Due Diligence Requirements

Article 9 of the EUDR outlines the information that traders such as Papyrus need to collect to undertake and fulfil the due diligence requirements of the EUDR. Some of this information is also listed in Annex 2 of the EUDR, which sets out the requirements of due diligence statements that must be submitted through the EU’s Traces IT system.

Submitting due diligence statements results in the provision of EUDR reference numbers (and associated verification numbers), which can be used down the supply chain as due diligence proofs.
 

  1. Papyrus Due Diligence System
    A summary of the Papyrus due diligence system that it has put in place to ensure compliance with the EU Deforestation Regulation. Download the summary →
  2. FSC® Chain-of-Custody certificate
    All Papyrus companies are FSC® certified – this verifies that FSC®-certified material has been identified and separated from ineligible and unacceptable material as it makes its way along the supply chain from the forest to the market.
  3. PEFC Chain-of-Custody certificate
    All Papyrus companies are PEFC certified – this verifies that PEFC-certified material has been identified and separated from ineligible and unacceptable material as it makes its way along the supply chain from the forest to the market.
  4. Origin of Wood Statements
    ​Annually updated data regarding the previous whole calendar year’s wood sourcing, outlining tree species used, their scientific and common names and country of origin.
  5. Papyrus EUDR Statement (until end of 2025 not confirmation, but status report of EUDR implementation)
    ​This statement confirms that Papyrus meets the requirements of the EU Deforestation Regulation.
  6. Papyrus Code of Conduct
    The Papyrus/OptiGroup Code of Conduct sets out the principles that help Papyrus organizations make ethically sound decisions. It is the basis for Papyrus’ corporate responsibility and compliance programs, policies, and procedures. Papyrus also maintains a system specifying how to detect compliance risks, how to respond to them, and how to control and monitor them.
  7. Papyrus Sustainability Statement
    The statement describes our commitments and positions regarding sustainability topics and the company’s responsible business conduct regarding them. The document also defines our approach to the governance of sustainability-related topics, and how our environmental and societal performance is assessed, managed, and continuously improved.
  8. Papyrus Human Rights Responsibility Statement
    This statement provides an overview of how the company has implemented human rights responsibility in its work. It describes human rights due diligence practises at Papyrus, highlighting the work done and the lessons learned, while also describing the work still to be done.

1. Information Collection

Collection of information, data and documents needed to fulfil the requirements set out in Article 9.


Description of:

  • Products & species, quantity, volume, country of production
  • Geolocation/reference number, time range of production
  • Verifiable documentation of deforestation and conversion-free status
  • Verifiable info & documentation of legality of produced products

2. Risk Assessment

Risk assessment measures as referred to in Article 10.
 

  • Presence of forests and indigenous people and their rights
  • Prevalence of deforestation & forest degradation
  • Concerns of corruption, human rights, armed conflict, sanctions,
  • Complexity of supply chain, risk of circumvention and mixing
  • Reliability of data and sources

3. Risk Mitigation

Risk mitigation measures as referred to in Article 11.
 

  • Mitigating actions: additional information policies, data, documents, audits or third-party systems

4. Reporting

Risk assessment conclusions & evidence records to be reviewed annually Article 12.
 

  • Records stored minimum 5 years 
  • Information validity based, but latest annual review of due diligence system

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