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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).
EUDR has been pushed forward in time – and changed
The implementation date for EUDR, the European Deforestation Regulation, has now been formally postponed by one additional year, to December 30, 2026. The regulation will also be changed – several paper end-use products such as books, magazines, newspapers, and other printed material will now be removed from the EUDR product scope.
EUDR aims to counteract deforestation by making sure that relevant commodities or products are deforestation free, legally produced, and covered by a due diligence statement. Now, the traceability requirements will be simplified. But the origin of the raw material will still need to be ascertained – and the associated risk assessed – in the value chain, for the products covered by the EUDR scope.
Regardless of what the EUDR legislation ultimately will look like, Holmen has well-implemented processes for traceability, and traceability will continue to be in our focus. All fibre used in our products originates from sustainably managed forests.
What applies to your product?
Printed products will be excluded, according to the European Parliament, but in some cases, packaging materials are included. Read more on the following pages:
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).
24 November 2025 – Holmen Board and Paper submits DDS to the live server
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 had, was that it might not be able to handle the data-flow in relation to EUDR when the EUDR is going to be implemented. We will monitor the information communicated by the EU and make the necessary adjustments as soon as they are announced.
30 December 2026 – EUDR scheduled to be in effect for medium and large companies
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.
We are monitoring information from the EU to gain further details on specifications and guidelines for implementation. This page will be updated as soon as new information becomes available.
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.
Please note that adjustments may be made as new details are provided by the EU.
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 relevant 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.
Please note that adjustments to this process may be made as new details are provided by the EU.