The EU Deforestation Regulation poses a significant challenge for the paper industry as well. As one of the main buyers of wood fibre and pulp, the industry must ensure its products have not contributed to deforestation. Companies importing paper, board or pulp into the EU, or producing and selling them here, must provide seamless evidence that their supply chains meet the EUDR's requirements.
The regulation covers not only raw material deliveries but a broad range of paper-based products: printing paper, packaging materials, hygiene papers and speciality papers. The exact scope is determined by the customs tariff numbers (HS codes) named in the law.
Note: there were major changes for paper-based products at the end of 2025. HS code "ex 49" (including books, newspapers, calendars and other printed products) was removed from Annex I of the EUDR; printers are fully exempt from the remaining obligations for these product categories. Paper, board and products under HS code 48, such as wallpaper, packaging, labels or notepads, remain in scope.
Countries of origin and risk assessment
The paper industry sources its raw materials mainly from wood fibre and pulp of very different origins. While countries like Sweden, Finland and Canada are often considered low-risk areas known for sustainable forestry, large volumes of pulp also come from countries with higher deforestation risks, including Indonesia, Brazil and Russia.
The EUDR benchmarking system classifies countries of origin by the risk of their forestry practices, low, standard or high, and thereby sets the due diligence requirements. Countries with weak law enforcement or high deforestation rates are particularly critical. For the paper industry it is therefore essential to know the exact origin of the pulp or wood fibre and to analyse supply chains carefully, because a single sourcing point can affect the risk of the entire chain.
Specific challenges for the industry
The paper industry's raw material chains are often highly complex, as pulp is processed in several stages, from fibre extraction through pulp production to papermaking and converting. Fibres from different countries of origin can be mixed along the way, which makes precise traceability harder.
Conclusion: the EUDR as an opportunity
The EU Deforestation Regulation is a major turning point for the paper industry. Companies that invest early in transparent supply chains, document raw material origins precisely and commit to sustainable sourcing will not only meet the legal requirements but also strengthen their market position. Polygon One supports the paper industry in implementing the EUDR's requirements, from geolocation through risk analysis to integration with the EU's TRACES system.
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