For Europe’s wood and paper supply chain, the question is no longer whether the EU Deforestation Regulation will be delayed again.

The more difficult question is deciding exactly which tonne, pallet, paper grade or packaging product carries an obligation when the rules begin to apply on 30 December 2026.

That became considerably clearer on September 17.

The European Union published Commission Delegated Regulation (EU) 2026/2102, finalizing the latest changes to the EUDR product list after the European Parliament and Council scrutiny period.

The regulation enters into force on September 18.

Large and medium operators must comply with the EUDR from 30 December 2026. Micro and small operators already covered by the existing EU Timber Regulation also move onto the EUDR on that date, while most other micro and small operators receive until 30 June 2027.

For pulp, paper and packaging companies, this closes one important uncertainty.

Wood remains one of the seven commodities covered by the regulation.

Wood residues and sawmill by-products under HS 4401 remain within scope.

Pulp and paper under Chapters 47 and 48 remain covered.

Wooden tools and kitchenware remain.

Printed products under Chapter 49, meanwhile, had already been removed from the EUDR through the EU’s December 2025 amendments.

But the final scope also contains increasingly detailed exemptions for recovered material, second-hand goods and packaging being used to transport another product.

That is where compliance becomes much less intuitive.

Under the final EUDR framework, knowing that something is made from wood or paper is no longer enough. Companies increasingly need to know where the material came from, what stage of its lifecycle it is in and what the product is being used for at the moment it enters the market.

For an industry accustomed to classifying material primarily by grade and fibre furnish, that creates a second classification system layered on top of the physical product.

Wood and paper remain firmly inside the EUDR

The July review did not produce the broad removal of forest products that some businesses had sought.

The European Commission specifically considered a request to remove wood residues and sawmill by-products under HS 4401.

It rejected that request.

The Commission said those materials were already regulated under the EU Timber Regulation and that removing them did not receive support from the relevant industrial sectors.

That means products including wood chips, sawdust and certain wood residues remain part of the EUDR product architecture unless another exemption applies.

Pulp and paper also remain clearly covered.

The revised Annex I now identifies:

Chapter 47: pulp of wood

and

Chapter 48: paper and paperboard and articles of paper pulp, paper or paperboard.

The wording is broad.

It covers much more than market pulp and printing paper.

It reaches many cartons, sacks, labels, packaging papers and converted paper products classified within Chapter 48.

For mills and converters, that means EUDR cannot be treated simply as a forestry-department issue.

It extends into purchasing, fibre recipes, ERP data, customs classification, supplier declarations and customer documentation.

But recovered paper creates a major dividing line

The most important exemption for the paper industry is recovered fibre.

The finalized Annex I excludes recovered waste and scrap paper and products derived from recovered waste and scrap from the Chapter 47 and 48 entries.

This has an important practical consequence.

A paper product produced entirely from material that has completed its lifecycle and would otherwise have become waste can fall outside the EUDR.

But a recycled-content claim does not automatically create an exemption.

If a product contains virgin pulp, that virgin component remains relevant under the regulation.

The Commission’s 2026 guidance puts this clearly: products made entirely from recycled or recovered material are outside the EUDR, but where non-recycled material is incorporated, that portion remains subject to the regulation. It specifically gives virgin pulp in paper production and new timber used to repair pallets as examples.

That creates a significant distinction for recycled paper producers.

A 100% qualifying recovered-fibre product can have a very different EUDR profile from a product using 95% recovered fibre and 5% virgin pulp.

From a papermaking perspective, those products may look almost identical.

From an EUDR perspective, they are not.

Pre-consumer scrap is not automatically the same as recovered waste

This may become one of the easiest mistakes for converters to make.

Paper manufacturing generates large quantities of internal and downstream trim.

Edge waste.

Box-plant scrap.

Sheeting waste.

Printing make-ready material.

Converting offcuts.

Those materials are commonly described commercially as recycled fibre when they return to the paper system.

But EUDR draws an important legal distinction between material that has completed its lifecycle and become waste and by-products generated during a manufacturing process using material that was not waste.

The general Annex I rule specifically says the waste exemption does not automatically extend to manufacturing-process by-products where the process began with non-waste material.

That means companies cannot simply build their EUDR logic around the percentage of “recycled fibre” shown on a product specification.

They may need to distinguish:

post-consumer recovered material,

qualifying waste,

pre-consumer manufacturing residuals,

and virgin fibre.

That is a much more demanding chain-of-custody exercise.

It also means the environmental language used by the packaging industry and the regulatory language used by EUDR will not always align perfectly.

“Recycled” can be a broad commercial term.

EUDR needs a more precise origin story.

A pallet can be both in scope and outside scope

Wooden packaging demonstrates how unusual the new classification logic can become.

Consider a new wooden pallet.

If it is manufactured and placed on the EU market as a product in its own right, it is covered by the EUDR.

The wood needs to satisfy the applicable due diligence requirements.

But put goods onto that same pallet and use it to support, protect or carry those goods, and the EUDR treatment changes.

The finalized delegated regulation excludes single-use packing material and packing containers when they are being used to support, protect or carry another product.

It extends the principle to reusable packaging as well: reusable packing used for this purpose falls outside the EUDR from the moment it is first used in that role and onwards.

That means product identity alone does not determine scope.

Use does.

A new pallet being sold to a logistics company is one situation.

A pallet moving cartons through a supply chain is another.

The physical object may be identical.

Its EUDR status can differ.

That exemption extends beyond wooden pallets

The July delegated regulation is important because it generalizes the packing-material principle beyond the old HS 4415 wording.

The Commission explicitly states that single-use and reusable packing materials covered by other relevant Annex I categories should also be excluded when they are being used exclusively to support, protect or carry another product.

For the paper and packaging industry, this is significant.

A corrugated transport pack supplied and sold as packaging may fall under the Chapter 48 product scope.

That same packaging, when used to support or protect the goods being placed on the market and presented with those goods, can fall within the packing exemption.

Again, the distinction is not simply:

Is this paper packaging?

It is:

At this transaction point, is the packaging itself the commercial product, or is it functioning as packing for something else?

That is a question procurement and customs teams will have to answer consistently.

Reusable packaging becomes particularly interesting

The Commission also wanted to avoid creating unnecessary repeated obligations around circulating transport equipment.

The final act clarifies that reusable packing clearly suitable for repeated use falls outside the EUDR after it has entered use supporting, protecting or carrying another product.

That matters for:

pallet pools,

reusable crates,

wooden cable drums,

transport boxes,

and other closed-loop packaging systems.

Without this clarification, the same durable packaging asset could theoretically trigger repeated regulatory events as it circulated between businesses.

The final structure focuses the obligation much more heavily on the material when it first becomes a product rather than every subsequent trip through the supply chain.

But repairs create another boundary.

The Commission’s current guidance says that where a used pallet is repaired with new non-recycled wood, the EUDR applies to the newly introduced wood even though the existing recycled or previously used portion may remain outside scope.

That turns maintenance into another material-traceability issue.

EUDR creates a strange but logical advantage for genuinely recovered fibre

The circularity implications are worth considering.

Virgin fibre remains subject to EUDR because the regulation wants visibility back to the land where the relevant wood was produced.

Qualifying recovered waste can fall outside the regulation because it has already completed a product lifecycle.

That gives recovered fibre an administrative characteristic that virgin fibre does not have.

It would be an overstatement to call this a major economic advantage by itself.

Recovered fibre economics are still driven overwhelmingly by collection, quality, yield, energy, freight and paper-market demand.

But for converters comparing fibre inputs, compliance complexity now becomes another difference between virgin and recovered feedstocks.

That could particularly matter for highly recycled packaging grades.

A mill producing a 100% recovered-fibre containerboard product has a different traceability architecture from one blending virgin kraft fibre into the furnish.

The recycled product does not become inherently “better.”

It becomes different from an EUDR documentation perspective.

Mixed-fibre mills face the harder data problem

The challenge increases when one mill uses several fibre streams.

Imagine a board mill using:

OCC,

recovered mixed paper,

purchased market pulp,

internal broke,

and externally sourced converting waste.

The paper machine sees furnish.

EUDR sees origin categories.

Some inputs may be outside scope because they are qualifying recovered waste.

Some may remain inside scope because they contain virgin wood.

Some manufacturing residuals may not qualify for the end-of-life exemption.

That means mills may need to preserve enough information through procurement and production systems to know which fibre carries which regulatory status.

The difficulty is particularly acute because fibres mix.

Once pulp enters the machine chest, there is no practical way to point at a fibre in a finished sheet and identify the forest from which it came.

Compliance therefore has to be managed through documentation and controlled material flows before the furnish physically loses its identity.

This is not unusual for certification systems.

But EUDR introduces a legal rather than voluntary layer.

Species data could become an underestimated paper-industry challenge

The traceability requirement goes beyond country of origin.

Article 9 requires relevant wood products to carry information identifying the common name and full scientific name of the wood species used.

The Commission’s updated guidance says this requirement also applies to highly processed products such as paper.

Where species can vary, the operator may have to provide the list of species that may have been used.

That sounds simple in a sawmill.

It can become much more complicated in pulp.

A market-pulp bale may contain several species.

A mill may alter fibre recipes.

Hardwood and softwood furnish can come from different suppliers and regions.

Integrated producers may have more direct access to forestry data.

Converters purchasing paper from multiple mills are farther removed from the plot.

This is exactly why EUDR implementation is as much an information-management exercise as a forestry exercise.

The finished paper provides almost none of the information required by looking at it.

The data have to travel with the transaction.

The 2025 simplification changed where responsibility sits

Companies preparing for EUDR should also be careful not to build compliance systems around the regulation’s original 2023 architecture.

The EU significantly amended the system in December 2025.

Under the revised framework, responsibility for submitting the due diligence statement is concentrated primarily on the operator first placing a relevant product on the EU market or exporting it.

Downstream operators and traders were relieved of the earlier requirement to submit their own due diligence statements for products already covered upstream.

Non-SME downstream businesses retain registration and information obligations, while reference numbers or simplified-declaration identifiers move through the supply chain.

This is a significant simplification.

It also makes the quality of the first operator’s due diligence more important.

The paper converter at the end of a documented EU supply chain may no longer need to recreate geolocation work already performed by the first operator.

But somebody still has to do that work at the beginning.

EUDR has therefore not removed traceability.

It has moved more of the administrative burden toward the point where the relevant commodity first enters the regulated supply chain.

Small primary producers have another route

The 2025 amendments also created a special regime for micro and small primary operators in low-risk countries.

Instead of filing repeated due diligence statements for every transaction, qualifying primary producers can submit a one-time simplified declaration.

They can also use the postal address of relevant plots in place of geolocation coordinates under specified conditions.

This is particularly relevant to smaller foresters.

But it should not be confused with a general SME exemption.

The category is specifically defined.

And the 30 December deadline still applies to micro and small operators dealing in products already covered by the EU Timber Regulation, while the later June 2027 deadline applies to most other micro and small operators.

“Low risk” does not mean “outside the EUDR”

Country benchmarking is another area where language can create misunderstanding.

The EU currently classifies only four countries as high risk:

Belarus,

North Korea,

Myanmar,

and Russia.

Countries including Canada, the United States, Australia, China and all EU Member States are classified as low risk.

Countries not specifically listed as either low or high risk remain standard risk.

For wood buyers, low-risk sourcing can simplify parts of due diligence.

It does not remove the product from the EUDR.

Operators still need the required information, and the product must still be deforestation-free and legally produced.

Risk classification affects how the due diligence and enforcement architecture operates; it does not convert wood from a low-risk country into an exempt commodity.

That distinction matters for companies sourcing North American pulp into Europe.

Canadian or U.S. origin can reduce one part of the regulatory risk calculation.

It does not mean the mill can simply write “Canada – low risk” on a purchase order and consider EUDR finished.

Wood still carries the forest-degradation test

EUDR also treats wood differently from some of the other commodities in one important respect.

The basic deforestation cutoff remains 31 December 2020.

Relevant commodities must have been produced on land that has not experienced deforestation after that date.

For wood, there is an additional condition: harvesting must not have induced forest degradation after the cutoff.

This is why salvage logging and natural disturbances need careful treatment.

A forest damaged by wildfire, storm or disease is not automatically non-compliant simply because its condition deteriorated.

The regulatory question is whether the harvesting activity itself induced the prohibited degradation.

That reinforces the need to distinguish correlation from causation in forestry documentation.

The penalty language also needs precision

Another figure likely to receive increasing attention before December is 4%.

EUDR requires Member States to establish effective, proportionate and dissuasive penalties.

For a legal person, the maximum available fine must be at least 4% of its total annual EU-wide turnover in the financial year preceding the penalty decision and may need to be higher if necessary to remove the economic benefit obtained from the infringement.

That does not mean every EUDR mistake automatically produces a 4% fine.

The regulation establishes the required penalty framework available to Member States.

The distinction is important.

But the potential scale makes classification errors more consequential than an ordinary customs-data problem.

The final product list does not remove the need for interpretation

This may be the most important lesson from the September publication.

Annex I is now much clearer.

It explicitly addresses:

recovered materials,

second-hand products,

samples,

packing materials,

and a range of detailed HS-code questions.

Yet clarity has produced more boundaries, not fewer.

Companies now have to distinguish between:

a pallet and a pallet in use,

recovered waste and manufacturing scrap,

paper packaging sold on its own and packaging accompanying another product,

100% recovered paper and paper containing virgin pulp,

an upstream operator and a downstream operator,

low-risk origin and an actual exemption.

The industry wanted legal certainty.

It now has considerably more of it.

But certainty does not mean simplicity.

Paper converters may need to map transactions rather than products

That changes how companies should think about implementation.

A traditional product-scope exercise starts with the catalogue.

Which SKUs are under Chapter 48?

Which are under Chapter 49?

Which are packaging?

EUDR increasingly requires another layer:

What is happening to this product in this transaction?

A corrugated case sold to a food company is a packaging product.

The same case filled with food and placed on the market with the product inside is functioning as packing.

A virgin wooden pallet being sold is relevant.

After first use in an exchange pool, its treatment changes.

A paperboard product made from recovered waste can sit outside the regulation.

Introduce virgin pulp and EUDR returns for that component.

That means ERP design may become as important as tariff classification.

The system has to understand more than what the SKU is called.

It has to understand the material history and commercial event.

This could change supplier questionnaires dramatically

Paper and packaging procurement teams are likely to feel the effect first.

Traditional purchasing data might include:

grade,

basis weight,

brightness,

strength,

price,

delivery time,

and certification.

EUDR adds different questions.

Which HS code?

Which fibre components are virgin?

Which qualify as recovered waste?

Who was the first operator?

What is the due diligence statement reference?

Which countries produced the wood?

Which species are involved?

Is the product itself being placed on the market, or is it functioning as packing?

These are not questions the salesperson can always answer from a technical data sheet.

They reach into forestry, legal and customs systems farther upstream.

The result may be a substantial change in what counts as a complete supplier record.

Certification will not remove the need to understand scope

This is another area where companies should avoid over-simplification.

Many European pulp and paper supply chains already use FSC, PEFC and other forestry certification systems.

Those systems can provide useful evidence within an EUDR risk assessment.

But EUDR is a separate legal regime.

The first compliance question remains whether the product is in scope and whether the legal requirements for that transaction have been satisfied.

A certified pallet can still need EUDR due diligence when sold new.

A recovered-fibre product can fall outside the regulation even without needing a virgin-forest origin trail.

The legal scope has to be established before supporting evidence can be evaluated.

The final three months are therefore less about forest policy than data architecture

The forest-products industry has debated EUDR for years.

The December deadline now brings the issue down to operating detail.

For a paper mill, the hardest question may not be whether it supports deforestation-free sourcing.

Most established producers already have extensive forestry-control systems.

The harder questions can be much more mundane:

Can procurement identify the correct fibre category?

Can the ERP store the due diligence reference?

Can the company distinguish qualifying recovered waste from production scrap?

Can species information travel through the pulp chain?

Can sales determine when packaging is being sold as a product and when it is merely accompanying another product?

Can the business preserve the information required if regulators ask for it years later?

Those are implementation problems.

And December 30 is increasingly close.

The July simplification did not give wood and paper an exit

That may ultimately be the clearest takeaway from the final product list.

Several sectors succeeded in removing specific products.

Leather left the EUDR scope.

Certain rubber products were removed.

Other narrowly defined products were added with later application dates.

Wood and paper did not receive the same broad relief.

Instead, the EU refined their boundaries.

Recovered waste received clearer treatment.

Used products were clarified.

Packing exemptions were broadened.

But the core wood, pulp and paper supply chain remains firmly inside the regulation.

For pulp and paper companies that were waiting for the final scope before committing to implementation, that waiting period is effectively over.

EUDR compliance will depend on answering one question correctly

For every material flow, companies increasingly need to know:

What exactly is this product, from which material, at this point in its lifecycle and at this point in the supply chain?

That question sounds administrative.

It determines almost everything that follows.

Whether EUDR applies.

Who files the due diligence statement.

Whether a simplified declaration is available.

Whether geolocation is required.

Whether an exemption applies.

Whether only the virgin component has to be traced.

Whether the product is simply packaging carrying another good.

The final legislation gives businesses more answers than they had six months ago.

It also makes clear why a generic statement such as “all paper is covered” or “recycled paper is exempt” is no longer precise enough.

EUDR has turned wood and fibre provenance into a product-classification problem as much as a forestry problem.

For paper and packaging companies, getting that classification right may be the most important compliance job between now and 30 December.

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Last Updated on 17/09/2026 by Jota Machinery