The EU Deforestation Regulation (EUDR), effective from 30 December 2025, aims to prevent deforestation-linked products from entering the EU market. This regulation significantly impacts industries reliant on paper products, including print and direct mail marketing.
What is the EUDR?
The EUDR requires companies to ensure that certain commodities—such as wood, palm oil, soy, beef, coffee, cocoa, and rubber—and products derived from them are:
- Deforestation-free (not produced on land deforested after 31 December 2020)
- Legally produced according to local laws
- Fully traceable back to their source via due diligence and geolocation data.
Impact on Print and Direct Mail Marketing
For businesses importing or producing paper-based materials in the EU, the EUDR introduces several considerations:
- Sourcing Scrutiny: Ensuring paper comes from EUDR-compliant sources is crucial. Non-compliance may lead to fines or blocked shipments.
- Supply Chain Disruption: Suppliers may face challenges meeting traceability requirements, potentially causing delays or reduced availability.
- Increased Costs: Implementing due diligence measures (e.g., audits, certifications) may raise costs for print and mailing campaigns.
- Brand and Compliance Risk: Using non-compliant materials could damage brand reputation or result in regulatory penalties.
Key Clarifications from April 2025 EUDR Guidance
Recent updates provide some important clarifications:
- Packaging Scope: Standalone packaging (e.g., pallets sold separately) falls under EUDR. However, packaging used solely to support, protect, or carry another product is excluded. Repaired packaging using new materials must undergo due diligence.
- Geolocation Data Sharing: Upstream operators are not legally obligated to share geolocation data with downstream customers, but you should contact your paper and packaging supplier to get clarity on the information they are able to share with you and the requirements for you to pass it on to your own customers
- Contractor Responsibilities: When a company contracts another to supply products, the entity making the product available on the EU market is responsible for compliance.
- Exemptions: Items of correspondence (e.g., letters) and product samples for testing or evaluation are excluded from EUDR scope.
Who Needs to Prepare?
- Marketers using print (flyers, catalogs, postcards)
- Print and mailing service providers
- Publishers and packaging printers
- B2B companies with EU customers
How to Prepare
- Audit Your Supply Chain: Identify all print and paper suppliers. Inquire about their EUDR preparedness, traceability systems, and certifications (e.g., FSC or PEFC).
- Choose Certified Partners: Collaborate with printers and paper suppliers who can guarantee EUDR-compliant sourcing and documentation.
- Stay Informed on Due Diligence Obligations: Understand your role—whether you’re an “operator” (first to place the product on the EU market) or a “trader” (within the supply chain)—as duties differ.
- Train Your Team: Educate procurement, compliance, and marketing teams on EUDR basics and its impact on decision-making.
- Monitor Updates: Stay abreast of evolving implementation guidance.
Resources for Further Information
- EU Commission EUDR Official Page: https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en
- Two Sides Europe: https://www.twosides.info
- FSC (Forest Stewardship Council): https://fsc.org/en/fsc-eudr
- PEFC (Programme for the Endorsement of Forest Certification): https://pefc.org/eudr