EUDR for paper and packaging: what pulp importers, paper mills, printers and packaging manufacturers must do by 30 December 2026

In brief

Pulp and paper have been in Annex I since the first version of the Deforestation Regulation, as ex chapter 47 and ex chapter 48. That covers the whole chain from imported pulp through paper and board to the folding carton and corrugated case traded empty. Two exemptions carry most of the industry: products made entirely from recovered paper or other recovered material are out, and packaging that protects or carries another product stops being a relevant product the moment it is used.

Because pulp and paper were already covered by the EU Timber Regulation, there is no deferral for these products: micro and small enterprises must deliver from 30 December 2026 as well. Due diligence falls on whoever first imports pulp, paper or packaging into the EU or produces it from EU forests. Paper mills using EU pulp, printers and packaging makers using EU paper are downstream and only keep records. This article shows which headings are covered, where the exemptions apply, who holds which role and what goes into the customs declaration.

Which headings are covered

Under the commodity wood, Annex I lists chapters 47 and 48 of the Combined Nomenclature with the prefix "ex": covered is what consists of the commodity wood, with the exceptions the annex itself names. In practice:

Two consequences of this list are regularly missed. First, the chain ends at the printer: a printed catalogue of heading 4911 is not a relevant product, the unprinted paper before it was. Second, it starts at the pulp: anyone importing pulp from Brazil, Chile or Canada is an operator with full due diligence, even if they never sell a reel of paper. How to check against Annex I by CN code is explained in E4 Annex I and CN codes; the Excel scope checker matches your item master data offline.

The two exemptions that carry the industry

Recovered material. The second explanatory paragraph of Annex I takes out of scope products made entirely from material that has completed its life cycle and would otherwise have been discarded as waste. For chapters 47 and 48 the express exclusion of recovered products and products derived from them is added. A corrugated base paper made from one hundred per cent recovered paper is therefore not covered, and neither is the carton made from it. As soon as virgin fibre is blended in, the regulation applies to the product; due diligence then relates to the plots the virgin fibre comes from. By-products of a manufacturing process that did not involve waste remain covered.

Packaging in use. For headings 4415, 4401, 4405, 4416 and chapter 48, Annex I makes clear that packing material and packing containers used exclusively to support, protect or carry another product are not covered from the moment they are used for that purpose. The folding carton around the pasta, the shipping box around the printer, the pallet under the machine are not relevant products when they arrive with the goods. The same folding carton, traded empty as goods of heading 4819, is covered. Customs has had code Y190 for this since 23 September 2026.

Both exemptions relieve the user, not the manufacturer. Whoever makes corrugated board from imported virgin-fibre paper and sells empty cases is in the chain; whoever buys cases and ships goods in them is not.

Who holds which role

The role is determined per product, not per company. The operator is whoever first places a relevant product on the market or exports it; the downstream operator is whoever makes something new from relevant products already placed on the market; the trader passes goods on unchanged. The roles in detail are in E3 Operator or trader.

Since Regulation (EU) 2025/2650, downstream operators and traders submit no due diligence statement of their own, whatever their size. Those that are not SMEs must register in the information system under Article 5(2). The first customer of an operator additionally stores the reference numbers received; further down the chain no numbers are passed on. How the reference number is created and travels is in E1 Reference number.

Deadlines: no deferral for paper

The obligations apply from 30 December 2026. For operators that were micro or small enterprises on 31 December 2024, Article 38(3) moves the start to 30 June 2027, with one exception: products that were already covered by the annex to the EU Timber Regulation (EU) No 995/2010. That annex included pulp and paper of chapters 47 and 48. The deferral therefore does not apply to the paper chain; the small stationer importing copy paper from a third country is due on 30 December 2026 just like the group.

Two more dates: products produced before 29 June 2023 are outside the regulation (customs code Y132), and goods first placed on the market between that date and the start of application count as transitional goods on later export or re-import (code C718). All dates of the regulation are in the E12 EUDR guide.

Country risk in the pulp chain

Implementing Regulation (EU) 2025/1093 assigns the countries of production to three risk classes. For pulp and paper importers this is the main lever, because risk is determined by the country of production, not by the seat of the supplier. All EU member states, the United States and Canada count as low-risk countries: the importer collects the Article 9 information including geolocation but does not have to carry out a risk assessment and mitigation. Brazil, Chile, Indonesia and most other pulp countries are standard risk with full due diligence. Russia and Belarus are high-risk countries; the authorities check more intensively, and sanctions come on top.

For geolocation, wood is tied to the area where it was harvested: points up to four hectares, polygons above, with the harvest period and the scientific species names. For pulp from plantation wood these are the plantation areas of the pulp mill, for pulp from natural forest the harvest areas. Certificates such as FSC and PEFC are information for the risk assessment under Article 10 but do not replace the plot data. How the timber chain is built as a whole is in E13 Timber industry.

What goes into the customs declaration

On import, the reference number of the due diligence statement is entered with document code C716 and the ten-digit TARIC code; on export, Article 26(4) applies with the eight-digit CN code. The exemptions of the paper chain have their own codes: Y133 for products made from recovered material, used goods and waste; Y190 for packing material in use; Y129 for goods under an ex code that are out of scope, such as bamboo paper; Y132 for production before 29 June 2023. Without a valid entry the import is not allowed after the check. All codes are in the TARIC codes glossary, the export cases in E6 Export and re-import.

Where the EUDR and the PPWR meet

Packaging manufacturers and companies placing packaged goods on the market have been dealing with the Packaging Regulation (EU) 2025/40 since 12 August 2026: declaration of conformity under Annex VIII, technical documentation, substance limits, from 2028 the harmonised labelling. The EUDR starts elsewhere, at the origin of the fibre. Both obligations meet in master data: the material composition per component that the PPWR requires also says whether virgin fibre is involved, and thus whether the packaging as traded goods falls under the EUDR. Whoever keeps both regulations in one dataset answers the question "recovered or virgin fibre" once and uses it twice. The PPWR obligations in detail are in Declaration of conformity and PPWR deadlines.

How to proceed

1. Check the item master against Annex I. Mark all headings of chapters 47 and 48 and 4415, exclude printed matter of chapter 49 and bamboo goods.
2. Clarify the fibre share per item. Entirely recovered fibre: not covered, file the supplier's evidence. Virgin-fibre share: covered, determine the origin of the virgin fibre.
3. Fix the role per item. Import from a third country or production from your own forest: operator. EU input material: downstream or trader.
4. Separate the packaging cases. Empty packaging as traded goods is covered, packaging around your own goods is not. Keep both apart in the item master.
5. Assign the country risk per source and set the scope of checks accordingly: information collection at low risk, full due diligence at standard risk.
6. Request plot data. GeoJSON in WGS 84, point up to four hectares, polygon above, harvest period, species names. Check before import, not at the customs declaration.
7. Brief the customs agent. C716 with the reference number for covered goods, Y133, Y190 and Y129 for the exemptions, each per goods item.
8. Keep numbers and evidence for five years, per item and batch, with a time stamp.

Polygon One brings item master, supplier requests, plot checks by satellite and the submission of the due diligence statement together in one platform; for packaging manufacturers, EUDR origin and PPWR declaration of conformity sit in the same record. We show what that looks like in your chain in a [Demo].

Frequently asked questions

Does paper fall under the EUDR?

Yes. Annex I covers paper and paperboard of chapter 48 as an ex heading under the commodity wood, as well as pulp of chapter 47. Excluded are products made entirely from recovered material and paper made from bamboo, rattan, reed or straw.

Is recycled paper exempt from the EUDR?

Products made entirely from recovered paper or other recovered material are out of scope. As soon as virgin fibre is contained, the product is covered, and due diligence relates to the origin of the virgin fibre.

Do I need a due diligence statement for shipping cartons?

No, if the cartons pack your goods. Packing material that supports, protects or carries another product is not covered from the moment it is used. Whoever imports empty cartons as goods or produces them from EU forest is an operator, however.

Are books and catalogues covered?

No. Printed matter of chapter 49 is not in Annex I. The unprinted paper before it was covered; the printer is a downstream operator for that paper and keeps the numbers received.

Does the deferral to June 2027 apply to small paper merchants?

Not for pulp and paper. These products were already in the annex to the EU Timber Regulation, and Article 38(3) excludes them from the deferral. Micro and small enterprises must deliver for paper from 30 December 2026 as well.

Which customs code applies to recycled paper on import?

Y133, the code for products made from recovered material, used goods and waste. Y190 applies to packaging in use, Y129 to bamboo paper under an ex code, C716 with the reference number to covered goods.

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Articles 2, 4, 5, 9, 10, 13, 26 and 38 and Annex I as amended by Delegated Regulation (EU) 2026/2102 with its explanatory paragraphs and note 4. Regulation (EU) No 995/2010, Annex. Implementing Regulation (EU) 2025/1093. DG TAXUD TARIC document on the EUDR, revision 1 of 23 September 2026. Commission FAQ on the EUDR. As at 27 September 2026. This article is not legal advice.