EUDR update: the latest developments and what they might mean for you
With implementation of the new EU Deforestation Regulation less than six months away, here’s what you should know
On 9 July, the European Parliament rejected the EU Commission’s deforestation risk benchmarking system – and became the latest in an increasing number of political, national and industry players calling for late changes to the EUDR before it enters into application on 30 December.
Most are calling for simplification measures of one kind or another to what is a hugely detailed, complex regulation. Partly in response to such pressures, the EU Commission released updated materials in April to help operators and traders better understand their obligations under the EUDR.
The new EUDR FAQ Version 4 includes important clarifications on, for example, provisions related to the transitional period, obligations of downstream operators, the role of EUDR reference numbers, and re-imports to the EU.
Further updated help
Alongside the new FAQ document, the EU Commission has also issued an updated guidance document giving comprehensive insight into the obligations, timelines and system expectations for operators and traders alike.
Meanwhile, the European association representing the paper industry, Cepi, has released its own updated guidance – with the aim of presenting a common understanding of the obligations that come with EUDR and suggesting efficient approaches to implementing it across the pulp and paper value chain.
Key clarifications from the European Commission
The Commission has confirmed that downstream non-SME operators must ascertain that due diligence was exercised upstream. For this purpose, they can verify the validity of the RNs (incl. VNs) received from their direct suppliers and review the information in the Due Diligence Statements (DDS). They should then submit their own DDS referencing those upstream records.
Geolocation data is only required at the origin and referenced via RN/VN thereafter. Competent Authorities will always have full access to all DDS data.
Furthermore, according to the previous EUDR FAQ 3.4, downstream non-SME operators and non-SME traders who only have to ascertain that due diligence was exercised, do not have to collect information required by EUDR Article 9. (A DDS includes a declaration that due diligence was exercised, implying that the information required by EUDR Article 9 has been collected by the upstream operator.)
The EUDR transitional period: what applies until December?
The EUDR entered into force on 29 June 2023, but only enters into application on 30 December this year. During the current transitional period, operators and traders do not need to submit DDSs or Reference Numbers for wood harvested in the EU. This includes pulp and paper products derived from such wood.
This transitional phase is particularly important for non-industrial private forest owners and upstream SMEs who need time to adapt their systems.
Once the regulation enters into application, wood harvested and processed in non-EU countries must comply with EUDR.
Our Sappi Europe EUDR timeline and readiness
All Sappi Europe paper mills will be fully EUDR-compliant by 30 December 2025.
Meanwhile, we're currently testing EUDR data and system workflows in the TRACES training and live platforms. RN (Reference Number) generation from non-EU pulp suppliers is also already underway.
Full deployment to TRACES Live is expected by October/November of this year (subject to system readiness). In the meantime, we continue to collaborate closely with our wood and pulp suppliers and customers to ensure full traceability and compliance.
Testing and collaboration with customers
In addition to testing Sappi’s own EUDR IT systems and procedures together with our suppliers, we have invited our customers to test our EUDR solutions in order to ensure compatibility. We will extend our internal test cases to customers as soon as possible. An important part of the tests relates to the functionalities, reliability, responsiveness and overall steadiness of the TRACES system.
EUDR Reference Numbers (RNs): traceability in practice
Each DDS submission via TRACES generates a unique 14-digit RN. These RNs are required in customs documentation and link each product to its forest of origin. Sappi Europe will provide one Reference Number (RN) per specification in a shipment.
There are three delivery options for the RNs…
- Automated email in the form of a PDF + CSV file with all key data
- E-commerce portal (from 2026)
- EDI transmission – based on papiNet standard
Sappi due diligence and you
Sappi Europe’s existing due diligence system will be extended to cover the new EUDR requirements – especially articles 8 (due diligence) and 9 (information requirements).
We will provide all our customers with EUDR-relevant information about our due diligence system and procedures – this should be available on our website and upon request.
