Reposted by Newlife - Flexstone; original copyright belongs to the author; see "Sources" at the end for the original link.

Cepi Releases Updated EUDR Guidelines to Guide the Pulp and Paper Industry in Compliance Preparation

The EU Deforestation Regulation (EUDR) will officially come into effect on December 30, 2026. To help relevant enterprises prepare for compliance in advance, the Confederation of European Paper Industries (Cepi) has released a new version of EUDR guidance documents for the pulp and paper industry. This document replaces the old guidelines released in June 2025, sorting out the core compliance obligations that enterprises need to fulfill after the regulation is implemented. The content incorporates the latest policy developments up to September 2026, including the EUDR regulation amendment in December 2025, the simplification package released by the European Commission in May 2026, the secondary legislation officially adopted in 2026, as well as the updated official guidance documents, FAQs, and other supporting public documents from the European Commission.

The brief content of the document is as follows:

1. Regulatory Objectives and General Obligations for Operators and Traders The regulation applies to enterprises that place, export, or trade controlled products in the EU. Controlled products must simultaneously meet the requirements of being deforestation-free, complying with the laws of the country of production, and having a due diligence statement or a simplified statement. These statements need to be submitted online via the TRACES system.

2. Scope of Products The control scope includes Chapter 44 (Wood), Chapter 47 (Pulp), and Chapter 48 (Paper). It clarifies the exemption conditions for recycled materials, packaging, and letter samples. Chapter 49 (Printed matter) has been removed from the control list. It also provides examples to distinguish whether certain products fall under the jurisdiction of the regulation.

3. Relevant Definitions It defines deforestation and forest degradation. Deforestation and degradation occurring after the product is placed on the market do not retroactively affect the compliance of the original product. The scope of applicable laws in the country of production is expanded to include labor and indigenous rights. It defines the concepts of operators and traders. If the HS code is changed, the enterprise becomes a downstream operator; merely reselling without changing the code classifies the enterprise as a trader. The same enterprise can simultaneously hold multiple supply chain roles.

4. Conducting Due Diligence The due diligence for upstream operators is divided into four processes: collecting information, risk assessment, risk mitigation to a negligible level, and submitting the DDS in TRACES. Procurement from low-risk areas can exempt the enterprise from risk assessment and mitigation, but the information collection obligation remains unchanged. Downstream operators do not need to conduct due diligence.

5. Determining Enterprise Roles Based on Size and Supply Chain Position It distinguishes between upstream operators, first-level downstream operators, downstream operators, and traders. Micro and small primary operators (MSPO) in low-risk countries are allowed to submit simplified statements. Each legal entity within an enterprise group independently determines its status as an MSME and can designate an authorized representative within the EU to submit various statements on its behalf.

6. Import, Re-import, and Export Processes for Non-EU Enterprises When non-EU enterprises supply goods to the EU, the first market participant within the EU is considered the upstream operator. Re-imported products that can prove they have already been placed on the EU market comply as downstream operators. It distinguishes the export declaration requirements for operators and downstream operators, clarifying the usage scenarios for various TARIC customs codes.

7. Substantiated Concerns and Other Evidence of Non-compliance Any entity can raise substantiated concerns. If an enterprise receives such information, products already placed on the market must be reported to the competent authority and downstream customers. For products not yet on the market, non-SMEs must conduct verification. During the verification period, the products involved cannot be placed on the market, and the competent authority can implement temporary suspension measures.

8. Relevant Obligations Based on Enterprise Roles Through 8 typical business cases, it explains the compliance operations of different types of enterprises. Only first-level downstream operators need to retain the DDS number, while all downstream operators and traders need to keep the information of upstream and downstream cooperation entities for 5 years.

9. Verifying Suppliers' Due Diligence Work Downstream operators have no obligation to verify the due diligence work of upstream operators. When upstream operators procure from low-risk countries, they still need to confirm that all raw materials come from low-risk areas to avoid the risk of high-risk materials being mixed in.

10. Country Risk Classification The EU classifies countries into three categories: low risk, standard risk, and high risk. Simplified due diligence can be implemented for products from low-risk countries, but plot geolocation information must still be provided. Member states conduct regulatory spot checks at different proportions based on the risk level.

11. Frequency of DDS Submission by Upstream Operators One DDS can cover multiple batches of goods, with a maximum validity of 1 year, and must be submitted before the product is placed on the market. When forest land conditions are stable, it can be submitted in advance before harvesting. The same batch of products cannot correspond to multiple DDSs.

12. Transmitting Reference Numbers via CSV Files The regulation does not mandate a specific data exchange format. It recommends using UTF-8 encoded CSV to transmit DDS numbers, and the numbers can also be printed on invoices. The verification code does not need to be passed down mandatorily and can only be requested from suppliers when substantiated concerns arise.

13. Entry into Force, Application, and Transition Period The EUDR entered into force on June 29, 2023. Large and medium-sized enterprises will fulfill their obligations from December 30, 2026. Micro and small enterprises established before December 31, 2024, will have their deadline postponed to June 30, 2027. Products placed on the EU market during the transition period will continue to follow the old EUTR rules. For mixed old and new inventory, only the new inventory requires a DDS. Products produced outside the EU during the transition period and imported into the EU after December 30, 2026, must still comply with the EUDR.

Sources

- WeChat Official Account (2026-11-09) - Original link: 【行业】Cepi 发布新版 EUDR 指南，指导浆纸行业做好合规准备 - https://mp.weixin.qq.com/s/W8pYQ0TUFZQxFsSLOcu6Nw