Expert knowledge

Implementing the EU Deforestation Regulation (EUDR) presents unique challenges for paper manufacturers, as pulp deliveries typically lack batch-level identification, warehouse management follows a first-in-first-out principle, and once pulp enters the pulper it can no longer be traced to specific deliveries. To ensure supply chain traceability and remain compliant, we apply a batch-based approach: each production period is defined as a batch, and all relevant DDS numbers for the pulps processed during that period are collected, verified, and documented. This meets the EUDR requirement to report origin data “as precisely as possible.” While this approach naturally introduces some uncertainty—since certain pulp lots may stay in storage longer than average and others may be processed immediately—it guarantees that no unverified or unassessed raw materials enter production. For pulp or wood raw materials imported from non-EU countries, we perform a documented due diligence process that includes full supply chain transparency, geolocation data for the forest plots of origin, and harvesting permits, as required by the EUDR. Even in countries classified as low-risk under the EU Benchmark 1 system, data and documentation must still be collected and archived. This approach provides a practical, auditable, and scalable solution for deforestation-free sourcing in the paper industry, enabling manufacturers to align with EUDR compliance requirements while maintaining efficient production and inventory management.

The EU Deforestation Regulation (EUDR) introduces a country benchmarking system that classifies countries as low, standard, or high risk for deforestation and forest degradation. While a “low-risk” classification can simplify due diligence obligations, companies are not exempt from proving full supply chain traceability and documenting the origin of raw materials. The first benchmarks published by the EU have sparked criticism for being politically influenced, with countries like Russia and Belarus marked “high risk,” while major hubs such as China and India received “low risk.” For operators, the real challenge remains: credibly tracing and documenting supply chains rather than relying solely on the benchmarking system.