With regulations tightening across sourcing, packaging and waste, the paper and publishing industry is entering a new era of accountability. Here’s what the EUDR legislation means in practice – and why traceability is now business‑critical.

This article is taken from the Products of Change Paper Chapter. Read the full publication here.

EUDR is arguably one of the most significant pieces of environmental legislation currently coming out of the European Union. It forms part of the EU Green Deal, alongside the Green Claims Directive, Eco-design for Sustainable Products Regulation (ESPR), and Extended Producer Responsibility (EPR).

It covers several key commodities that have historically been linked to deforestation risk, including timber, paper and pulp products, cattle, cocoa, coffee, soy, palm oil and rubber, alongside a range of derived products.

While EUDR spans all of these sectors, for the purposes of this discussion we’re going to focus specifically on paper and paper-based products. For many businesses in the licensing industry, paper is likely to be one of the first materials where the impact of these regulations will be felt, making it a useful place to start when understanding how the wider regulatory landscape is evolving.

At the heart of EUDR is the EU’s ambition to ensure that products entering the European market are not contributing to global deforestation. The goal is to make sure that paper and paper-based products originate from sustainably managed forests, building on practices that many responsible forestry organisations have been implementing for years.

Crucially, it is the only regulation coming out that can actually prevent products from being sold within the European market if they do not comply, rather than functioning as a tax for non-compliance. With EUDR, if businesses cannot demonstrate compliance, products can be stopped at the border.

One of the more positive developments over the past year has been the simplification of some of the requirements. As discussions have continued around the complexity of implementation and the number of operators involved, regulators have taken a more phased approach. Initially, the focus will be on larger companies, with responsibility sitting primarily with the first operator placing the product on the EU market. That operator must be able to demonstrate that the material originates from a compliant source and provide the required due diligence information.

POC Member, the Zoological Society of London (ZSL) has been doing a lot of work on EUDR, working with organisations to create guidance and to prepare.

One such project has been with the Book Chain Project to publish six country-specific guides (Thailand, Brazil, Malaysia, Mozambique, India, Argentina) on the sourcing requirements of each region and its paper mills.

Mirjam Hazenbosch, sustainable business programme manager at ZSL, provided more detail: “it’s really about telling individual companies what they need to do, what documents they need to look at when they’re sourcing from the different countries. […] We have an overview of the different key documents that publishing companies need to collect from specific countries to comply with EUDR, and that looks at different categories, including land use rights, for example, environmental protection, forest-related rules, third parties’ rights, labour rights, human rights, FPIC, and then any tax and anti-corruption regulations.”

These guides are available to download from bookchainproject.com/resources.

ZSL’s other EUDR projects include work with HSBC on an EUDR Guide for Relationship Managers and what it means for financial institutions that invest in companies affected by EUDR. It has also been working on the Timber Origin Testing Project with World Forest ID to develop isotope testing to provide independent geographic origin evidence for timber so that it can be proved where it came from for enforcement agencies.

This is particularly necessary, Mirjam explained, because as fraud is still a big issue in timber supply chains as they remain reliant on a paper trail. “I think that will be very important for enforcement agencies to consider and to do alongside checking the paperwork, because the paperwork is quite easy to tweak,” she said.

And while there has been numerous delays and simplifications, most significantly at the end of last year, the postponed implementation date of 30 December 2026 for large and medium-sized operators, and 30 June 2027 for micro and small companies, now looks unlikely to change. One such revision particularly pertinent to the paper and publishing industry, was the removal of certain printed products from the scope of EUDR for the time being, including books, newspapers, printed pictures, and likely also greeting cards and calendars, but there is some contention there and further clarity is being sought.

There may still be edits and revisions, but; “I think it’s all about just getting started and getting something across the line that will be very important,” said Mirjam, adding that “with traceability comes responsibility, and once you know, you can’t say that you didn’t know, so I think in that way EUDR is having a positive influence.”

It is opening up visibility of supply chains for companies, beyond tier 1, and ensuring greater accountability, which, while undoubtedly causing significant administrative burden, can only be a positive change in the long term.