EUDR Compliance for the Printing Industry

• But China is refusing to comply. Surely this means that EUDR won’t happen?

China is a major player in global trade and one of the EU’s main suppliers of furniture, plywood panels, cartons, etc. It is also the latest country to oppose the EUDR, refusing to share geolocational data due to “security concerns.”

A Chinese withdrawal from the EUDR rules could have enormous consequences on global supply chains for timber, paper, and pulp products. China controls more than 30% of the global supply chain of forest products, consolidating its crucial role in the industry.

Twenty (out of 27) European Agriculture Ministers have called for the rules to be delayed due to concerns about global supply chains, echoing warnings from government officials in Australia, New Zealand, Brazil, Indonesia, and Malaysia.

That said, this applies only to where the paper pulp and fibres come from. There is nothing to stop, say, Brazilian pulp being made into Chinese paper as long as its origins can be shown. If China does not comply, we will have to flag up any Chinese pulp – as well as any that are ‘unknown’.

• What about US pulp? Hasn’t the Biden administration also opposed it?

EUDR is perhaps one of the only core issues that has unified the United States and China, the two largest producers of forest products. As of today, the US has highlighted that there are significant challenges in meeting the data requirements by the required date. We will update this as and when it is necessary.

• What about Canada – will their paper comply?

Once again, the situation is unclear and fluid. We assume that Canada will meet its obligations under the United States-Mexico-Canada Agreement (USMCA) but we strongly advise you to make your own enquiries. We can use whatever paper you ask us to.

• If the EU pushes ahead, despite this opposition, what will likely happen?

Given the short timeline until EUDR is supposed to become mandatory, we have no option but to prepare for it. We hope there will be a pragmatic solution to the impasse that does not preclude papers with Chinese (and US) forest sources being used.  Otherwise, this could well lead to paper shortages and increased costs.

• That’s worrying, can I simply ignore it?

Possibly. EUDR applies only to the European Union. All books manufactured in the EU and / or sold in the EU will be affected. If your books avoid the EU, meaning they are printed outside, and are not imported inside, then EUDR would not apply.

• Does all recycled paper & paperboard fall under scope of the EUDR?

It does not apply to goods if they are produced entirely from material that has completed its lifecycle and would otherwise have been discarded as waste, however, if the recycled material contains any virgin fibres then EUDR will apply

• Am I an SME?

Small and medium-sized enterprises (SMEs) are defined in the EU recommendation 2003/361. But generally speaking, if your staff headcount is below 250 and your turnover is less than €50m (or your Balance Sheet is less than €43m), then you are classified as an SME.

These ceilings apply to the figures for individual firms only. A firm that is part of a larger group may need to include staff headcount/turnover/balance sheet data from that group too.

Further information can be found here:

–The revised user guide to the SME definition (2020)(2 MB, available in all EU languages)
-Declaring your enterprise to be an SME (the form is available in all languages as an annex in the revised user guide)
-The SME self-assessment tool which you can use to determine whether your organisation qualifies as a small and medium-sized enterprise. It remains your responsibility to check.

• I’m an SME but I’m selling on to a large company, what does that mean for me?

As an SME selling onto a large company, you are still granted the extended compliance deadline of June 30th 2025. The regulation recognizes the different capacities of SME & large companies, so your compliance timeline remains the same regardless of your customer’s size. However, your large (non-SME) client will still need to comply, meaning you should probably ensure EUDR compliance although the responsibility lies with the large client.

Note, you are still granted the extended compliance deadline of June 30th 2025 as the regulation recognizes the different capacities of SME & large companies, meaning your compliance timeline remains the same regardless of your customer’s size.

• I’m an SME, do I still need to register before Dec 2024?

Yes, as an SME you will still need to register with the EU Commission by November 2024. See The Deforestation Due Diligence Registry – European Commission (europa. )

• I only use FSC paper (or another certification scheme), does this mean I’m OK?

Certification schemes like FSC or PEFC can assist with compliance as they are ‘aligned’ but they should not be taken as a ‘green light’. You will still need to carry out your own due diligence.

FSC Launches Dedicated Site to Streamline EUDR Compliance | fsc.org 

• How do I know if I am an Operator or a Trader?

An operator is a natural or legal person who places relevant products on the market (incl. via an import) or exports them in the course of commercial activity. A Trader is any natural or legal person who places relevant products on the EU market, repeatedly but not for the 1st time. This typically involves buying or selling products that have already been placed on the EU Market by an Operator.

• You are Imago Group. Surely you’ll take responsibility that my books are compliant?

We will help, but we are only responsible for Information Gathering, listed as Article 9 in the EUDR regulation.

Even if you want us to print outside of the European Union, the legal obligation to comply to the EUDR, falls on the EU Operators & Traders. We will, of course, help by providing the required data and documentation to facilitate compliance.

• I have got differing advice to what you are telling me. Will you do what I ask?

Of course! The responsibility is yours so you are free to do as you see fit. We will simply pass on the information that we have gathered, and what we believe it means.

• Will EUDR affect my sales samples & advances?

In short, yes, it will apply to all inter-company transactions. These could include samples, advances, blank dummies and proofs.

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