Processes established to ensure traceability
The EUDR (EU Deforestation Regulation) aims to prevent trade in goods that contribute to deforestation and forest degradation worldwide. It is part of the EU’s Forest Strategy 2030. The scope and requirements of the EUDR have been simplified in several steps since the regulation was adopted and postponed, first in 2024 and then in 2025.
At Holmen, we see our work on the EUDR as an opportunity to further leverage our sustainable business practices. Thanks to our different established processes, we can clearly demonstrate that our products do not contribute to deforestation and that they are based on a responsible value chain.
EUDR implementation timeline
Follow the timeline to see important dates in the EUDR implementation process.
June 2023 – EUDR was formally adopted
The European Deforestation Regulation (EUDR) was formally adopted in June 2023, after decisions in the EU Parliament and Council. The aim of EUDR is to fight climate change and biodiversity loss by preventing deforestation or forest degradation linked to EU consumption of cocoa, coffee, palm-oil, soya, wood, rubber and cattle products.
Enforcement of the regulation was originally set for 30 December 2024, then postponed to 30 December 2025, and later further postponed to December 2026 with amendments and simplification measures.
November 2025 – Holmen submits DDS
Since November 2025, we at Holmen Board and Paper have connected our ERP system to the production environment of the EU information system and have begun submitting Due Diligence Statements (DDS) to the live server. Customers can request CSV files with references or electronic messaging via Papinet (standard). In some cases, units may be delivered without a reference number, as we are in a transition period which in December 2025 was prolonged until December 2026. Please note that adjustments may be made as new details will be provided by the EU. We will monitor the information communicated by the EU and update accordingly when new information becomes available.
December 2026 – EUDR scheduled to be in effect
According to the decision of 18 December 2025, the EUDR is scheduled to take effect on 30 December 2026. The decision was communicated together with amendments and simplification measures. Link to press release: https://www.europarl.europa.eu/news/en/press-room/20251211IPR32168/deforestation-law-parliament-adopts-changes-to-postpone-and-simplify-measures
We are monitoring information from the EU to gain further details on specifications and guidelines for implementation. This page will be updated when new information becomes available.
Regarding products in the transition period
Special rules will apply for products that are produced after 29 June 2023 and placed on the market during the transition period before EUDR has entered into effect. The time of harvest of the commodity will be referred to as the production date.
Wood is placed on the EU market when it is harvested. Paper and paperboard are products derived from wood. During the transition period, and until EUDR enters into effect, wood and timber products produced within the EU have to comply with the rules of EUTR, the European Timber Regulation. The forest raw material used in Holmen's Swedish mills, Braviken, Hallsta and Iggesund, has been harvested inside the EU market and in compliance with EUTR. For the Workington mill we can provide reference numbers on request. And for transitional material, that is, material produced prior to 29 June 2023, there will be no requirement for EUDR reference numbers.
Please note that adjustments may be made as new details are to be provided by the EU.
EUDR compliance in practice
Only businesses that first place a relevant product on the EU market are responsible for submitting due diligence statements – not the operators or traders who commercialise it later in the chain.
The operator that first places a relevant product on the EU market is referred to as the upstream operator, or the first operator. This operator submits a Due Diligence statement (DDS) including the geolocations of the commodity's origin, into the EU information system. By doing so, the operator assumes the legal responsibility for ensuring that the commodity complies with the EUDR.
EUDR compliance with Holmen’s products
For paperboard and paper products, the key raw material is wood. There is no conversion on Holmen land from forest to agriculture use. We have had long-standing procedures in place for tracing all timber purchased, established well before the EUDR.
The upstream operator for our mills in Sweden, within the EU, is Holmen Forest. In our mill in Workington, UK, our process for acquiring raw material is equally established and strict. This enables you, when necessary, to demonstrate that products purchased from us are EUDR compliant.
Obligations of downstream operators or traders
Downstream operators and traders are businesses further along the value chain that place products on the EU market using material already covered by a Due Diligence Statement (DDS). Their input materials are already “EUDR declared” as deforestation free by an upstream operator. Their obligations are described in short in a press release by the European Parliament, to be clarified more in detail during spring 2026.
How to obtain the reference and verification number
Please note that adjustments to the following process may be made as new details will be provided by the EU. The reference and verification number submitted by Holmen Forest to the EU Information system refers to the declaration of due diligence (DDS, in Swedish FOTA) for the specific harvesting operation. In our production, we assign the incoming reference number to the paper tambours and reels made from the incoming material, linking the number to the order that will be delivered. These numbers can be provided as part of the delivery documentation, either via EDI integration or a .csv file, which you can import into your preferred system. In some cases, units may be delivered without a reference number, as this is a transition period.
Future development of the EUDR
The EUDR will enter into force the 30 December 2026 for large companies such as Holmen, but the latest communication from the EU included simplifications to the regulation. The EU will carry out a review of these simplifications by 30 April 2026, meaning that the final design of the updated regulatory framework has not yet been fully established. We will monitor the information communicated by the EU and update accordingly when new information becomes available.