The European Union Deforestation Regulation [EUDR] is aimed at ensuring that products derived from certain commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood), which are placed on the EU market or exported from the EU, have not caused deforestation or forest degradation during their production.
The EUDR will enter into application on 30 December 2026.
EUDR Latest Updates
The key changes concerning the timeline and content agreed in December 2025 are:
- Extension of the application date for all operators until 30 December 2026, with an extra six-month cushion for micro and small operators. (Note: For micro and small operators already covered by the EU Timber Regulation (EUTR) the entry into application will be 30 December 2026.)
- The obligation and responsibility to submit the required Due Diligence Statement will fall exclusively on the operators who first place the product on the EU-market.
- Only the first downstream operator in the supply chain will be responsible for collecting and retaining the DDS Reference Number(s) of the initial DDS(s), rather than passing it/them on further down the supply chain.
- Certain printed products (such as books, newspapers and printed pictures) were removed from the initial scope of the regulation. (ref. EUDR Annex I)
- The European Commission has been tasked with conducting a simplification review and presenting a report by 30 April 2026.
What is the EUDR – and why does it matter?
The EU Deforestation Regulation (EUDR) aims to minimise the EU’s contribution to deforestation and forest degradation worldwide, thereby helping to reduce global deforestation, greenhouse gas emissions and biodiversity loss.
As well as wood and woodfibre-based products, it applies to a wide range of relevant commodities including cattle, cocoa, coffee, palm oil, rubber and soya – and products made from them.
The EUDR applies to all trade within and between the 27 EU member states, as well as to exports from and imports to the EU.
The initial EUDR [(EU) No 2023/1115] entered into force on 29 June 2023 and its main provisions were to apply from 30 December 2025 onwards. The new regulation [(EU) 2025/2650] agreed in December 2025 amends certain key obligations of operators and traders covered by the provisions of the EUDR.
Under the revised framework, the obligation to submit a EUDR Due Diligence Statement lies solely with the operator who first places a product on the EU market. The first downstream operator must collect and retain the DDS Reference Number of this statement, while actors further down the supply chain are not required to carry out additional due diligence procedures.
See below for a list of FAQs containing further practical details…
The EUDR covers seven relevant commodities: cattle, cocoa, coffee, palm oil, rubber, soy and wood – and a wide range of products derived from them. Such products range from leather goods to chocolate to paper and packaging. The full list is set out in Annex 1 of the regulation (note also the changes to the Annex I in the Regulation - EU - 2025/2650 - EN - EUR-Lex).
For the pulp and paper sector, all products that contain wood fibre are in scope unless they fall into an exempt category.
RNs are issued by the EU’s TRACES system when a DDS is submitted. They are unique 14-digit codes and serve as the official identifier for compliant goods by linking them back to their initial forest of origin.
This forest area is localised by means of latitude and longitude coordinates/polygons or a declaration identifier and is identified at the beginning of the value chain, by the first operator and in the first DDS. Thereafter traceability is built on the RNs.
Upstream operators are those closest to the source – such as forest owners and wood procurement companies. The revised EUDR states the following: “Operator” means any natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them, excluding downstream operators.
Downstream operators are further down the supply chain – the likes of pulp mills, paper converters, printers and retailers, including companies such as Sappi Europe’s paper mills and their partners and customers. The revised EUDR states the following: “Downstream operator” means any natural or legal person who, in the course of a commercial activity, places on the market or exports relevant products made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration
Packaging manufactured using in-scope commodities – such as fibre-based packaging – is covered by the regulation. This includes packing material placed or made available on the market or exported as products in their own right, as well as containers that give a product its essential character.
Not subject to EUDR is packing material presented with goods inside and used exclusively to support, protect or carry another product
Recycled products are generally exempt, provided they are produced entirely from material that has completed its lifecycle and would otherwise have been discarded as waste.
But any product that mixes recovered with non-recycled material is subject to the EUDR requirements – meaning due diligence obligations must be applied to the share of the virgin material in the mix.
This means the first making available of a relevant commodity or relevant product on the EU market. Moreover, the ‘making available on the market’ means any supply of an EUDR relevant product for distribution, consumption or use on the EU market in the course of a commercial activity.
The benchmarking system has been developed by the European Commission to classify countries or parts of countries according to risk of deforestation and degradation. They are classified as either standard (by default), low risk or high risk. Full details are available here.
How is Sappi preparing for the EUDR?
All Sappi’s European mills were prepared to be fully EUDR-compliant by December 2025. We have been working closely with our wood and pulp suppliers, as well as our customers, to ensure complete supply chain traceability throughout our value chain. Around 80% of our wood-based raw materials are sourced within Europe – primarily from Austria, Finland and Germany – through long-established suppliers and partners.
Sappi is now analysing and assessing the impact of the revised EUDR regulation on our EUDR compliance solution and relevant processes and procedures. We will continue informing our customers about our EUDR preparations and will share more information as soon as we have completed an assessment on the impact of the proposed changes on the content and timeline of the entry into application.
Sappi Europe’s existing due diligence system will be extended to cover the requirements of the EUDR. EUDR-affected supply chains for Sappi’s operations in South Africa and North America will be able to provide customers with necessary information upon request.
Sappi’s EUDR preparations are not taking place in isolation. We have been actively involved in sector-wide collaboration – working through organisations such as Cepi (Confederation of European Paper Industries) and national industry associations to help shape industry-wide solutions and approaches. This work continues.