Regulation guidance: deforestation and EUDR

What is the upcoming European Union Deforestation Regulation, when does it come into force and how will it affect the print industry? Sustainability specialist Rachel England outlines everything you need to know.

The EUDR (European Union Deforestation Regulation) is designed to combat deforestation and forest degradation worldwide. For companies operating in the wood, paper and cardboard industries, as well as other sectors linked to deforestation, the regulation presents a significant challenge.

What is the EUDR?

The EU Regulation on Deforestation-free Products (EU/2023/1115) imposes a number of new responsibilities on businesses that use or trade any of the following seven materials, or their byproducts, within the EU: coffee, cocoa, cattle, palm oil, soy, rubber and wood. 
At over 1,000 pages, the regulation guidance is extensive but is based on a straightforward premise. Businesses must be able to prove that their materials:

1. Do not contribute to deforestation or degradation
2. Have been produced in accordance with the relevant legislation of the country of production
3. Are covered by a due diligence statement

Because businesses must be able to demonstrate the clear provenance of their materials – and the materials of their suppliers – they’re facing big changes in supply chain management. 

How are printers affected?

As key consumers of pulp, paper and cardboard, many – if not all – print companies will need to become compliant with the EUDR. However, there are several key exceptions. The regulation only applies to products placed on the EU market and will not affect the same products sold within the UK market. 

It is also only applicable to virgin fibre-based commodities, so any products made of 100% recycled content do not fall under the EUDR umbrella. However, if there is any proportion of virgin fibre used at all, the EUDR applies.   

There is no minimum threshold volume or value for commodities or products to fall in scope of the regulation.

How do printers become compliant with EUDR?

In order to comply with the EUDR printers need to know what’s in their materials and where it’s come from. This involves a huge amount of data, complicated further by the ‘silo problem’, where different fibres, or raw materials from different mills, are blended and stored together.  

Printers will need to robustly examine their data management processes and consider how new supplier audit procedures and supply chain management systems could make their supply chains more transparent. However, both come with their own challenges. Finding suppliers that meet all of the EUDR’s requirements may be difficult in the context of complex global supply chains, while IT infrastructure needs to be advanced enough to track the origins of materials in real time. Inevitably, there will be costs involved in these measures.  

It should also be noted that certifications alone, such as Forest Stewardship Council (FSC)-certification, are not sufficient for EUDR compliance. However, partnerships with such certification schemes can be helpful as they often facilitate data collection, which will help in meeting the requirements of the EUDR.  

The EU Information System (also called TRACES) is intended to help address the data challenge, and will act as a database of raw material sourcing information, including geolocation data. This system, however, is still under development (more on this below).
 
As part of the regulation, companies will have to submit a due diligence statement for their printed products to the Information System in order to obtain a reference number, which can then be shared with their suppliers and customers. 

All the data within the Information System will then be used by national authorities to ensure enforcement of the regulation along the value chain. Penalties for non-compliance will be issued by these authorities within each EU country, although it’s not yet clear what they might look like. 

Companies that aren’t in the EU but want to put a product on the EU market will need to provide a due diligence statement reference number as part of their customs procedure. No reference number, no access to the European market – so print companies outside the EU must be ready to move on the EUDR when necessary.  

When does the EUDR come into effect?

Originally, the EUDR was due to come into effect on 30 December 2024 for large enterprises, with the transition period for small and medium enterprises (SMEs) delayed to 30 June 2025. (SMEs are defined in the EU recommendation 2003/361, but generally speaking are classified as businesses where staff headcount is below 250 and turnover is less than €50m, or the balance sheet is less than €43m).

However, given the scale of the data required – and the fact that many of the tools designed to assist companies in compliance (such as the Information System) are not yet ready – the EU Commission has proposed a 12-month delay to the implementation of the EUDR. The proposed delay has also been driven by EUDR opposition from China – which controls more than 30% of the global supply chain of forest products – on the grounds of ‘security concerns’ around the requirement to share product geolocation data. 

If the delay is approved, large companies will be expected to be compliant by 30 December 2025, with SMEs following by 30 June 2026. 

What does the print industry think of EUDR?

Laetitia Reynaud, Senior Policy Advisor at Intergraf – the voice of the European printing industry in Brussels – says that while there has been an overall “positive response” to the general aim of the legislation, the uncertainty around many of its aspects has created a headache for printers. 

“The tools that were meant to be available to assist printers with compliance are not yet ready, and we’re still facing questions on really practical aspects of the regulation,” she says. “Books, for example. It’s not clear who is responsible for putting a printed book on the European market – the printer or the print buyer. While this particular example might not be applicable to FESPA members, it’s indicative of the need to postpone the application of the EUDR to ensure clarity and enable every business affected to prepare properly.”

How can printers get help with EUDR?

Printers – regardless of their size and sector – are not alone in facing this challenging legislation, and there are multiple avenues available for advice and support. For printers in the UK, the FSC has a dedicated EUDR Journey Hub, with practical resources and step-by-step guidance to support compliance. 

For companies in the EU, Reynaud suggests contacting national trade associations, or with Intergraf directly. “It’s a complex regulation and no company is expected to manage it all by themselves,” she says. “Speak to industry associations and trade bodies for expertise and advice – that’s what they’re there for.”