What is the European Deforestation Regulation (EUDR) and how will it affect your business?
Background and scope
As a major economy and consumer of commodities, the EU wishes to reduce its environmental impact by promoting ‘deforestation-free’ products. It therefore developed Regulation (EU) 2023/1115 on deforestation-free products (also known as EUDR) to guarantee that the products EU citizens consume, do not contribute to deforestation or forest degradation worldwide.
The EUDR covers 7 commodities and some of their derived products. Wood is one of the 7 commodities in scope, which means that pulp, paper, board, but also printed products are included. Consequently, for security printing, items such as postage and excise stamps, certificates and paper-based identity documents fall under the scope of the EUDR as well.
As the representative of the European printing industry, Intergraf[1] closely monitors these developments, offering regular updates and practical guidelines to the industry. Additionally, Intergraf constantly advocates for the industry's best interests towards the European Institutions.
Objectives and obligations of EUDR
The new rules aim to avoid that the listed products Europeans buy, use, and consume contribute to deforestation and forest degradation in the EU and globally, and at the same time reduce carbon emissions caused by EU consumption and production of the relevant commodities by at least 32 million metric tonnes a year.
Relevant products in scope, including paper, board, and printed products, shall not be placed, or made available on the European market or exported, unless they are deforestation-free. To prove this, these products must be compliant with EUDR and covered by a due diligence statement.
The EUDR impacts both EU printers and non-EU printers who deliver to the EU market. EU printers will have to comply with the EUDR, not only when importing paper/board from third countries but also when using paper/board originating from the EU. EU printers not only have obligations when placing printed products on the EU market, but also when exporting printed products outside the EU. Non-EU printers who deliver to the EU market must provide the same level of detailed information on the origin of the paper/board to their EU customer, as the latter will have the obligation to exercise due diligence.
The due diligence obligation is one of the pivotal points of the EUDR: every company manufacturing or trading paper or printed products must ensure traceability back to the specific plot of land where the wood pulp fibres originated. The due diligence statement requires the collection of the exact geographic coordinates for each plot involved plus other information, documents and data which demonstrate that the relevant products are deforestation-free. The due diligence also includes risk assessment and risk mitigation measures. The obligations of the different actors along the value chain depends on their size, activity, and position in the value chain.
Implementation and timeline
The Regulation entered into force on 29 June 2023 and repeals the former EU Timber Regulation (EUTR). Under the EUDR, any operator or trader who places these commodities on the EU market, or exports from it, must be able to prove that the products do not originate from recently deforested land or have contributed to forest degradation. Operators and traders will have until 30 December 2025 to implement the new rules; micro and small enterprises are granted a longer adaptation period (30 June 2026), as well as other specific provisions.
While the legislation has been adopted, a lot of preparation is still required by all sectors impacted by the Regulation ahead of the deadline (December 2025) as implementing the EUDR requires a significant increase in administrative work for the affected companies.
To help our industry navigate these regulatory complexities, Intergraf has drafted a guidance document for its members (and their member companies). To receive it, please send a message to your national printing federation or lreynaud@intergraf.eu.
Sign up for Intergraf’s monthly Newsflash if you want to stay up to date on the developments of EUDR and other industry-relevant EU legislative initiatives.
[1] Intergraf represents the European printing industry, gathering 22 national printing federations in 21 countries in Europe. The printing industry provides jobs to more than 625,000 Europeans active in 112,000 companies and generates a turnover of approximately € 79.5 billion. The industry throughout Europe consists of small enterprises, as 90% of them employ fewer than 20 persons.