.
- Recycled content in plastics. Plastic packaging will have to contain minimum percentages of post-consumer recycled material, phased in over time. Food-contact recycled plastic raises an additional food-safety dimension to confirm with your converter.
- Packaging minimisation. Empty space and over-packaging are restricted; ratios of product to void volume come under scrutiny. Generous secondary packaging on a small retail pouch is a typical exposure.
- Marking and labelling. Harmonised material-identification and sorting labels are required, with defined application dates, so artwork files need a planned update.
- Substances of concern. Limits apply to certain substances in packaging — for food contact this overlaps with existing food-contact-material rules and must be reconciled.
- Extended Producer Responsibility (EPR). EPR registration and fees continue to apply per member state and increasingly tie fee levels to recyclability (eco-modulation).
| PPWR obligation area | What a dried-fruit importer should produce | Highest-risk format to check first | | --- | --- | --- | | Recyclability by design | Design-for-recycling assessment per pack | Multi-layer barrier pouches / metallised film | | Recycled content (plastic) | Recycled-content declaration from converter | Plastic trays, films, lidding | | Minimisation / empty space | Product-to-void ratio justification | Oversized cartons around small pouches | | Marking & labelling | Updated artwork with material/sorting marks | All retail-facing packs | | Substances of concern | Food-contact + PPWR substance declaration | Inks, coatings, adhesives | | EPR | Per-country EPR registration & reporting | All packaging placed on market |
The packaging documentation pack to request from your supplier
Whether packaging is filled at origin or in the EU, ask for a packaging dossier per format, mirroring the discipline of a per-batch COA on the food side:
- Material specification (polymer/film structure, paper grade, weights)
- Recyclability assessment and, where available, a recyclability grade
- Recycled-content declaration (percentage and source) for plastic components
- Food-contact compliance (e.g., Regulation (EC) No 1935/2004 and plastics Regulation (EU) No 10/2011) reconciled with PPWR substance limits
- Declaration of conformity and any harmonised marking artwork
- Confirmation of which legal entity is the PPWR "producer" for EPR purposes
The combined 2026 compliance checklist
Use this as a working checklist. Split it into the EUDR file and the PPWR file, because they are assessed by different logic and, often, different authorities.
EUDR file (per SKU)
- [ ] Bill-of-materials screen — list every ingredient and packaging component against the seven commodities and Annex I CN codes.
- [ ] In-scope flag — mark each fraction in/out of scope (most plain dried fruit: out; palm/cocoa/soya coatings: check).
- [ ] Operator vs trader role — confirm whether you are the first placer (operator, full due diligence) or a downstream trader.
- [ ] Geolocation data — for any in-scope input, obtain plot-level coordinates/polygons and harvest data from the supplier.
- [ ] Legality evidence — country-of-production legal compliance documentation.
- [ ] DDS readiness — TRACES access set up; DDS draft prepared; reference-number flow mapped to downstream customers.
- [ ] Date check — re-confirm the current EUDR application date before contracting.
PPWR file (per packaging format)
- [ ] Material declaration — full structure of every pack and shipper.
- [ ] Recyclability assessment — design-for-recycling review; identify laminate/metallised risk formats.
- [ ] Recycled-content plan — converter declaration; roadmap to upcoming minimums.
- [ ] Minimisation review — product-to-void ratio justified; remove avoidable over-packaging.
- [ ] Labelling/marking — artwork updated for harmonised material and sorting marks.
- [ ] Substance check — food-contact compliance reconciled with PPWR substance limits.
- [ ] EPR registration — confirmed per destination member state; producer entity identified.
- [ ] Date check — confirm which PPWR obligations are live versus phasing in for your formats.
Cross-cutting
- [ ] Supplier qualification — your supplier can produce per-batch food COA and a packaging dossier, with consistent lot/traceability references.
- [ ] Recordkeeping — both files retained for the periods the regulations require, retrievable by lot.
How Arovela's setup supports both files
Neither EUDR nor PPWR is a certificate a supplier simply "has." Both are evidence and traceability exercises, and that is where the day-to-day quality of your supplier relationship decides how painful 2026 becomes.
Arovela exports Turkish natural products including geothermally-dried fruit and natural snacks produced in Türkiye, from a Sındırgı (Balıkesir) facility, with stock held in a warehouse in Solingen, Germany. For an EU importer, the German node shortens lead times and simplifies intra-EU movement, and the underlying quality system — documented under ISO 22000, ISO 9001, and ISO 27001, with a per-batch Certificate of Analysis — gives you lot-level traceability to build supplier-data requests on.
To be precise about scope: Arovela holds ISO 22000, ISO 9001, and ISO 27001. We do not claim organic, BRC, FSSC, or other scheme certificates; where your programme requires one of those, or a specific EUDR/PPWR evidence format, raise it during qualification so the right route is confirmed rather than assumed. What we can support directly is the traceability backbone: consistent lot references, per-batch COA, and a documented quality system that the geolocation, DDS, and packaging-dossier work both regulations require can be attached to. Current grades, formats, and quote requests are handled through our wholesale page.
Frequently asked questions
Does EUDR apply to dried apricots, figs, or sultanas?
On a strict reading, plain dried apricots, figs, sultanas, mulberries, and dates are not in EUDR scope, because they are not among the seven relevant commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood) or their listed Annex I derivatives. The catch is the finished recipe and packaging: if a product is coated or fried in palm oil, dusted or coated in cocoa, bound with soya ingredients, or shipped with in-scope wood packaging, that fraction can fall under EUDR even though the fruit itself does not. Screen the full bill of materials per SKU rather than assuming the whole product is exempt.
When do EUDR and PPWR actually apply in 2026?
PPWR (Regulation (EU) 2025/40) has a general application date of 12 August 2026, with further targets phasing in over later years. EUDR's main obligations apply to large operators and traders from 30 December 2026 and to micro and small enterprises from 30 June 2027, following a second postponement adopted in late 2025. Both timelines have moved, so always re-confirm the live dates on EUR-Lex and the European Commission's pages before drafting a contract clause.
What is an EUDR Due Diligence Statement and who files it?
A Due Diligence Statement (DDS) is an electronic declaration filed in the EU information system (the EUDR module of TRACES) by the operator — the party first placing the in-scope goods on the EU market — confirming the product is deforestation-free and legally produced. It must include commodity and product detail and the plot-level geolocation of where the commodity was produced, plus a risk assessment. The system generates a DDS reference number that travels downstream; subsequent traders rely on and pass it on rather than re-filing from scratch.
Does PPWR apply even if my dried fruit is outside EUDR?
Yes. PPWR governs packaging, not the food inside it, so it applies to every dried-fruit pouch, carton, bulk bag, and shipping case placed on the EU market regardless of whether the fruit is in EUDR scope. This is why importers who conclude that EUDR does not touch their plain fruit still need a full PPWR file covering recyclability, recycled content, minimisation, marking, substance limits, and EPR registration for each packaging format.
What packaging changes should dried-fruit importers prioritise first?
Start with multi-layer barrier pouches and metallised films, which dried fruit relies on for shelf life but which are the hardest to make recyclable and therefore the highest PPWR risk. Next, review over-packaging — oversized cartons around small retail pouches will be exposed by minimisation rules. Then plan recycled-content sourcing for plastic components and update artwork for harmonised material and sorting marks. Confirm your EPR registration per destination member state, and reconcile food-contact-material compliance with PPWR substance limits.
What should I ask a Turkish dried-fruit supplier to provide for compliance?
Request two parallel evidence packs per lot. On the food side: a per-batch Certificate of Analysis, an SDS where relevant, country-of-origin and phytosanitary documentation, and — for any in-scope coating or inclusion — supplier geolocation and legality data for a DDS. On the packaging side: a packaging dossier per format with material specification, recyclability assessment, recycled-content declaration, food-contact compliance, and clarity on the PPWR "producer" entity for EPR. A supplier with a documented quality system (for Arovela, ISO 22000/9001/27001) and consistent lot traceability makes both requests far easier to fulfil.
Build your 2026 compliance file with a traceability-ready partner
EUDR and PPWR will not be solved by a single certificate; they are won with clean data — screened bills of materials, plot-level geolocation where it is genuinely needed, recyclable-by-design packaging, and lot-level records you can retrieve on demand. The importers who start the two files now, rather than in the final 30 days before each date, will treat 2026 as a routine update instead of a fire drill.
Arovela supplies geothermally-dried fruit and natural snacks from a Sındırgı (Balıkesir) facility with a Solingen, Germany warehouse for short EU lead times, backed by ISO 22000, ISO 9001, and ISO 27001 documentation and per-batch COA. Tell us your SKUs, your packaging formats, and your destination markets, and we will align the documentation to your EUDR and PPWR checklists. Contact the Arovela team or request grades and a quote through our wholesale page.