The EU Deforestation Regulation (EUDR), enacted in June 2023, is a groundbreaking piece of legislation designed to prevent deforestation-linked products from entering the EU market. It applies to seven key commodities, including timber and paper, which makes it highly relevant for publishing houses. The regulation comes into effect on December 30, 2025, for large companies and June 30, 2026, for small and medium enterprises (SMEs).
For publishing houses, compliance is particularly complex. Books are composite products that require tracking of multiple materials, primarily wood-based paper. The intricate, multi-tiered global supply chains in publishing make it challenging to collect supplier geolocation data, ensure legal compliance, and conduct due diligence at each stage.
This article provides an in-depth analysis of how EUDR affects publishing houses, outlining the core compliance challenges and exploring how advanced digital solutions can facilitate efficient data collection, risk assessments, and legal compliance.
Understanding the EUDR
The EUDR replaces the EU Timber Regulation (EUTR) and introduces stricter requirements for proving that wood-based products do not contribute to deforestation or forest degradation.
Deforestation-Free Sourcing Requirements
The regulation mandates that businesses demonstrate deforestation-free sourcing by ensuring that no paper used in book production originates from land cleared after December 31, 2020.
Geolocation Data and Risk-Based Due Diligence
Companies must also collect and store geolocation data, providing exact coordinates of the land used for raw material production. In addition, businesses are required to conduct risk-based due diligence, assessing their supply chains for deforestation risks and implementing mitigation measures where necessary.
Due Diligence Statement Submission
Before placing books or paper products on the EU market, companies must submit a Due Diligence Statement (DDS) through the EU Information System, demonstrating compliance with EUDR requirements.
Why Publishing Houses Are Affected
As paper is derived from timber, publishing houses are directly impacted by EUDR’s requirements. Unlike industries where raw materials can be sourced from a single, direct supplier, books undergo multiple transformations across several supply chain tiers.
The Multi-Tiered Nature of Publishing Supply Chains
Publishers commission and distribute books, while printers source paper and manage book production. Paper mills process timber into usable paper, and wood producers harvest raw materials from forests.
Each of these entities must comply with EUDR, ensuring that materials are sourced responsibly. If a single entity in the supply chain fails to provide the necessary compliance documentation, it puts the entire supply chain at risk.
The EU Deforestation Regulation (EUDR) affects every stage of the publishing supply chain, requiring publishers, printers, paper mills, and wood producers to ensure that materials used in book production comply with deforestation-free sourcing requirements. The availability and use of reference numbers for due diligence statements depend on where compliance is first established in the supply chain.
Supply Chain Responsibilities
Publishers may be the first stakeholders to act as operators under the EUDR if they are responsible for placing books on the EU market. In this case, publishers must ensure that the paper used in their books meets EUDR standards by obtaining due diligence documentation, which may include reference numbers from their suppliers’ due diligence statements. If the publisher is not the first operator, they must ensure that all suppliers upstream provide the necessary compliance records, including reference numbers, if available.
Printers, when acting as operators, must ensure that the paper they source is EUDR-compliant. They are responsible for collecting due diligence statements from their paper suppliers, including geolocation data for the land where the timber used in the paper was harvested. If the printer is the first operator, they must generate a new due diligence statement and reference number. If not, they must retain and reference the existing one.
Paper mills must document the origin of all wood pulp used in production and confirm that timber suppliers adhere to EUDR requirements. This involves verifying that the wood used is deforestation-free and that suppliers provide precise geolocation data and compliance records. If a paper mill is the first operator, they issue the due diligence statement with a reference number, which is then passed along the supply chain.
Wood producers, at the beginning of the supply chain, must provide geolocation data for harvested timber and demonstrate compliance with both local forestry laws and EUDR requirements. If they sell directly into the EU market, they must issue a due diligence statement with a reference number that will track compliance throughout the supply chain.
Compliance Challenges
Compliance with the EUDR presents logistical and documentation challenges throughout the supply chain:
- Books stored in EU warehouses: Books that are placed on the EU market (i.e., made available for sale or distribution) must fully comply with EUDR requirements before they can be legally sold or distributed. Reference numbers from due diligence statements, if available, help verify compliance.
- Books in transit through the EU are exempt from EUDR requirements. However, customs authorities require proof of transit status, which may include a transit declaration, bill of lading, or other shipping documents confirming that the books are not intended for sale within the EU.
- Reprints and new editions: Even if a book retains the same ISBN, each reprint or new edition may require a separate due diligence statement, as compliance must be verified for each batch of materials used in production. If a reference number exists from a previous compliance check, it may facilitate the process, but a new due diligence statement is still required.
The Role of Reference Numbers in Compliance
- If a supplier has already conducted due diligence and provided a reference number, downstream actors (such as publishers) may reference it in their compliance checks. However, each entity placing products on the EU market must conduct its own due diligence assessment and submit a new Due Diligence Statement (DDS) where required. Reference numbers help track compliance but do not transfer legal responsibility for EUDR obligations.
- If no prior reference number exists, or if changes to the product (such as reprints) require new due diligence, the responsible operator must generate a new due diligence statement and obtain a reference number.
- Reference numbers allow authorities to track compliance records efficiently, but their presence depends on where in the supply chain due diligence is first conducted.
Failure to comply with the EUDR at any stage of the supply chain can result in delays, fines, or the removal of non-compliant books from the EU market. Because reference numbers do not automatically transfer compliance obligations, every stakeholder must verify their role in the supply chain and ensure that all necessary due diligence steps are met.
Core Compliance Challenges for Publishing Houses
Publishing houses face several core challenges in complying with the EUDR, particularly in the areas of traceability, legal compliance, and supply chain management. One major issue is traceability and data collection.
Traceability and Data Collection Challenges
ISBNs are not relevant for EUDR compliance, as traceability is based on the batches of paper used in production. Each shipment requires a separate Due Diligence Statement (DDS) linked to the specific batch of raw material used.
Many publishers rely on third-party suppliers, which makes obtaining direct geolocation data difficult. The complexity of multi-tiered supplier networks further obscures visibility into the origins of wood-based materials, creating additional challenges in ensuring compliance.
Legal and Regulatory Complexity
Timber laws vary across jurisdictions, making compliance verification for international suppliers more challenging. Some regions lack accurate land-use records, which complicates the collection of required geolocation data.
Additionally, suppliers must demonstrate that their sourcing practices comply with EUDR’s definition of deforestation-free production and do not involve forest degradation, as defined by the regulation. This means ensuring that forests are not converted into plantation forests or significantly altered in ways that impact biodiversity.
Potential Risks of Non-Compliance
Companies that fail to meet EUDR requirements can face fines of up to four percent of their total EU revenue. Non-compliant products may be confiscated at customs, and businesses could be excluded from public procurement contracts. Reputational damage is also a serious consequence, as public blacklisting can harm long-term business relationships and consumer trust.
Supply chain disruptions are another concern for publishers. IIf suppliers fail to comply with EUDR, they may be excluded from the market, potentially impacting the availability and pricing of paper. Both EU-based and non-EU paper suppliers must comply with EUDR’s legal and deforestation-free requirements. Smaller publishers, in particular, may face higher compliance costs, which could put them at a competitive disadvantage compared to larger industry players with more resources to manage regulatory requirements.
How TradeAware Facilitates EUDR Compliance for Publishers
One of the primary challenges publishers face is collecting supplier geolocation data and assessing risk levels across multiple supply chain tiers. Manual verification is inefficient, costly, and prone to errors.
TradeAware provides a streamlined solution by:
- Automating geolocation collection to ensure paper is sourced from deforestation-free zones.
- Maintaining a centralized supplier compliance database for real-time decision making.
- Providing AI-powered risk assessment tools to flag high-risk suppliers before compliance issues arise.
- Integration Legal Expertise from global law firm CMS to automate and streamline legal risk assessment
- Integrating seamlessly with publishing ERP systems, reducing operational friction.
Legal Risk Assessment for EUDR
LiveEO is partnering with global law firm CMS to enhance legal risk assessment for EUDR compliance, ensuring that businesses can navigate both EU regulations and local forestry laws effectively. Legal compliance under EUDR is not just about traceability; it also requires a thorough analysis of regional forestry laws, verification of supplier adherence to sustainability regulations, and proactive mitigation of potential legal risks.
TradeAware’s CMS-backed legal risk assessment streamlines this process by automating supplier legal verification, ensuring that all entities within the supply chain comply with both EU and local forestry laws.
It assigns risk scores to suppliers based on compliance data and past performance, allowing businesses to identify and address potential issues before they become regulatory liabilities.
By integrating legal assessments, publishers can reduce uncertainty in regulatory compliance, strengthen supply chain integrity, and ensure that all sourcing practices align with EUDR requirements. This automation also saves significant amounts of time in operational work, reducing the manual burden of legal verification and allowing businesses to focus on strategic supply chain management.
Best Practices for EUDR Compliance in Publishing
Ensuring compliance with the EUDR requires publishing houses to adopt a structured approach to supply chain management, legal verification, and risk mitigation. Implementing a digital traceability system is essential for efficiently tracking the origins of paper and verifying that all materials meet deforestation-free requirements.
Establishing proactive engagement with suppliers ensures they fully understand EUDR obligations and can provide the necessary geolocation data and compliance documentation.
Automated risk assessment tools help identify and mitigate potential supply chain risks, allowing publishers to address compliance gaps before they become regulatory issues. Additionally, integrating legality assessments into the compliance process ensures that supplier documentation aligns with both EU and local forestry laws, streamlining verification efforts and reducing operational burdens.
Conclusion
EUDR compliance presents significant challenges for publishing houses. It requires comprehensive supply chain oversight, legal risk management, and real-time traceability. Failure to comply risks financial penalties, product seizures, and reputational harm.
By leveraging technology-driven compliance solutions, such as TradeAware’s automated supplier data collection and CMS-backed legal risk assessments, publishers can navigate EUDR compliance efficiently, reduce regulatory risks, and safeguard their market position.
The publishing industry must act now to integrate compliance frameworks, ensuring uninterrupted market access while contributing to global sustainability efforts.
.webp)
