The European Union Regulation on Deforestation-free Products (EUDR) marks a significant milestone in the EU's ongoing efforts to combat deforestation and forest degradation globally. This regulation replaces the EU Timber Regulation, extending the mandatory due diligence requirements to cover a broader range of commodities. The EUDR entered into force on 29 June 2023, with a transition period for compliance of 18 months.
UPM is in full preparation to ensure the compliance by 30th December 2025. The aim of the regulation is to secure that the use of forests as a raw material is transparent throughout the value chain and that the forest is used in a responsible way. At UPM, we are deeply committed to sustainable forestry practices, and we support the regulation’s overall targets.
Compliance with EU Deforestation Regulation (EUDR)
UPM’s EUDR implementation
Status May 7, 2025
UPM’s Due diligence system description
UPM’s due diligence system description is now available. Please note that the due diligence system will be updated as relevant updates, such as country level risk classification are available.
Sending of EUDR reference numbers from UPM EU mills
The sending of the first reference numbers and verification numbers has begun and you will gradually begin to see these on your delivery notes. These numbers are generated as we begin receiving EUDR-related information from our suppliers.
EUDR: What Does It Mean?
The regulation entered into force on 29 June 2023 and is currently in a transition period that ends on 30 December 2025. The original application date 30 December 2024 was postponed by twelve months as per Regulation (EU) 2024/3234.
Under the regulation, it is prohibited to place or make available on the EU market, or to export from the EU, any relevant commodities or products made using such commodities unless they meet the following criteria:
Deforestation and Forest Degradation-Free
Compliance with Country Legislation
Due Diligence Statement
Recognizing the obligations set forth by the EUDR, UPM Papers are proactively preparing for full compliance by December 30. During this transition period, the company is taking necessary measures, such as:
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- Engaging with Suppliers and Customers: Actively collaborating with suppliers, customers, and competent authorities to share information and ensure a seamless transition to the new regulation.
- Implementing Compliance Measures: Adapting internal processes and systems to meet EUDR requirements effectively.
Update: December 17th, the proposal to delay EU's Regulation on Deforestation-Free Products (EUDR) by 12 months reached its final approval. The delay has now been approved by all relevant EU bodies. You can read the EU’s announcement here.
At UPM Communication Papers we continue to implement our EUDR processes as previously planned to ensure compliance with the Regulation.
EUDR FAQ
Please be aware that our comments refer to EUDR compliance related to the supply of paper materials to our direct customers based on UPM’s interpretation of publicly available information on EUDR. We recommend customers consider their own EUDR obligations when selling products to their own customers. UPM does not offer legal advice or consult on EUDR compliance. We recommend requesting guidance from the EU or a third party when determining the impact of the regulation to your own business activities.
EUDR applies only to products listed in Annex I of the Regulation.
This EU website lists the competent authorities on the EUDR per Member State. For goods imported to the EU or exported from the EU, the responsible customs authority is also involved.
No, they do not. For large and medium operators and traders, EUDR will be applied starting December 30, 2025. This means that the products placed on the EU market before that date do not have to comply with EUDR.
Full EUDR compliance is required from December 30, 2025 for the first wood-based product entering the EU market. In practice this means that all wood harvested and placed on the EU market from December 30, 2025 onwards need to be compliant with EUDR. From there the compliance requirement is cascaded downwards in the value chain.
Also products further down the value chain (such as books) need to be compliant as of December 30, 2025 if they are 1) imported into the EU after the transition period and 2) not using paper (or other relevant raw material) produced by UPM’s EU paper mill.
Case example 1: A UPM paper mill is producing paper, which is made from raw material that was harvested and placed on the EU market in October 2025. The relevant paper product is placed on the EU market by UPM in January 2026. Based on the Regulation, this paper product does not need to fulfill full compliance requirements of the EUDR as the raw material was harvested and placed on the EU market during the transition period .
Case example 2: A company that has purchased paper products produced at a UPM EU paper mill in September 2025 and will produce end-products are sold on the EU market in February 2026. These end-products do not need to be EUDR-compliant, as both the wood was harvested and placed on the EU market, and paper was produced during the transition period.
The EU Commission has taken a stand on the matter in its Q&A and guidance document. If a relevant commodity or a relevant product is placed on the EU market before the end of the transition period, the obligations of an operator placing on the EU market or exporting a derived relevant product, or of a trader making the product available on the EU market, is limited to being able to show that the relevant commodity or product was indeed on the EU market before the end of the transition period. In addition, the products falling under the scope of the EU Timber Regulation (EU) 995/2010 shall comply with that regulation.
For the paper products the obligation of the operator (and of non-SME traders) will be limited to gathering verifiable evidence to prove that the relevant commodity (wood) used to produce these was placed on the EU market before the entry into application.
Under the Regulation, any operator or trader who places relevant commodities or relevant products on the EU market, or exports such products from the EU, needs to comply with EUDR. The rules apply for both exports from Europe, and products in –or imported to – the EU. The regulation applies for any quantity of product, large or small.
Annex I states that EUDR does not apply to goods produced entirely from material that has completed its lifecycle and would otherwise have been discarded as waste. This means that 100% recycled material is not in the scope of the Regulation.
However, if the product contains non-recycled (virgin) material, then that material is in the scope of the Regulation.
Certification schemes such as FSC™ or PEFC can be used by supply chain members as part of their risk assessment, to the extent that the certification covers the information needed to comply with their obligations under the Regulation. However, operators and traders which are not considered SMEs will still be required to exercise due diligence as set out in the Regulation.
No, EUDR does not apply to materials used exclusively as packing material to support, protect or carry another product placed on the EU market – even if they are listed under a relevant CN code. This is clarified in Annex I of the regulation.
Penalties for non-compliance include, for example:
- a maximum fine of at least 4% of the total annual turnover in the EU of the non-compliant operator or trader,
- a temporary prohibition against selling relevant products on or exporting them from the EU market,
- or confiscations.
When importing products that fall under the scope of the EUDR into the EU market, the importer must exercise due diligence and submit a due diligence statement in the EUDR Information System (EU Traces). In such cases, the importer will need to gather information relating to the products, as listed in Article 9 of the EUDR.
If the paper products have been produced at UPM’s EU paper mills:
The EU Commission has stated in its FAQ that if the products imported contain raw materials that were already placed on the EU market - and are therefore already subject to a previous due diligence statement - the importer should be able to refer to such due diligence statement.
If the paper products have been produced at UPM’s non-EU paper mills (excluding UPM Blandin): UPM will provide the necessary and relevant data for its customers, so that the subsequent members in the value chain are able to submit the due diligence statement.
For raw materials originating from the EU, this means:
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- due diligence statement reference numbers,
- and verification numbers.
For non-EU raw materials, the relevant information includes:
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- GeoJSON files,
- information concerning wood species,
- country of production,
- and the UPM due diligence system description.
A publisher is transforming an EUDR relevant product into another relevant product and placing the paper product on the EU market for the first time.
Depending on the size of the company, a publisher can be considered as a non-SME downstream operator or an SME downstream operator.
If you are a non-SME downstream operator, you must submit a due diligence statement for the paper product to the EUDR Information System (EU Traces) before placing it on the EU market. You can refer to UPM’s due diligence statements by including the relevant reference numbers while ascertaining that due diligence was exercised in accordance with the EUDR (Art. 4.9; FAQ 3.4). A publisher is responsible for the compliance of the relevant product.
Small publishers that are identified as an SME downstream operator, and are placing a new (and relevant) product on the EU market, is not required to exercise the due diligence or submit a new due diligence statement to the EUDR Information System Based on EU’s EUDR guidance, it must, however, keep a record of the received due diligence reference numbers (Art. 4(8)).
Based on the EU’s guidance, you are not the first operator placing the paper products on the EU market, as they were already placed on the EU market by UPM. Therefore, you are considered a non-SME trader, not an operator. Obligations for non-SME traders are the same as for non-SME operators; this means that you must submit a due diligence statement to the EUDR Information System. Since the paper has already been subject to due diligence by UPM, you can refer to UPM’s due diligence statements by including the relevant reference numbers while ascertaining that due diligence was exercised in accordance with the EUDR (Art. 4.9; FAQ 3.4).
UPM’s sold-to customer is responsible for EUDR obligations; in this example it would be the publisher.
UPM is a non-SME operator and trader.
All UPM paper products are in the scope of EUDR.
UPM’s EUDR due diligence system description is available here. Please note that all countries have been assigned a standard level of risk in 2023; the EU will publish their country risk assessment clarifying low and high risk countries no later than June 30, 2025. The country risk assessment is needed to finalize the work required for the due diligence system. Therefore, our due diligence system description will be updated as relevant information becomes available.
We have developed a holistic project around EUDR to develop a feasible solution for our customers. We have conducted extensive end-to-end system testing during December 2024 and January 2025 and made a final solution go-live in early March. We have already full technical solutions in place to support our EUDR process. From April 2025 onwards, we have gradually started to share EUDR reference numbers and verification numbers with our customers.
We have also documented our UPM Paper Due Diligence system description that you can find here.
Please contact your company’s UPM sales representative. If you have no direct sales contact, please contact us via our our contact form.
Reference numbers and verification numbers can be accessed using UPM Customer Online and UPM delivery notes. All different formats of customer delivery notes are covered e.g. container delivery notes and delivery notes with barcodes.
In UPM Customer Online you can find the downloadable xml file format of the delivery note with the EUDR reference number and verification number. These are available in the UPM Customer Online Delivery module behind each delivery document.
EDI connections will also be used to share delivery notes with those customers that have existing connections with UPM.
No, UPM is currently not planning on providing the reference numbers or verification numbers on the product packaging.
UPM paper businesses aim to begin application of the Regulation as soon as possible, already during the transition period.
As of April 2025, the sending of the first reference numbers and verification numbers has begun and you will gradually begin to see these on your delivery notes. These numbers are generated as we begin receiving EUDR information from our suppliers.
While EUDR compliance is required only from December 30, 2025 onwards for the value chain’s first relevant product entering the EU market, we are already sharing the data we have available from our suppliers. Kindly note that the products in current deliveries are placed on the EU market during the EUDR transition period and are not yet subject to the requirements of the EUDR. The due diligence statements during the transition period cover the products to the extent that the wood contained in the products has been subject to due diligence in accordance with the EUDR.
We wanted to start proactively sending reference numbers and verification numbers as soon as our technical solution was ready. This helps us to ensure that the solution and process with the EUDR Information system (EU Traces) is working. This will also enable our customers to test their own processes utilising the reference number and verification numbers we are sharing.
As of April 2025, the sending of the first reference numbers and verification numbers has begun and you will gradually begin to see these on your delivery notes. Reference numbers and verification numbers are generated as we begin receiving EUDR information from our suppliers. Due to the gradual process not all deliveries will include reference numbers, as of now. Further, they cannot be allocated for specific deliveries.
Currently there is no standard set-up or connection to third-party solutions. UPM’s paper businesses have developed its own solution for delivering EUDR reference numbers.
Reference numbers and verification numbers can be accessed using UPM Customer Online and on UPM delivery notes. EDI connections will also be used to share delivery notes with those customers that have existing connections with UPM.
If you are an existing UPM customer, you can register for UPM Customer Online here.
When creating a due diligence statement (DDS), the EUDR Information system shares an alphanumeric reference number (14 digits) and an alphanumeric verification number (8 digits). They confirm validity of the due diligence statement. Please see two sample numbers below:
- Reference nr.: 25FIOR8FQ11543
- Verification nr.: TDIY0D8W
No, a product will not have the same reference number over time, as the wood raw material will change.
Based on the Regulation, there is no pre-determined unit of reference for the creation of a due diligence statement. UPM’s paper businesses have chosen to create one reference number per production run. One production run may include one or more customer orders, and one customer order may include one or more products with different reference numbers.
In the case of paper materials from UPM EU paper mills, we will conduct the due diligence process and other obligations as described by the Regulation and provide our customers with the required reference numbers and verification numbers. No geolocation data is needed in this case.
In the case of paper materials from UPM’s non-EU paper mills (excluding UPM Blandin), UPM will provide the necessary and relevant data so that the subsequent members of the value chain are able to submit the due diligence statement.
For raw materials originating from the EU, this means:
- reference numbers, and
- verification numbers
For non-EU raw materials, the relevant information includes:
- GeoJSON files,
- information concerning wood species,
- country of production, and
- the UPM due diligence system description
No, that information is not visible for the next step in the value chain via the reference numbers. The associated information behind the reference numbers is only visible for the relevant authorities.