EUDR Compliance for the Printing Industry

As of 29 June 2023, the European Union Deforestation Regulation (EUDR) has been introduced to combat global deforestation, forest degradation, and biodiversity loss. At Imago Group, we’re dedicated to helping businesses in the printing industry ensure compliance with EUDR requirements and maintain deforestation-free supply chains.

Imago Group’s EUDR Declaration of Compliance

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eudr agreement made

European Union Deforestation Regulation (EUDR) compliance for printing industry – What You Need to Know

  • I keep hearing about EUDR. What is it and will it affect me?

In force since 29 June 2023, the EUDR has been introduced to limit the EU market’s impact on global deforestation/forest degradation and biodiversity loss, promote deforestation-free supply chains, reduce the EU’s contribution to greenhouse gases (GHG) emissions– and protect human rights and the rights of indigenous people.

When compliance becomes mandatory at the end of 2024, the new regulation will require large companies trading in seven key commodities (and products derived from those commodities) to prove that these goods/products do not originate from recently deforested areas or contribute to forest degradation.

Large and medium-sized operators and traders will have until 30 December 2024 to demonstrate compliance with the EUDR, while small and medium-sized enterprises will have until 30 June 2025.

There is no minimum threshold volume or value for the respective commodities or products to fall in scope of the Regulation.

  • What products are going to be affected?

The EUDR applies to seven commodities produced within and imported to the EU. These are: palm oil, soya, wood, cocoa, coffee, cattle and rubber. It also affects derived products from these commodities including, among others, chocolate, beef, leather, furniture and printed paper.

  • All wood products? Is anything not going to fall under the scope of EUDR?

Interestingly, at the moment we believe that jigsaw puzzles, playing cards and board games don’t seem to fall under EUDR, because they are not covered in chapters 47, 48 and 49 of the Combined Nomenclature document. They come under chapter 95, with other games and toys, implying that it does not matter whether they are made from wood. This is, of course, merely our interpretation, and you will have to check yourself to ensure this is the case,

  • What do I have to do to make sure I am compliant?

The Regulation is based on a basic premise: the prohibition on introducing into the market, marketing, or exporting relevant commodities and products – unless they meet three conditions:

They do not contribute to deforestation or forest degradation.

They have been produced in accordance with the relevant legislation of the country of production (which includes not only compliance with environmental regulations, but also those related to land-use rights, forest management, labour, tax and /or human rights laws).

They are covered by a due diligence statement.

  • 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.

EUDR printing industry
  • I only sell to the UK, but that includes Northern Ireland. Does that matter?

The Northern Ireland Protocol lists the provisions of EU law which continue to apply as regards Northern Ireland.  This has significant practical implications for trade in goods between the mainland UK and Northern Ireland; for example, as a general rule, goods from the UK destined for Northern Ireland must meet EU standards, as specified in the Protocol (although the Windsor Framework includes some important relaxations of and exceptions to this general rule). That said, at the moment, we believe that if you are delivering to Northern Ireland, EUDR will apply.

  • So, in the UK, I’ve kept my books out of the EU and Northern Ireland – am I free from EUDR?

Ultimately it will always be your own decision, but we understand that if your titles appear on Amazon in the UK, they will also be available in the EU and therefore will need to be EUDR compliant. We are seeking urgent clarification from Amazon on this.

  • I’m a US (or Canadian or simply a non-EU) customer. I can ignore all of this, right?

It’s up to you, but you might want to check if your titles are available in the EU (when you definitely do need to comply) or the UK (probably need to comply – see above). Restricting their distribution there is one option, alternatively, compliance with EUDR will ensure you do not need to worry.

  • I am a publisher based in the US, printing a book in Europe for export to the US. Do the books need to comply with EUDR and, if so, who is responsible?

Yes, the goods will need to comply with EUDR and responsibility falls on the company exporting it from the EU.  In this scenario the books are not being placed on the EU market and the US publisher sits outside the jurisdiction, so the printer, as exporter, would need to ensure that the books meet the EUDR’s requirements.

  • My books will cross the EU in transit. Will they be affected?

No, Goods in Transit are not affected, as the EUDR primarily affects goods that are placed onto the EU market or exported from the EU. So, for example, a book printed in Turkey and delivered to the UK & placed on the UK market would not be affected. Similarly, if the books are stored in an EU warehouse, but are not put on the market there, then our understanding is that they do not need to be EUDR compliant.

  • What about packaging?

Disposable point of sale packaging is not exempt from EUDR unless it is recycled material. However, transportation packaging is exempt, for example, cartons & pallets.

  • 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 

EUDR in the printing industry deforestation
  • Can you submit the information to the EU Portal for me?

We can help you, but the primary responsibility for submitting the due diligence statement and relevant information is the Operator.

  • Will my books still have free movement within the EU?

Yes, goods that comply with the EUDR will still be allowed free movement within the EU. The EUDR does not change the fundamental principle of the free movement of goods within the EU Single market. We believe that the competent authorities will conduct checks on Operators & Traders to ensure compliance, using a risk approach.

  • 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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