The EUDR is a new regulation intended to reduce the impact of businesses operating in the EU on global deforestation and forest degradation.
Wood is one of seven commodities within the scope of the regulation and pulp, paper, board and printed products are within scope as wood-derived products. The EUDR applies to all products placed on the EU market or exported outside the EU from 30th December 2024 including products manufactured after the 29th June 2023. All products within scope must meet three key requirements:
- Originate from lands not subject to deforestation after 2020
- Produced in accordance with local legislation
- Covered by a due diligence statement (DDS) – Depending on the risk associated with the country of origin and the size of the company, differing levels of detail and public disclosure are required. Further guidance is expected from the European Commission in advance of 30th December 2024.
As a printer based outside the EU, sourcing paper and boards both within and outside the EU, Clays have no legal obligations under the EUDR however will be requested to provide information to our customers classed as ‘operators’, placing products in the EU market and/or exporting products outside the EU.
Clays will be requested to provide the necessary information to ensure our customers can fulfil their own compliance requirements, and as such we are undertaking preparatory steps to gather the information and develop tracking systems towards meeting the 30th December 2024 compliance date:
- Supply chain management: We currently have tracking in place for our supply chain to the paper mill and maintain strong relationships with our suppliers. We are engaging with all our suppliers as a priority to understand their current position on the EUDR and gather the necessary information on the source of the paper to enable traceability to the end product.
- Industry engagement: We are attending multiple industry-wide forums to interpret how the EUDR applies to the print and publishing sector and field queries from member companies with the European Commission.
- Publisher discussions: We are continuing to engage with our publishers on the EUDR to agree the information requirements and develop track systems along the supply chain.
Given the complexity of the regulation, we advise our customers to seek secondary guidance to understand the compliance requirements for the EUDR.
Legislation: Regulation – 2023/1115 – EN – EUR-Lex (europa.eu)
Guidance and FAQs:
Deforestation Regulation implementation – European Commission (europa.eu)
EUDR and FSC | Forest Stewardship Council UK
Book Chain Project – EUDR guidance is available to all member organisations