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A forest view
EUDR and paper
Do you work with books, magazines or other paper or printed products? Here's what you need to know about the European Union’s Deforestation Regulation (EUDR).
How to ensure EUDR compliance for your paper products
Simply put, EUDR aims to counteract deforestation by making sure that everyone that is part of a supply chain that places print and paper products on the market ascertains the origin of the raw material and assesses the risk associated with it. That's why traceability throughout the value-chain has become such a central part.
Holmen Board and Paper fully supports the objective and goal of EUDR, to halt deforestation in order to fight climate change and protect biodiversity. There are three compliance requirements in the regulation. The relevant commodity or relevant product must be:
- Deforestation free
- Legally produced
- Covered by a due diligence statement
EUDR defines the following commodities as relevant, including all products derived from them: cattle, cocoa, oil palm, coffee, rubber, soy and wood. To know whether your product falls under the EUDR scope, identify the Harmonized System (HS) codes related to your business and check the EUDR Annex I list.
What applies to your product?
Continue reading on this page if you buy or develop products from printing and writing paper, such as book paper, graphical paper, notebook paper or gift wrap. Or go to:
EUDR implementation timeline
Follow the most recent news and coming steps to align with the EUDR administration process.
15 April 2025 – The EUDR FAQ 4th iteration was released, entailing simplifications
The fourth iteration of the EUDR guidance document "Frequently Asked Questions - Implementation of the EU Deforestation Regulation" was released, and can be downloaded here.
The document clarifies that the submission of the due diligence statement which includes geolocation is a requirement for a product covered by EUDR to be placed on the EU market or exported from the EU. The operator first placing the product on the market needs to verify and be able to prove that the geolocation is correct. This geolocation information is to be provided in a due diligence statement for the product in the EUDR Information System. Downstream operators and traders will then be able to provide the necessary information by including the relevant reference number for the parts of their relevant products that have already been subject to a due diligence (see FAQ 1.13, 3.4 and 3.5). Depending on their role, they may or may not be required to submit a new due diligence statement into the system. However, if downstream operators or traders obtain or are made aware of information pointing to non-compliance, they must immediately inform the competent authorities and offer all necessary assistance to facilitate checks.
This process has been simplified compared to what was stated earlier. The fourth iteration of this implementation FAQ also highlights that it is the responsible authorities that enforce the EUDR by checking the information submitted into the system. All the geolocation data is stored within the EUDR information system and referred to by the reference number. This means that it will no longer be required of downstream operators and traders to gather and store all information that was stated in the regulation's article 9 (see FAQ 3.4 and 3.5).
Furthermore, it will be sufficient for the downstream operator or trader ton provide the reference number and verification number for the product, and they do not have to access or review the actual geolocation data (see FAQ 3.6 and 7.7).
30 June 2025 – Holmen's Swedish units can offer EUDR reference for deliveries on request
Holmen's paper is produced within EU, at Braviken and Hallsta paper mills. This applies to graphical paper, book paper, notebook paper, gift paper, trayliner, void fill and containerboard components.
Holmen's Invercote paperboard is also produced within EU, at Iggesund mill.
For these products, after June 30, 2025, you can obtain the EUDR reference number, which is to be entered into the EUDR platform Traces, on request.
This will be the reference number and verification number from the Acceptance server. Data in the due diligence statement at this stage will be based on information about the raw material that Holmen Group is in control of, which is the wood harvested by Holmen Forest. Suppliers from outside of the Holmen Group will be onboarded and integrated into the Holmen's platform during second half of 2025.
12 September 2025 – Holmen Board and Paper can trigger an automatic distribution of CSV-files
Since September 12th, 2025, Holmen Board and Paper can trigger an automatic distribution of CSV-files with the required reference numbers retrieved from the EU Traces test environment to the customer, as long as reference numbers have been allocated to the units. These numbers are test-numbers until we go live with the EU production environment, which we will do before the official final date of EUDR implementation.
There will be situations where delivered units will still lack a reference due to the whole value chain being in a transition period. Not all raw material used for production will have a reference due to earlier sourcing of raw material while we are in this transition period. As the process moves forward, this will gradually reduce.
Holmen commits to comply with all relevant aspects with the EUDR from the time EUDR comes into force. If you are a customer who would like to have our compliance document for the EU or for the UK, please ask your sales or customer service contact in Holmen Board and Paper.
24 November 2025 – Holmen Board and Paper submits DDS to the live server
Holmen Board and Paper is ready for the possible go-live of EUDR, where the entire upstream due diligence process will be in place by December 30. However, we wish to emphasise that an actual go-live is still awaiting final approval from the EU.
We have now connected our ERP-system to the production environment of the EU information system and began submitting Due diligence statements (DDS) to the Live server. Customers can request to receive CSV-files with references or connect electronic messaging via Papinet (standard).
In some cases, units might be delivered which do not yet have a reference number due to a transition period. As the process moves forward, this will gradually reduce. One concern the EU has, is that it might not be able to handle the data-flow in relation to EUDR. The data-load has exceeded their expectations, which is to be observed when the EUDR is going to be implemented as currently planned.
30 December 2025 – Awaiting further information about the date for EUDR implementation
EUDR is scheduled to enter into effect 30 December, 2025. But there has been a request for an additional 12-month delay, due to concerns with the IT platform. There has also been proposals for amendments. As of 28 November, 2025, The Parliament voted to support simplification measures and one year postponement for all companies.
The European Parliament and the Council both need to formally adopt an amendment before it can come into effect. This information will be updated when we know their decision.
Regarding products in the transition period
For products which will have been placed on the market before EUDR has entered into effect, and are produced after 29 June 2023, there will be a transition period where special rules apply. 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 are providing 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.
Here's how the traceability works
The first operator that places a relevant product on the EU market, or exports it, is called the upstream operator. The upstream operator submits a due diligence statement (DDS) including the geolocations of the commodity's origin, into the EU information system. By doing this, the operator assumes the legal responsibility for the commodity being compliant with EUDR.
For paper produced at Holmen's mills in Sweden, the commodity is wood, and the upstream operator is Holmen Forest. Downstream operators and traders refer to the reference and verification numbers that they get from the supplier who made the latest due diligence statement in the value chain. The EU information system keeps track of how all the references and verifications are related back to the original geolocations.
The value chain of paper products made in Holmen's Swedish mills
All Holmen's printing and writing paper, including graphical paper, book paper, news paper, notebook and gift paper, is produced within EU, at Braviken and Hallsta paper mills. The wood raw material is supplied by Holmen Forest. All wood originates from Holmen’s own land or is purchased by Holmen Forest from other forest owners within the EU or Scandinavia.
For all purchases Holmen Forest has a due diligence process to secure that national laws and the guidelines are followed. This includes risk assessment and risk mitigation activities.
In total, 90–95 percent of the timber flow to Holmen’s Swedish mills originates from Swedish forests. The remainder is sourced from Finland, Norway, Estonia, and Latvia. Regardless of origin, Holmen applies the same stringent traceability standards.
Holmen does not buy wood from forests that:
- Are classified as key habitats in Sweden according to the Swedish Forest Agency’s definition and methodology.
- Are protected for nature conservation purposes.
- Are primary forests, i.e. layered natural forests of varying age with a significant presence of old, large trees and dead wood in various stages of decomposition.
- Have been harvested illegally.
- Originate from genetically modified trees.
- Are located in areas where human rights are actively violated.
- Possess high conservation value.
Each harvesting operation is assigned a unique identity that follows the timber throughout the entire flow.
How to get and use the EUDR reference number for your products
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.
The wood raw material used at Holmen Board and Paper is fully traceable from the origin of the harvest to forwarding, transport, and delivery to our industry. In our production, we assign the incoming reference number to the paper tambours and reels made from the incoming material, thereby also connecting the reference number to the order that will be delivered.
We submit our own due diligence statement to the EU Information system, which automatically gives us new reference and verification numbers. These numbers will be sent to you as part of the delivery documentation, as an EDI integration or a .csv file which you can import directly into a system of your choice.
You will need to keep track of these numbers to refer to the origin of your own products if you are to make your own due diligence statement in the EU Information system. In doing that, you will get the next reference and verification numbers from the EU Information system, to send to your customers, so that you can provide them with traceability for your products.
