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EUDR Compliance for the Printing Industry

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EU Deforestation Regulation (EU) 2023/1115 (EUDR) – compliance for the printing industry

The EUDR is an important piece of European legislation which will impact the trade of certain commodities within the European Union.  This new regulation comes into force on December 30th 2025, following a year-long postponement.  The aim is to combat deforestation and forest degradation and the legislation targets 7 key commodities:

  • Timber
  • Cattle
  • Coffee
  • Cocoa
  • Palm Oil
  • Soya
  • Rubber
eudr agreement timelime imago group

From December 30th 2025, these commodities and their derivatives (e.g. paper from timber, leather from cattle) must be proven to be deforestation free and legally produced before they can be imported or exported out of the EU.

 Who is responsible and what information is required?

Under EUDR responsibility for compliance falls to Operators and Traders.   The Operator is the entity that places the products on the EU market for the first time, or exports them from the EU.   A Trader buys or sells products that have already been placed on the market which may include re-importing them.

The key responsibility of an Operator is to submit a due diligence statement (DDS) to the EU’s centralised information portal prior to import / export.

The due diligence statement should include :

  • The Operator’s name. address and EORI number
  • The HS code /  description of the product / weight / number of items
  • Country of production and geolocation data of plots where production / harvest takes place
  • Dates of production / harvest
  • Where an existing DDS exists, reference number of that statement
  • If there is no existing DDS then proof of legality / risk assessment and mitigation documents are to be submitted to the EU portal for assessment

Traders are responsible for verifying that upstream due diligence has been conducted and for maintaining records of this verification for a period of five years.   If a product is re-imported into the EU and released for free circulation, then it is being placed on the market again and the Trader will need to assume the responsibility of an Operator.

 Information about the EU Information system and details on how to register are here https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/information-system-deforestation-regulation_en

EUDR printing industry
  • When does the EUDR come into force?

Large and Medium Enterprises must comply 30th December 2025

Small Micro Enterprises (SMEs) must comply 30th June 2026

The dates refer to the date that the goods are placed on the market, or are exported from the EU.  When products complete customs clearance and are ‘released for free circulation’ they are deemed to be ‘placed on the market’ so customs clearance is a key trigger point.

  • What is an SME?

To qualify as an SME companies must satisfy two or more of the criteria below :

Fewer than 250 employees
Turnover less than Eur 50 million per annum
Balance sheet less than Eur25 million per annum

 This is more complex if, as an SME, you are selling to a large Trader as their compliance kicks in 30th December 2025.   For further guidance check here https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/factsheet-smes_en

  • What are the legal obligations of non-EU suppliers?

If you are producing your products in non-EU countries your suppliers are not regulated by EUDR, but they will need to play a key role in supplying you with accurate and complete data to support your DDS.

  • What is country benchmarking and what impact does that have?

The European Commission have published a list that classifies countries as low, standard or high as an assessment of the deforestation risk associated with that country.  This classification will determine the level of due diligence required and the level of scrutiny / inspections that the Competent Authorities will carry out annually.

 The geolocation data remains mandatory for all classification levels, although the risk assessment / mitigation requirements are simplified.

The following have been classified as High-Risk EUDR Countries and will be subject to more scrutiny:

  • Belarus
  • Myanmar
  • North Korea
  • Russia
  • What Goods are in scope?

Annex 1 of the regulation lists out the Combined Nomenclature (CN) codes, also referred to as Harmonised System (HS) codes, of all items which are in scope. If your product’s code is not listed in Annex 1, it is not in scope.

For example, in the case of printed paper products the following CN codes are in scope :
Chapter 4901 – printed books
Chapter 4910 – calendars
Chapter 4820 – diaries / memo pads

Items with HS codes from Chapter 95 are not in scope, this includes card / tarot decks (9504.4000) and board games (9504.9000) and jigsaw puzzles (9503.0069)

Paper and Pulp are covered in Chapter 47 and 48 and are in scope, with the exception of bamboo based papers and papers made from post-consumer waste and scrap materials.

Functional packing materials that support, protect or carry another product that is in scope, such as cartons and pallets, are not in scope. Packaging that enhances the product, such as a gift box or slipcase for an item in scope would also be in scope.

It is important to identify if your products are in scope or not. The regulation (including Annex 1) is available here https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1115

  • How will Imago support me?

Imago are committed to sustainability and support the goals of the EUDR.    We are well prepared for EUDR, having conducted extensive supply chain mapping of our printers and the mills / papers they use.   Imago cannot assume the responsibility of an Operator, as we do not place goods on the European market, but we will support you with the timely supply of the information required to help you fulfil your DDS obligations.

To facilitate this Imago have signed up to the Book Chain Project’s EUDR solution, a digital platform which will allow us to collect, retrieve and share data / legality information on the mills/ papers that we use.

Imago will use FSC certified papers whenever possible.  FSC supports legality and sustainability and FSC-certified papers already meet high standards for responsible forest management although they are not a ‘green lane’ for EUDR compliance.

Imago’s EUDR team welcome discussion / meetings with clients to explain how we can assist you to navigate this milestone piece of legislation.

  • Further information

We recommend consulting the European Commission’s website for further information and the latest FAQs :

https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation_en

https://www.ico.org/documents/cy2024-25/European-Commission-FAQ-UPDATE-4th-Iteration_APRIL25.pdf

EUDR in the printing industry deforestation

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