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.

Roadmap for reducing carbon emissions in the printing industry

Background and roadmap

The European Green Deal set the ambitious objective of transforming Europe into "the world's first climate-neutral continent" by 2050. At its core lies the commitment to mitigate climate change through comprehensive policy initiatives and collaborative efforts. All sectors are called upon to collectively contribute to reducing emissions and every facet of the economy will need to undergo transformational changes to align with the overarching climate goals. So is the (European) printing industry which has a long history of complying with environmental restrictions and legislation.

Legislation at both the European and national levels will increasingly require the assessment of carbon footprints for products and processes, as well as environmentally conscious decision-making. In addition to these regulatory demands, there is a rising trend of customer preference for products with strong carbon credentials.

Intergraf[1] has been working on recommendations for CO2 calculation in the graphic industry for close to 15 years and has more recently developed an approach to support printing companies and print buyers in their efforts to prioritise and reduce CO₂ emissions related to printed products in the most efficient way.

Methods, tools, and parameters

The Intergraf approach encompasses two crucial components: the Intergraf Recommendations on CO2 emissions calculation and the Intergraf Roadmap on CO2 calculation, reduction, and compensation in the printing industry. While the first provides a standard on what to take into consideration when calculating carbon emissions for our industry, the second offers a concrete procedure to printers as well as print buyers to categorise parameters that influence carbon emissions and to prioritise emission reduction measures.

The printing sector consists mostly of small or micro enterprises in need of a simple model which is easily applicable to their activities. Even though there are numerous tools available on the market to calculate the carbon footprint of a product or a company, the print industry disposes of their own practical calculation tools: www.climatecalc.eu & www.klima-druck.de. Both are based on the Intergraf Recommendations.

These were created by printing industry experts specifically for the printing industry and its products. Moreover, both tools can provide the calculations for the entire company or for a specific print product.

The Intergraf Recommendations point out 13 parameters to be included in the CO₂ calculation to cover minimum 95% of the emission within the defined scope. Furthermore, they categorise the 13 parameters into site relevant parameters related to the printing company and product relevant parameters related to the design of the printed product. The categorisation into parameters related to the printing company and the design of the printed product is essential for the prioritisation of the activities for the reduction and compensation in the life cycle of the printed product.

In addition to being industry-specific, the Intergraf Recommendations represent a neutral and credible approach as they cover the 3 scopes of the Greenhouse Gas Protocol. Scope 1 encompasses all direct emissions, while Scope 2 addresses indirect emissions associated with energy consumption. Scope 3 includes all other indirect emissions throughout the supply chain. In the printing industry, Scope 3 is particularly crucial for calculating the carbon footprint, as it accounts for over 70% of total emissions, with substrate production being the primary contributor.

The printer manages site-specific factors like minimising energy use, whereas the print buyer determines the design specifications, making them the key decision-maker for substrate choice. To effectively lower emissions, it is important for the printer and print buyer to engage in a collaborative dialogue.

The Intergraf Recommendations have received international recognition with their inclusion in the ISO 16759:2013 standard on the quantification and communication for calculating the carbon footprint of print media products.

In the Publishing 2030 Accelerator's CO2e emissions calculation for printed books, the International Publishers Association (IPA) acknowledges the Intergraf Recommendations as the preferred method for evaluating the carbon footprint associated with the printing process of a book.

Conclusions and way forward

The Intergraf Roadmap concludes that there are two main ways to reduce the carbon footprint in the printing sector: implement energy efficiency measures and optimise the substrate. Moreover, it demonstrates that both printers and print buyers are crucial in the carbon reduction strategy in the printing industry.

Looking ahead, Intergraf anticipates that the carbon footprint will remain a top priority in 2024 and the years to come. By actively promoting sustainable practices, working with international associations and partners, and offering valuable resources, Intergraf has earned recognition for its crucial role in advancing sustainability in the graphic industry and remains committed to fostering meaningful change in the printing sector.

In an era where sustainability is paramount, our industry shows its capacity to adapt, reinforcing its resilience and seizing new opportunities.

• For more details, feel free to visit https://www.intergraf.eu/policy/environment/carbon-footprint.

• Sign up for Intergraf’s monthly Newsflash if want to stay up to date on the European Green Deal and other industry-relevant EU legislative initiatives.

Sources:

2021_Intergraf recommendations on CO2 emissions calculation in the printing industryREV

202203_Intergraf_Roadmap_CarbonFootprint

202404_Brochure_Carbon footprint

https://www.intergraf.eu/images/pdf/ActivityReport_2024.pdf page 10

https://www.intergraf.eu/images/pdf/ActivityReport_2023_spread.pdf pages 13-14

[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.

Impact of EES and ETIAS on the Identity Industry

Background

The United Nations World Tourism Organization (UNWTO) estimated that the number of international tourist arrivals have reached a 56-fold increase over the last 70 years. The UNWTO states that Europe accounts for 50% of the world’s tourist arrivals, making it the most visited region in the world before the Covid-19 crisis. 

 The Schengen Area is a border-free zone currently consisting of 29 countries[1] and remains one of the European Union (EU)’s great success stories. The area guarantees freedom to travel without border controls at its internal borders as well as harmonised rules for external border checks. Borderless travel between 25 EU and four non-EU states (Iceland, Lichtenstein, Norway, and Switzerland) has transformed the offer of multi-country itineraries enjoyed by long-haul visitors in particular. There are also visa and document requirements for non-EU citizens visiting the Schengen Area for short-term tourism, family visits, business, or other purposes.

EES and ETIAS explained

To ensure consistent and reliable border control across the Schengen Area, the EU developed the Entry/Exit System (EES), a standardised digital system for registering non-EU travellers using biometric data. Originally set to launch in 2021, the EES faced delays due to technical and contractor challenges and is now scheduled for phased rollout starting in October 2025, alongside new tools for biometric checks.

The EES, along with the upcoming European Travel Information and Authorisation System (ETIAS), is part of a broader strategy to strengthen the Schengen Area. These systems support the European Security Union and aim to enhance border management, combat cross-border crime, and contribute to the goals of the European agendas on Security and Migration.

The European agency eu-LISA is in charge of developing and managing the system, which supports EU border control, law enforcement, migration & asylum, and future judicial cooperation. For the shared Biometric Matching System (sBMS), eu-LISA selected Idemia[i] as the lead contractor.

EES

The Entry/Exit System (EES) is a new European Union automated IT border control system, impacting how both travellers and authorities manage border crossings and is part of the EU's broader effort to modernise and strengthen its external borders. The system will be used for registering third-country nationals (TCNs), both short-stay visa holders and visa exempt travellers, each time they cross an EU external border. It will enable a wider use of automated border control checks and self-service systems, which are quicker and more comfortable for the traveller. They will also help border agents flag security and compliance risks for those entering and exiting.

Who is affected?

Non-EU nationals travelling for a short stay to a European country using the EES.

Exemptions apply: see To whom does the EES not apply?

Travellers will be required to submit fingerprint and face biometrics on their first crossing of Schengen borders. These will be stored with additional personal data in the central EES system for up to 5 years; subsequent EES crossings will only require a  face or fingerprints biometric verification against enrolled biometric data. Self-service kiosks assist with the acquisition of biometric data during initial registration or upon re-entry, thereby reducing the workload at border control counters.

The EES will replace manual passport stamping, track entry refusals, and help prevent irregular migration. It will enhance security, streamline travel for legitimate third-country nationals, and improve the identification of overstayers—those who exceed the 90-day limit for short stays in the Schengen Area. The system will also more effectively detect document and identity fraud, while enabling real-time information sharing to ensure EU border authorities have accurate data when needed.

The future EU-EES will comprise of:

• Central Systems for the overall management including a computerised central database of biometric and alphanumeric data owned and managed by eu-LISA
• A National Uniform Interface and a Secure Communication Channel through which each country will exchange traveller movement information with the Central System, including the information systems already deployed (SIS, VIS, EURODAC etc.)
• A web portal for third country nationals (TCNs) to check their allowed duration of stay in the Schengen Area at any time
• An interface for carriers to verify whether the number of entries authorised by a visa

Biometric information will not be stored directly in the EU-EES Central System, but in a European automated matching system: the Shared Biometric Matching System (sBMS). This system will securely store the biometric information and will oversee travellers’ authentication and identification for all European border crossing points using its biometric search and matching capabilities.

Conditions for collecting and storing personal data in the EES are set out in Regulation (EU) 2017/2226 establishing the Entry/Exit System.

Soft Opening planned in October 2025

Rather than implementing the Entry/Exit System (EES) simultaneously at all external EU borders, the so-called "big bang" approach, a gradual rollout is now scheduled to begin in October 2025. This phased introduction will allow Member States to connect their border control points to the EES over several months.

During this period, initial traveller registration may be conducted temporarily without collecting biometric data. This soft launch will give national border authorities the flexibility to address any unforeseen issues with border control systems, national interfaces, or the central EES system, helping to minimise disruptions to the overall travel process.

Key challenges

• Privacy and data security: both companies and governments are focusing on ensuring that the vast amount of biometric data collected is securely stored and protected from potential cyber threats.
• Operational delays: travel infrastructures and especially airports, seaports and border authorities will need to adapt their control procedures. There is concern about potential delays at border crossings, particularly during the initial phase of implementation. Efforts are being made to streamline processes to minimise these delays.

Overall, the preparation for the EES involves significant investment in technology, training, and public communication to ensure a smooth transition to this new border management system. The traveller experience is central to the solution, but it is also necessary to consider the needs of the other stakeholders: border control authorities and facility operators such as airports. 

ETIAS

About six months after the full implementation of the EES, the European Travel Information and Authorisation System (ETIAS) will be introduced. Similar to the Australian ETA and US ESTA, ETIAS is a travel authorisation for non-EU citizens who do not need a visa to enter the Schengen Area.

Under the ‘90-day rule,’ non-EU nationals can stay up to 90 days within a 180-day period in Schengen countries without a visa. However, after ETIAS is implemented, they will need to apply for a €7 travel authorisation. This change adds a mandatory application process but does not alter the 90-day stay limit. It is hoped that the visa waiver will help improve the detection of human trafficking, particularly in the case of minors, and help tackle cross-border criminal activity.

How long does it take to apply for the ETIAS visa waiver?

The process will be mostly automated and should take no more than 10 minutes to complete. An applicant will need to provide passport details, travel information, and answer basic security questions. The visa waiver will be issued within minutes of payment, but travellers are advised to apply at least 72 hours before they need it, just in case of any delays.

Once the application has been approved, the electronic travel authorisation will be electronically linked to the traveller’s passport and will last for three years for an unlimited number of entries. After three years, the ETIAS visa waiver process will need to be repeated for further travel in the EU.

What steps should those in the affected sectors take?

To keep pace with evolving digital regulations, businesses in impacted sectors must adjust to the growing digitisation of processes—particularly in areas like border management. Entry bans can significantly disrupt both travel and business operations, making proactive planning essential.

Frequent travellers to the Schengen Area should remain informed about changing requirements, such as the ETIAS application and rules for tracking travel days in ETIAS-participating countries. Accurately calculating these days and understanding related obligations is critical.

Ensuring that data submitted to authorities matches the traveller’s actual information is vital. While access to this data is currently limited to immigration, visa, law enforcement, and border control agencies, other bodies, such as tax and social security authorities, may be granted access in the future. Leveraging technology to track travel dates, organise important documents, and set alerts for document expirations can enhance compliance and minimise potential risks.

Technology must be precise, and it is essential to establish how to measure biometric quality. However, accuracy and quality are not the only critical factors. We must also prioritise data protection, compliance with regulations, and the safeguards in place. Equally important are the procedures to follow, as well as training that demonstrates how the technology works—clarifying what it can and cannot do, and what it is permitted to do.

 It is important to find a balance between the rapid pace of technological advancement and the time needed to fully understand and adapt to these changes and associated risks. We must ensure there's sufficient time to regulate what needs to be regulated.

    Javier Galbally, R&I Engineer, eu-LISA

For the foreseeable future, physical ID documents are here to stay. They incorporate various security features, like watermarks and holographic images, which currently do not yet have a counterpart in the virtual world. Moreover, there is still a lack of national IT infrastructures to support the widespread adoption of digital identities, as well as a lack of international standards for their global implementation. As a result, the passport—our primary identity document—will continue to exist in its current form for the time being.

The future could be biometric

The European Union's pilot project for biometric corridors at airports offers a glimpse into a future without physical passports. In this scenario, passengers check in online before arriving at the airport. Instead of presenting their passport at a traditional border checkpoint, they walk through a biometric corridor, where advanced camera systems verify their identity by matching their pre-registered passport and biometric data with the information stored in a database and passenger manifest.

Ideally, the process is seamless, enabling travellers to pass through security without even realising a check is taking place. All relevant passenger information is sent directly to the border authorities at the destination, eliminating the need for additional checks upon arrival and ensuring a smoother, more efficient and enjoyable travel experience.

[1] 29 Countries are in the Schengen Area – Austria, Belgium, Bulgaria, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland.

Sources

• Entry/Exit System factsheet
• Technical study on Smart Borders – final report
• Executive Summary of the Impact Assessment Accompanying the EES Regulation
• Smart Borders Pilot Project - Report on the technical conclusions of the Pilot
• https://travel-europe.europa.eu/key-differences-between-etias-and-ees-2023-06-06
• https://www.fragomen.com/insights/preparing-your-business-for-upcoming-schengen-area-developments-considerations-and-action-items.html
• https://www.businesstravelnewseurope.com/QA/Getting-to-grips-with-increasingly-digitalised-borders
• https://home-affairs.ec.europa.eu/policies/schengen-borders-and-visa/smart-borders/entry-exit-system_en
• https://travel-europe.europa.eu/ees_en
• https://regulaforensics.com/news/42-percent-of-companies-ready-to-adopt-digital-id/?utm_source=linkedin&utm_medium=social&utm_campaign=post&utm_content=05222024
• https://www.biometricupdate.com/202408/eu-biometric-entry-exit-system-launch-date-confirmed-for-november-10
• https://www.biometricupdate.com/202410/eus-ees-delayed-again-border-crossings-still-lack-equipment
• https://www.biometricupdate.com/202411/imars-conference-reveals-details-on-the-ees-pre-enrollment-app
• https://www.biometricupdate.com/202412/eu-announces-phased-approach-for-ees
• https://aviationweek.com/air-transport/digital-ids-transform-future-passenger-travel-experience
• https://dig.watch/updates/eu-set-to-implement-entry-exit-system-for-border-control
• https://www.biometricupdate.com/202503/eu-council-sets-out-progressive-launch-of-landmark-ees-biometric-border-management-system
• https://identityweek.net/ees-will-intensify-travel-rules-from-october-whilst-impact-on-etias-delay-prompts-fraud-warnings/
• https://idtechwire.com/id-talk-eu-lisa-ri-engineer-javier-galbally-talks-biometrics-privacy-and-the-ees/
• https://www.idemia.com/our-vision-eu-entryexit-system
• Frank Steffens, Product Management, secunet Security Networks AG

[i] Idemia’s five key recommendations for effective border control

• Optimise border guard efficiency: implement self-service desks, automated biometric eGates, and operational supervision tools to enable border guards to focus on high-value tasks

• Ensure reliable biometric data: collect and verify biometric data in diverse border environments by working only with top-tier, NIST-certified suppliers.

• Leverage data for risk analysis: use Advanced Passenger Information (API) and Passenger Name Record (PNR) data to analyse travel risks ahead of arrival. Integrating this with visa, ETIAS, and national interest lists enhances border security insights.

• Tailor solutions to border needs: adapt solutions to each border's unique requirements, considering differences between air, land, and sea borders. Member States must deploy varied verification equipment to meet specific demands.

• Guarantee data security and privacy: ensure GDPR-compliant systems that secure biometric and personal data throughout its lifecycle, including robust access controls, user privilege management, and encryption.

UPDATE: What is the EUDR and how will it affect your business?

Background and scope

Things have changed since we last published our article on EUDR on 17 December  2024. Extensive industry negotiations resulted not only in a one-year extension to the entry into application of the Regulation, but also in a simplification of the requirements down the supply chain and a review clause by 30 April 2026 to explore further simplification measures.

But most importantly for us, printed products classified under HS 49 are no longer included in the scope of the EUDR. As a result, most finished printed products, including security printing items such as postage and excise stamps, certificates and paper-based identity documents, are no longer directly subject to EUDR obligations.

For the printing industry, and security printers in particular, the EUDR is therefore only relevant when EUDR-covered materials are imported or placed on the market, such as paper, board or other wood-based inputs that fall under HS 48.

Objectives and obligations of EUDR

EUDR aims to ensure that products consumed in the EU do not contribute to deforestation or forest degradation, while also reducing greenhouse-gas emissions linked to EU consumption and production of the covered commodities by at least 32 million metric tonnes per year.

The EUDR covers seven commodities and some of their derived products, including wood. Within this framework, pulp, paper and board (HS 48) are within the scope of the Regulation and may therefore not be placed on, made available on the EU market unless they are deforestation-free and covered by a valid due-diligence statement.

When printers import the above-mentioned material, they must ensure compliance with EUDR for the material inputs, even if the final printed product is not covered. Non-EU suppliers of EUDR-covered materials must provide EU customers with the necessary information to enable compliance with due-diligence obligations.

The due-diligence obligation remains a key element of the EUDR for companies dealing with covered materials. Any company placing paper, board or other in-scope wood-based products on the EU market must ensure full traceability back to the specific plot of land where the wood originated.

Implementation and timeline

The Regulation entered into force on 29 June 2023 and repeals the former EU Timber Regulation (EUTR). Operators and traders dealing with EUDR-covered commodities and products, such as paper and board, must comply with the new rules by 30 December 2026.

To help our industry navigate these regulatory complexities, Intergraf is at your disposal for questions and requests of clarification from its members (and their member companies). If you have questions, please send a message to your national printing federation or to 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.

The weakest link: why breeder documents matter

Europe has invested heavily in making its passports among the most secure documents in the world. Yet the process of obtaining one often begins with a piece of paper that looks much as it did a century ago. That paradox sits at the heart of a growing conversation in the identity community, and addressing it is far overdue.

What is a breeder document?

Foundational identity is the starting point for everything that follows in an individual's civic life. Before a person can hold a passport, open a bank account or exercise their legal rights, there must first be a record that they exist, and that record is most commonly established through a birth certificate. It is when  a birth certificate is presented to support an application for a higher-value identity document, that it takes on a specific and consequential role: it becomes a breeder document. The term captures the function precisely, it is the document upon which further identity is bred, the foundation from which passports, residence permits and other credentials are issued.

The European Union defines breeder documents as "documents used to support applications for identity, residence and travel documents, such as birth, marriage and death certificates." The birth certificate occupies a unique position within this category: it is typically the very first document that anchors an individual to the legal and civil world, and it is on this basis that the entire subsequent chain of identity is constructed. Article 6 of the Universal Declaration of Human Rights recognises the right to be acknowledged as a person before the law, while Article 7 of the Convention on the Rights of the Child enshrines the right to birth registration. For most people in the developed world, these protections are invisible and taken for granted. For more than one billion people globally, roughly one in eight, they remain out of reach.

The significance of this gap is reflected in the UN Sustainable Development Goals. Target 16.9 calls for legal identity for all, including birth registration, by 2030. Meeting it requires taking not just the absence of civil registration in underserved regions seriously, but also the quality and integrity of civil registration everywhere.

The passport success story, and its blind spot

The story of the modern travel document is one of extraordinary achievement. Since ICAO began its work on machine-readable travel documents in the late 1960s, successive generations of standardisation have produced a genuinely global system. Today's biometric ePassport, with its chip-stored fingerprints and facial images, its cryptographic security protocols and its compatibility with automatic border control gates, represents decades of painstaking technical collaboration.

That achievement has, however, exposed a structural vulnerability. The ePassport is only as trustworthy as the process that produces it, and that process begins with breeder documents. Because forging an ePassport has become so technically demanding, fraudsters have shifted their focus to the entitlement process: obtaining genuine documents on the basis of false or fraudulent breeder documents. Identity theft and the use of counterfeit birth certificates to obtain legitimate passports is now a well-documented phenomenon.

The gap that remains

Across most European countries, and indeed the world, breeder documents remain largely paper-based, without standardised formats, security features, or issuance processes. An administrative officer presented with a foreign birth certificate may have no reliable way to assess its authenticity. Where civil registries have been digitised, cross-border and even cross-agency verification is often blocked by technical incompatibilities or legal constraints. In many countries, standards for breeder documents vary not just between states but within them.

The result is a chain of trust with a weak link at the very beginning. Highly secured downstream documents and sophisticated border systems rest, ultimately, on a foundation that has not kept pace with the security standards applied to what it supports.

Why this matters to our community

For the security printing and identity industries, this is not an abstract policy concern. It directly affects the integrity of the issuance processes that underpin the documents and credentials produced and verified every day. Strengthening breeder documents means strengthening the entire identity chain, and opening new opportunities to apply the materials, processes and expertise that the industry has developed for high-security travel documents to an adjacent and growing area of need.

The next article in this series examines the active European standardisation efforts underway to address precisely these challenges.

Author: Stephan D. Hofstetter, Editor of CEN prTS 17489-5 and Managing Partner of SECOIA Executive Consultants AG, updated for Noted. by Intergraf.

Raising the bar: new framework sets higher standard for government identity document security

This unique and collaborative international endeavour between industry, forensic and secure document experts provides a practical roadmap to creating robust and secure identity documents intended for issuing authorities and policymakers.

Best practice guidelines and minimum security standards for identity documents: recommendations for advanced document design and integration of security features

At a time when the sophistication of counterfeit credentials poses an escalating threat to public safety and national security, the Document Security Alliance (DSA), INTERGRAF, and the Secure Identity Alliance (SIA) are pleased to announce the publication of our best-practice guidelines for Identity Documents.

The publication comes against a backdrop of serious and growing concern. Counterfeit identity documents are now pervasive across Europe, North America, and beyond — facilitating identity theft, financial crime including money laundering, worksite enforcement violations, and immigration-related offences such as human smuggling and trafficking.

Fraudulent credentials are also actively exploited by individuals connected to organised criminal networks, including international terrorist groups, to reduce scrutiny at travel screening and border control. The paper's authors are unequivocal: the threat is not abstract. It is active, adaptive, and escalating.

A practical guide, not an encyclopaedia

Passports, national identity cards, driver's licenses, and other government-issued credentials are woven throughout the structure of modern civic and economic life; enabling citizens to cross borders, open bank accounts, board aircraft, access healthcare and receive numerous other essential government services. For government officials that bear responsibility for the integrity of the credentials they issue, the Best Practice Guidelines and Minimum Security Standards for Identity Documents is an actionable tutorial for going well beyond today’s existing minimum standards to create a truly secure document.

The paper is explicitly designed as a guide to concepts, principles, and decision-making — focused on the "why" and "how" rather than exhaustive technical specifications. It acknowledges directly that not all technologies are equal: laser engraving, for example, offers a level of durability and tamper resistance that thermal personalization cannot match, and authorities with the means to adopt superior technologies should do so. But it also recognizes the realities of long procurement cycles, constrained budgets, and the time required for transition — and offers guidance on extracting the maximum security benefit from current tools while planning for future uplift.

An invitation to raise the standard

The framework is grounded in both established best practice and the practical realities facing issuing authorities worldwide. It is offered, in the authors' own words, not as criticism of current practice, but as an invitation: to examine existing standards honestly, identify where improvements are achievable, and commit to a trajectory of continuous improvement.

Governments are continually under pressure to define security, technical, and design requirements that are financially sustainable and genuinely effective — keeping their documents ahead of counterfeiters who are rapidly closing the gap. This paper aims to show what a higher standard looks like in practice, and how every issuing authority can aspire to it.

See the guideline document here.

See the press release here.

Building a standard: Europe's response to the breeder document challenge

Recognising a problem is one thing. Doing something about it in a structured, internationally credible way is quite another. But in the case of breeder documents, Europe has been doing exactly that. Through one of the continent's most established standardisation bodies, it is producing a technical specification that could reshape civil registration for generations.

The body behind the work

The European Committee for Standardization (CEN) is the recognised body for developing voluntary standards across Europe. Its members are the national standardisation bodies (NSBs) of 34 European countries. Beyond these, CEN Partners include non-European NSBs and European organisations, giving the body a reach that extends well beyond the continent's borders. CEN’s Technical Committee 224 (TC224) covers Personal identification, electronic signature and cards and their related systems and operations,  the institutional home of much of the expert knowledge that has shaped identity documents across Europe and beyond. It was within TC224 that Working Group 19 (WG19) was established to lead standardisation activities specifically in the field of breeder documents. The first WG19 meetings took place in March 2017 in Oslo.

As of March 2024, WG19 counted 43 registered members drawn from Austria, Belgium, Finland, France, Georgia, Germany, Iceland, Luxembourg, the Netherlands, Norway, Spain, Switzerland and the United Kingdom, alongside representatives from ANEC and ETSI. The group meets quarterly and its membership reflects the cross-sectoral nature of the challenge: it brings together public sector officers – civil registration authorities, government identity specialists, and border management professionals – alongside subject matter experts from private industry, all participating in their individual expert capacity rather than as representatives of their organisations.

What the standard covers

WG19 is developing the CEN Technical Specification series TS 17489, titled Secure and Interoperable European Breeder Documents. Its scope covers birth certificates, marriage and partnership certificates, and death certificates, along with the management processes associated with them: registration, issuance, renewal, verification, and revocation. The specification is designed to remain independent of specific technologies: it does not aim to impose a single form factor but instead, focuses on strengthening the issuance processes and their oversight.

The series is structured across five parts. Part 1, published in 2020, establishes the overall framework: common terminology, definitions, and an informative overview of the architecture to follow. Part 2, published in 2023, defines an abstract data model for breeder document data. It provides a semantic description of the information contained in birth, marriage and death certificates, designed to be both extensible and independent of any specific encoding format. As a result, it can be applied to documents regardless of whether they are paper-based, server-based or hardware-based.

Part 3 addresses the basic technologies: a visual electronic seal using a two-dimensional barcode for offline authenticity verification; a contactless chip and associated file structure for digital breeder documents; and detailed physical document specifications covering material features, security printing techniques, copy protection and personalisation methods.

At the time of writing, the working group was evaluating existing technology frameworks to determine their suitability for adoption, rather than creating new solutions when proven alternatives already exist. Frameworks under consideration include those developed by ICAO for travel documents, the European Digital Product Passport, eIDAS framework and ISO 18013, the international standard for mobile driving licences. The aim is to draw on established, interoperable approaches wherever appropriate, avoiding fragmentation and ensuring coherence with adjacent identity ecosystems.

Part 4 translates these building blocks into concrete profiles for each certificate type, enabling genuine interoperability across administrations and borders.

Part 5, published in 2024, addresses trust establishment and management. This is where the standard expands beyond the document itself to consider the institutional and procedural environment in which breeder documents are generated and used – a recognition that technology alone cannot solve a problem rooted partly in process and governance.

Alongside the TS 17489 series, WG19 is also contributing to the development of an updated version of DIN 91379, Characters and Defined Character Sequences in Unicode for the Electronic Processing of Names and Data Exchange in Europe. Originally a German national standard, DIN 91379 defines the normative subset of unicode characters and character sequences required for the correct electronic representation of personal and legal names across European languages and scripts, including Latin letters with diacritics, transliteration mappings for non-Latin scripts, and the character sets covering all EU official languages as well as those of Iceland, Liechtenstein, Norway and Switzerland.

The group is working to elevate this to an international standard, a step that would benefit TS 17489 directly – accurate and interoperable name rendering being a foundational requirement for any breeder document data model – while also serving the broader ecosystem of identity, civil registration and border management systems that face the same challenge of handling multilingual names reliably across jurisdictions.

Connecting to the global picture

WG19 does not operate in isolation. It maintains a formal liaison with TC224/WG18, which focuses on biometrics, and the two groups coordinate their meeting schedules to capitalise on synergies—particularly important given the complexities of capturing biometric data for infants and children in civil registration. Beyond Europe, WG19 engages actively with the UN Legal Identity Expert Group (LIEG) and with organisations across Africa, Oceania, and the Pacific, with the explicit goal of gradually incorporating additional regions. The intention is not to impose a European model, but to draw on the unique traditions, requirements and successful practices of different regions, ensuring the standard embodies a truly global range of experience.

At global level, this work aligns with ICAO's Traveller Identification Programme (TRIP), particularly the ICAO Guidance on Evidence of Identity. A revised edition of this guidance is currently in development and has already obtained conceptual approval from the ICAO Technical Advisory Group (TAG). The update is expected to explicitly reference CEN prTS 17489-5. WG19 members are also participating in a dedicated subgroup of the ICAO ICBWG responsible for drafting the new Evidence of Identity Guide, establishing a direct link that ensures the European standard can both inform and gain recognition within the wider international framework.

Expertise in action

For security printers and identity document specialists, the TS 17489 series represent familiar territory seen from a new angle. The specification calls on exactly the kinds of materials science, security printing expertise, chip integration knowledge and process assurance methodology that underpin high-security travel documents. The challenge is to apply these capabilities to a document category that has historically sat outside the industry's core focus – and to do so in a way that respects the diversity of civil registration traditions across European member states.

Yet perhaps the most distinctive challenge here has no real parallel in the world of travel documents: the technology must function reliably across highly independent administrations and, critically, over the potential span of a human lifetime. A passport is valid for ten years; the cryptographic framework underpinning it may be refreshed within a similar cycle. A birth certificate, by contrast, may need to be verified eighty or ninety years after it was issued, by systems and administrations that did not exist when it was created. Consider the gulf between the data recording and secure storage technologies available a century ago and those we rely on today – and then consider that the standards being written now must anticipate an equivalent leap in the other direction. The emergence of post-quantum computing alone presents a challenge that cannot be deferred: cryptographic approaches considered robust today may be vulnerable within years, not decades.

Designing a framework that is both technically credible now and structurally resilient over a human lifetime is a genuinely novel problem for the identity industry, and one that makes this standardisation effort as intellectually demanding as it is consequential.

Technology alone, however, cannot carry the full weight of this challenge. A framework that must remain coherent across independent administrations and over the span of a human life requires something more durable than any cryptographic standard: a foundation of trust and policy. A third article in this series explores precisely that – the governance architecture that Part 5 of TS 17489 provides, and why it may prove as consequential as the technical specification it accompanies.

Author: Stephan D. Hofstetter, Editor of CEN prTS 17489-5 and Managing Partner of SECOIA Executive Consultants AG, updated for Noted. by Intergraf.

Trust, policy, and the road ahead for breeder document standardisation

Reliable technology is an essential element of trust – but not a sufficient one. Cryptographic standards are superseded, storage technologies become obsolete, and the institutions of today will not be those of fifty years from now. What gives a breeder document its long-term credibility is the integrity of the data it contains and the reliability of the process behind it. Policy and a trust framework must therefore address what technology alone cannot, ensuring confidence in the data and processes while mitigating the technical limitations that will inevitably arise over a document's lifetime. Part 5 of the TS 17489 series is CEN’s answer to this challenge.

Beyond the document

Parts 1 through 4 of the TS 17489 series deal with frameworks, data models, technologies, and document profiles. Part 5 – published in 2024 – takes a different perspective. Rather than specifying what a document must contain or how it must be secured, it addresses the conditions under which breeder documents can be trusted: the processes, institutions and governance structures that give a certificate its credibility.

This distinction matters because the vulnerabilities in breeder document systems are not purely technical. Even a perfectly secured birth certificate can serve as a vehicle for fraud if the registration process that produced it is weak, if the issuing authority is not held accountable, or if there is no means for a receiving administration in another country to assess the reliability of what it has been given. Part 5 sets out a framework for analysing and responding to these processes and institutional dimensions.

What a trust framework involves

The starting point for Part 5 is a principle borrowed directly from ICAO's Traveller Identification Programme: principle 1 of the TRIP Guide on Evidence of Identity states that "the identity is genuine." Two supporting objectives follow from this – that the identity exists and is not fictitious, and that it belongs to a living person. Simple as they sound, these objectives expose the full weight of what a trust framework for breeder documents must deliver.

Three hypotheses have guided the development of Part 5.

• Hypothesis 1: a secure credential is worth little if the underlying data is not reliable.

Every data field must be clearly defined, its source known and verifiable, and the process that produced it monitored and enforced.

• Hypothesis 2: informed trust stems from knowledge and shared values.

Civil registration varies widely and frequently lacks transparency across borders. Building confidence between administrations requires sufficient transparency, while respecting sovereignty and security so that a verifier can perform due diligence without subjecting the individual presenting the document to unnecessary scrutiny.

• Hypothesis 3: no single entity can impose specific regulations or standard operating procedures for civil registration on other administrations.

CEN's mandate does not extend to a normative dimension, and the working group remains highly attentive of respecting administrative sovereignty. The framework therefore provides a normative process for developing and reviewing systems, drawing inspiration from ISO 900x and 2700x management system standards. The guidance in Part 5 is advisory rather than mandatory; it does not mandate specific outcomes but provides a structured set of considerations for authorities working to establish trustworthy breeder document systems. Three objectives frame the work.

The first aims to create a common understanding of issues in nationally applied procedures that have international relevance, allowing different countries to address the same challenge with a shared vocabulary. The second is to place particular emphasis on identity fraud prevention, specifically the misuse of breeder documents to obtain national and international identity documents, a vulnerability already identified in the previous articles of this series. The third is to strengthen inter-agency confidence by providing transparent reporting on implementation progress, so that a receiving authority has a solid foundation for assessing the reliability of a document issued in another jurisdiction.

Taken together, these objectives describe something more ambitious than a technical specification alone can deliver. They describe a governance framework meant to evolve with both its practical application by member states and the insights gained from experience.

The policy dimension

Breeder documents sit at an intersection of several policy areas: civil registration, identity management, border control, data protection, and civil rights. Reforms in this space inevitably involve multiple ministries, legal systems, and administrative traditions. Part 5 of TS 17489 is designed to support rather than pre-empt national policy decisions, providing tools that governments can use as they see fit within their own constitutional and administrative frameworks. Competent bodies assessing the standard's objectives are free to adopt recommendations, choose their own implementation approach, or even depart from an objective entirely, provided the decision is recorded and internally justified. This flexibility is deliberate: the framework demands accountability and transparency, not uniformity.

Two tangible tools put transparency into practice. The first is the Declaration of Implementation – a detailed, selective account of how an authority has evaluated and acted upon the framework’s objectives, shared with specific partners on an individual basis. Conceptually, it resembles the ICAO Electronic Filing of Differences but adapted for civil registration.

Instead of submitting data to a central repository, an authority communicates its implementation status directly, much like sharing new specimen travel documents. The second instrument is a scorecard, which calculates a score across the framework's twelve key themes, indicating the degree of adoption of objectives and adherence to recommendations.

Together, these tools offer receiving administrations a clear and structured means to assess the reliability of breeder documents issued by a partner authority, without compromising the sovereignty of either system. The European Commission has been kept informed of the group's progress, as have national authorities responsible for breeder documents and the ICAO ICBWG. The intention is for the TS 17489 series to act as a reference point for the development of future policies at both European and international levels.

What this means for the identity industry

This series of standards gives identity industry professionals a clear framework of questions and opportunities. On the supply side, the specification of physical document security requirements, chip technologies and data models provides a roadmap for developing products and services adapted to the breeder document market. On the assurance side, the trust framework creates a demand for audit, certification, and inspection capabilities – areas where the industry already has significant expertise through existing certification schemes. In this context, the security management processes and certification frameworks developed by Intergraf are directly relevant: ISO 14298, governing the management of security printing processes, and Intergraf 15374, addressing the security of the supply chain and production of document elements, represent established recommended practices that align naturally with the assurance requirements embedded in TS 17489. Producers certified under these schemes are well positioned to demonstrate the process integrity and accountability that the breeder document framework demands.

Perhaps most importantly, the TS 17489 series reflect a broader recognition that the identity chain is only as strong as its weakest link. Having spent decades strengthening travel documents and border systems, the community now has both the opportunity and the tools to address the security gap at the very beginning of that chain.

The standardisation work continues. Those who wish to contribute can do so through their national standardisation body, or by reaching out to participating experts. Participation is open.

Author: Stephan D. Hofstetter, Editor of CEN prTS 17489-5 and Managing Partner of SECOIA Executive Consultants AG, updated for Noted. by Intergraf.

For feedback on the CEN TC224 WG19 breeder document standardisation project, please contact us (contact us with link: intergrafconference@intergraf.eu cc breederdoc@secoia.ltd)

A new format of communication

Every 18 months, Intergraf Currency+Identity organises an international conference and exhibition for currency and identity experts in different European locations to share insights, innovations, and ideas. The event has been successful in reuniting the right people in one place and provides a neutral platform for industry players and end-customers worldwide to meet, be informed, inform and to cultivate business connections.

To further foster common interests and boost exchange during the months in between its events, Intergraf has looked into activities to deliver engaging coverage of industry trends to its global community and to broaden understanding and insight into the fundamental issues shaping the world of currency and identity. Intergraf therefore decided to transition from its former printed + online magazine Infosecura to a modern online format, tailored to meet the dynamic needs and trends of today's audience.

The result is Noted. a digital space reflective of the ever-changing media landscape going beyond the limitations of quarterly updates. We aspire to provide timely and engaging content that resonates with our audience's interests and preferences.

Noted. is not about publishing breaking news, but rather about providing context and presenting short articles that delve into topics significant to our community. Intergraf reaches out to industry enthusiasts to dive deeper into certain topics and share knowledge with our community.

Noted. targets seasoned currency and identity professionals ranging from central bank, government and law enforcement representatives to security printers and their suppliers. We strive to equitably cover currency and identity topics relevant to both industries.

Come along on our journey as we transition to this new dynamic format, reshaping the way we engage with our industries, while redefining our approach to deliver fresh content and insights to our audience.

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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.

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Interested in co-creating content with us? Please contact mvanderveur@intergraf.eu to discuss your options.