UPDATE: 22.10.2025
The European Commission (EC) issued a formal proposal relating to the implementation of the EUDR regulation. As you recall, the EC previously announced its intent on delaying the enforcement of EUDR by one year due to insufficiencies in the IT system designed to support EUDR. The latest announcement reversed that position.
Key elements of the proposal are as follows:
• Downstream operators and traders of products already placed on the EU market will no longer be required to submit due diligence statements /DDS.*
• Micro and small primary operators will only have to submit a one-off declaration to the IT system rather than for each shipment. (This affects purchases from small forest owners, and therefore not relevant for Papyrus and its customers).
• EUDR will be enforced for small and micro enterprises beginning December 30, 2026.
• For all other stakeholders, the date of EUDR application remains December 30, 2025, but there will be a phase-in grace period until June 2026 for checks and enforcement.
* This is only about DDS (Verification Number), but not about Reference Number. Updating DDS once a Year is a very minor issue in this process. The continued requirement for Reference Numbers to follow products throughout the entire value chain will not change anything on high administrative burdens without offering meaningful traceability.
Next steps
The EC proposal will now be taken up by the EU Parliament and Council to adopt or introduce additional amendments to the regulation.
The European Union Deforestation Regulation (EUDR)
What is the EUDR?
The EU Deforestation Regulation (EUDR) is designed to ensure that products placed on or exported from the EU market do not contribute to deforestation or forest degradation. It covers seven key commodities - timber, palm oil, soy, cocoa, cattle, rubber, and coffee - as well as a wide range of derived products such as paper, chocolate, furniture, and leather.
What are the main objective of the EUDR?
- Combat global deforestation and forest segradation
- Ensure products are “deforestation-free”
- Promote transparent and traceable supply chains
- Protect biodiversity and indigenous rights
- Reduce the EU’s environmental footprint
Papyrus Due Diligence Process
Who is affected?
The regulation applies to both operators (companies placing or exporting covered products on the EU market) and traders (companies further along the supply chain). Large and medium-sized businesses must comply from 30 December 2025, while micro and small enterprises have until 30 June 2026.What does compliance involve?
To meet the EUDR requirements, companies must ensure that products are:- 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:
EUDR Annex 1 List of relevant products
EUDR Competent Authorities
EUDR Compliance Guideline
EUDR FAQ Papyrus and Scaldia October 2025
EUDR Frequently FAQs by the European Union
EUDR HS-Codes and TARIC Codes
EUDR Information for SME companies