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 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)
EUDR update January 2026
In late December, the European Union adopted an amendment to EUDR. The amendment was published in the Official Journal on December 23, 2025 (EU) 2025/2650.
The main changes are:
- New compliance deadline: Implementation of EUDR is postponed to December 30, 2026 for large and medium operators and June 30, 2027 for micro and small operators
- Printed products excluded: Certain printed products (Chapter 49 of the Combined Nomenclature such as books, newspapers, printed pictures) are now outside the scope of EUDR
- Due diligence limited: Only the first operator placing the wood-based commodity or product on the EU market makes the Due Diligence Statement to the EU Traces system
- Review clause: European Commission will conduct a simplification review of the regulation and present a report by April 30, 2026.
UPM’s Due diligence system description
UPM’s due diligence system description is available. Please note that the due diligence system will be updated as relevant updates, such as country level risk classification are available.
You can find our Due Diligence System description here:
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 2026.
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 paper businesses are proactively preparing for full compliance by December 30, 2026. 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.
1. I buy paper from a UPM paper mill located in the EU and sell it within the EU. Do I need EUDR reference numbers or data?
No. In these cases, UPM Communication Papers is always the first downstream operator or further down the supply chain. Under the amended EUDR, reference numbers are not required to be shared beyond the first downstream operator.
2. My company is located in EU, but I buy paper from the UPM Caledonian paper mill which is located outside the EU. Who provides the EUDR data?
In this case, UPM’s sales company will handle the importing, as the first operator placing the paper on the EU market and submits the Due Diligence Statement (DDS). UPM will then provide the EUDR reference number to you as our direct customer and first downstream operator. No further obligations apply to you on passing on the reference number or submitting a DDS. You will however need to collect and keep the reference numbers.
3. I buy paper from UPM Caledonian paper mill outside the EU and then my customer imports it into the EU. What are my obligations?
In this case, your customer is the first operator placing the product on the EU market. They are responsible for submitting the DDS and for providing EUDR reference numbers to the first downstream operator buying the paper. UPM will provide you with the required upstream EUDR information.
4. I reimport paper into the EU that was originally produced in a UPM EU paper mill. Do I need to submit a DDS?
No. Paper has already fulfilled EUDR requirements in the EU, so when it is reimported there will be no further obligations. EU will clarify the process still, but we are expecting that proof that paper was produced within EU or generic code used in customs’ process should be sufficient.
5. I only buy, sell, or import printed products such as books, magazines or newspapers. Does EUDR apply?
No. Finished printed products (CN code ex49) are excluded from the scope of the EUDR. No EUDR obligations, including reference numbers or DDS, apply.
Please find further information on the EUDR roles and responsibilities in EU publication EUDR supply chain infographics (3rd edition) - Publications Office of the EU.