The European Union Deforestation Regulation (referred to below as ‘the EUDR’ or ‘the Regulation’) marks a significant milestone in the EU's ongoing efforts to combat deforestation and forest degradation globally. The Regulation replaces the EU Timber Regulation, extending the mandatory due diligence requirements to cover a broader range of commodities – covering wood, palm oil, coffee, cocoa, soy, rubber and cattle.

What is the EUDR? 

The EU Deforestation Regulation lays down rules regarding the placing and making available on the EU market (as well as the export from the EU) of relevant products that contain, have been fed with or have been made using relevant commodities – namely cattle, cocoa, coffee, oil palm, rubber, soya, and wood.

The purpose of this is to minimise the EU’s contribution to deforestation and forest degradation worldwide, and thereby contributing to a reduction in global deforestation; and to reduce the EU’s contribution to greenhouse gas emissions and global biodiversity loss.

As stated in the introduction above, the Regulation replaces the EU Timber Regulation (EUTR) – not only to cover a wider range of commodities – but also to require more stringent and detailed due diligence up and down the supply chain. 

Why has this been introduced? 

The EU point out within the text of the Regulation itself that the EU imported and consumed one third of the globally traded agricultural products associated with deforestation between 1990 and 2008. Over that period, EU consumption was responsible for 10% of worldwide deforestation associated with the production of goods or the provision of services. Moreover, the EU also recognise that while the existing legislation (EUTR and other regulation) has had a positive impact on forest governance, the objectives – namely to curb illegal logging and related trade, and to reduce the consumption of illegally harvested timber in the Union – have not been met, and so they concluded that focusing solely on the legality of timber was not sufficient to meet these.

The EU are therefore aiming to remedy this situation with the EUDR, by more effectively tracking these seven commodities (including wood) that are most commonly associated with deforestation. 

So, what does it mean in practice? 

Under the new Regulation, relevant commodities and relevant products shall not be placed or made available on the market or exported, unless all the following conditions are fulfilled:

1. they are deforestation-free;
2. they have been produced in accordance with the relevant legislation of the country of production; and
3. they are covered by a due diligence statement.

In practice, this means that companies placing products onto the EU market which contain any of the seven commodities covered by the EUDR (with some exceptions), need to follow the due diligence procedures outlined in the Regulation – such as collecting and retaining information about products and their constituent commodities, having a due diligence system in place, undertaking risk assessments related to these commodities, and entering due diligence information into the EU’s ‘information system’ (known as the Traces System).

What does the recently announced delay to implementation mean in practical terms?

The EUDR entered into force on 29 June 2023, with a transitional period until compliance is required (known as ‘entry into application’) of 18 months, meaning that the Regulation was due to enter in application on 30th December 2024.

However, the EU recently extended this transitional period, given the challenges still faced by many businesses to become compliant and due to delays by the EU Commission in providing guidance and other critical information updates. Therefore, the new date for entry into application is 30th of December 2025.

The aim of the Regulation is to secure that the use of forests as a raw material is transparent throughout the value chain and that the forest is used in a responsible way. At UPM, we are deeply committed to sustainable forestry practices, and we support the Regulation’s overall aims and purpose. 

Despite the announced one year delay, UPM Pulp plans to continue EUDR implementation broadly along the existing time schedule. Providing the data ahead of time will allow our customers to test their own systems and due diligence processes, and help us to make adjustments if necessary in a timely fashion. We aim to provide customers with data as soon as possible in early 2025, provided that other matters, such as the ‘go-live’ of the EU Commission’s Traces IT System, are successfully implemented.

Provision of information to our customers

There are two main scenarios for how pulp gets to our customers with regard to the EUDR and related data provision.

‘Traces Pulp’: this is how we describe pulp that’s either made in our Finnish pulp mills inside the EU or made in our Uruguayan pulp mills that is shipped directly into the EU market. For this scenario, we will provide our customers with EUDR Reference Numbers (and related Verification Numbers) provided through the EU Traces IT system. This means that customers won’t directly receive (or need) information such as geolocational data or harvest dates etc.

‘Third Country Pulp’: this is how we describe pulp that is made in our Uruguayan mills and sold to customers outside of the EU market.  Since some of those customers (or their customers, etc.) will want to place products that contain UPM pulp products onto the EU market at a later date, they will need due diligence information in order to do that. We will therefore provide those customers with the information required to enter due diligence statements into the EU Traces IT System, as well as other required due diligence information.

In both scenarios above, customers will receive automated information via email with pulp deliveries (or through direct connections between UPM Pulp and customer IT systems). These will contain the usual delivery notes as well as additional information files containing EUDR information.  In addition, we also provide additional due diligence evidence documentation to ensure that customers have the information they need to inform their own due diligence, via a dedicated webpage, which you can access here.

Seeking More Information

Please seek out guidance from the EU directly or from a third party when determining the full impact of the Regulation on your business activities.

Read more about EUDR on EU's official website here.

¹The formal name of the Regulation is as follows: REGULATION (EU) 2023/1115 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 31 May 2023, on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010.