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.
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