The EU Deforestation Regulation

We would like to provide you with a status update on the EU Deforestation Regulation (EUDR) and outline what this means for our future cooperation.

What has changed?
The European Commission published the EUDR simplification review package in May 2026.

The updated approach concentrates the formal due diligence obligation with the first operator placing relevant products on the EU market or exporting them, while downstream actors in the supply chain are primarily required to retain and provide specified traceability information when needed.

Downstream operators and traders are no longer required to submit their own due diligence statements. Their obligations are mainly limited to registration in the EUDR Information System for non-SMEs and receiving reference numbers where their direct supplier is an operator placing relevant products on the EU market or exporting them under the Regulation.
 

• Application dates: 30 December 2026 (medium and large operators) and 30 June 2027 (micro and small primary operators).
• Printed products: Printed products (CN code 49) are excluded from the scope of the Regulation.
• Due diligence responsibility: The operator placing products on the EU market submits the due diligence statement. Only the first downstream operator receives EUDR Reference Numbers (see "EUDR Due Diligence Senarios" in the EUDR supporting documents list below for more details).
• Downstream requirements simplified: Only the first downstream operator must receive and keep the Reference Number. Further downstream companies only need to keep information on their direct suppliers.
   

What does this means for our customers?
In general, Papyrus acts as a 1st Downstream Trader or a Downstream Trader. Therefore, Papyrus’s customers should not expect to receive a reference number. In the rare cases where Papyrus is acting as an Operator (placing products to the EU), the relevant due diligence statement reference number in line with the requirements of EUDR will be provided.

As a Downstream Operator/Trader, your obligation is to hold certain supplier and customer information specified in article 5 of the legislation. It’s basically what a company is doing anyway, keeping record on purchases and sales.

In the rare cases where Papyrus is acting as an Operator, our customers are in the role of a 1st Downstream Trader/Operator and need to retain the relevant reference number with the products and provided by us.

Who is affected?

What does compliance involve?

• Deforestation-free and legally produced, respecting environmental, human rights, and anti-corruption laws.
• Backed by a due diligence statement, including risk assessments and, where needed, mitigation plans.

EUDR supporting documents:

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