The European Union Deforestation Regulation (EUDR) aims to ensure that products derived from certain commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood) that are placed on the EU market or exported from the EU have not caused deforestation or forest degradation during their production.
The EUDR will enter into application on 30 December 2026.
What is the EUDR, and why does it matter?
The EU Deforestation Regulation (EUDR) aims to minimise the EU’s contribution to deforestation and forest degradation worldwide, thereby helping to reduce global deforestation, greenhouse gas emissions and biodiversity loss.
As well as wood and woodfibre-based products, it applies to a wide range of relevant commodities including cattle, cocoa, coffee, palm oil, rubber and soya – and products made from them.
The EUDR applies to all trade within and between the 27 EU member states, as well as to exports from and imports to the EU.
The initial EUDR (No 2023/1115) entered into force on 29 June 2023, with its main provisions originally set to apply from 30 December 2024 onwards. Following two successive extensions, an amending regulation – Regulation (EU) 2025/2650, agreed in December 2025 - changed certain core obligations for operators and traders. Consequently, the revised EUDR will now enter into application for relevant products placed on the EU market starting on 30 December 2026 for non-SME entities, as well as for all operators dealing in products covered by EU Timber Regulation (EUTR).
Under the revised framework, the obligation to submit an EUDR Due Diligence Statement lies solely with the operator who first places a product on the EU market. The first downstream operator must collect and retain the DDS Reference Number of this statement, while actors further down the supply chain are not required to carry out additional due diligence procedures.
EUDR latest updates
Legislative amendments adopted in December 2025 shifted primary due diligence responsibilities to the Operators first placing products on the EU market, exempting subsequent downstream operators and traders from submitting Due Diligence Statements (DDS).
The obligation to submit a DDS lies solely with the Operator who first places an EUDR relevant product on the EU market.
Downstream operators and traders do not submit DDSs, nor do they pass DDS Reference Numbers (RN) further down the supply chain. Only the first Downstream operator must collect and retain the RNs received from their direct suppliers acting as Operators.
Core requirements for importing products into the EU from non-EU countries remain largely unchanged; the first importing operator must perform complete due diligence and submit a DDS.
In May 2026, the European Commission released updated Guidance and Frequently Asked Questions (FAQ) documents, which provide essential practical frameworks to support consistent compliance across supply chains.
How is Sappi preparing for the EUDR?
All Sappi Europe mills are preparing to be fully EUDR compliant ahead of the revised December 2026 implementation deadline. We work closely with our wood and pulp suppliers, to ensure supply chain traceability throughout our value chain. Around 80% of our wood-based raw materials are sourced within Europe – primarily from Austria, Finland and Germany – through long-established suppliers and partners.
Sappi Europe has thoroughly analysed the impact of the revised EUDR framework on our EUDR compliance solutions and internal procedures. Our paper mills supply customers either via our EU-based trading company or directly, depending on the customer’s location and the product supplied. In both cases, Sappi acts as a Downstream operator and is not required to pass Reference Numbers further down the supply chain. For detailed guidance, please review Sappi Europe’s dedicated EUDR briefing (linked below).
Additionally, we are extending our existing due diligence system to cover all EUDR requirements. EUDR-affected supply chains for Sappi’s operations in South Africa and North America are also equipped to provide customers with necessary compliance information upon request.
These preparations do not take place in isolation. We have been actively involved in sector-wide collaboration – working through organisations such as Cepi (Confederation of European Paper Industries) and national industry associations to help shape industry-wide solutions and approaches. This work continues.
While under the revised EUDR, the due diligence model has shifted to a system where core responsibilities lie with the first operator placing an EUDR-relevant product on the EU market or exporting it, its ultimate objectives hold firm. The regulation aims to minimize the EU’s contribution to deforestation and forest degradation worldwide, thereby contributing to a reduction in global deforestation and reducing the Union’s contribution to greenhouse gas emissions and global biodiversity loss. Sappi continues to support this mandate through its unwavering commitment to sustainable, deforestation-free supply chains.