EUDR Compliance for the Printing Industry
EU Deforestation Regulation (EU) 2023/1115 (EUDR) – compliance for the printing industry
The EUDR is an important piece of European legislation, aimed at tackling deforestation, which will impact the trade of certain commodities within the European Union. Under the latest version of the regulation, which is now confirmed as postponed, the application dates are as follows:
- Large and medium sized operators on December 30th 2026
- Small and micro operators June 30th 2027
The revised regulation also includes simplified procedures which should be further clarified around April 2026.
The aim of EUDR is to combat deforestation and forest degradation and the legislation targets 7 key commodities:
- Timber
- Cattle
- Coffee
- Cocoa
- Palm Oil
- Soya
- Rubber
From December 30th 2026, 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 the revised, simplified regulation EUDR responsibility for compliance and for submitting a Due Diligence Statement falls to the 1st Operator placing the product on the EU market, or exporting from the EU. Downstream Operators or Traders who commercialize that product only need to collect and pass on the reference numbers from the 1st Operator. This simplification is designed to reduce the amount of interactions with the EUDR Information System.
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
- Proof of legality / risk assessment and mitigation documents (where risk has been identified)
Details on how to register for the EUDR Information System are here https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/information-system-deforestation-regulation_en
- When does the EUDR come into force?
For large and medium enterprises the regulation will come into force from 30th December 2026.
Small Micro Enterprises (SMEs) have an additional 6 months before they must comply – 30th June 2027.
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 Eur50 million per annum
Balance sheet less than Eur43 million per annum
This SME status matters under EUDR, not only because of the extended deadline, but also because of simplified due-diligence obligations when compared to large Operators. Details of what this simplified due-diligence involves are still being finalized but it is understood that the administrative burden will be less onerous including:
- reduced requirements when sourcing from ‘low risk’ countries
- reduced requirements when supply chains are fully certified – e.g. FSC
- grouped due diligence statements instead of per shipment
- simplified geolocation requirements
Details are still emerging and a review is expected during the first quarter of 2026 with further guidelines / clarification anticipated around April 2026.
- 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 after the December 2025 revision?
Annex I 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 I, it is not in scope.
The December 2025 revision introduced a major change affecting the publishing industry. Finished printed products categorized in Chapter 49 were removed from scope. This includes books, newspapers, magazines, periodicals, brochures, calendars, maps, prints, postcards and greetings cards. Likewise accessories such as clamshells or slipcases which support, protect or carry a printed product are out of scope. Functional packing materials such as cartons and pallets, are also out of scope.
Remaining in scope are printed paper products which fall into Chapter 48. This includes the raw material – paper and paperboard sold in sheets and reels and paper based stationery items such as notebooks, sketch pads, journals (blank or ruled), diaries, standalone packaging (e.g gift bags or boxes that are sold separately).
The distinction is if the product is primarily paper or board it is in scope. If it is primarily a printed product that is defined by its content it is out of scope.
Exemptions still apply if the Chapter 48 items are made with 100% recycled materials.
Items with HS codes from Chapter 95 are not in scope (no change there), 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.
It is important to identify if your products are in scope or not and to use the appropriate HS code for customs.
- 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 where appropriate.
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.
Deforestation Regulation implementation – Green Forum – European Commission
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