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EUDR and paper

Do you work with books, magazines or other products within paper and print? 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 puts 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.

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 has to submit 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.

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 offer EUDR reference on deliveries

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 all these products, after June 30, 2025, you can obtain the EUDR reference number, which is to be entered into the EUDR platform Traces.

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.

Q3-Q4, 2025 – Holmen Board and Paper will submit DDS to the live server

Holmen Board and Paper will begin submitting Due diligence statments (DDS) to the Live server of the Information system during second half of 2025.

During Q3 2025, onboarding of suppliers outside Holmen Group will be initiated.

During Q3-Q4 2025 due diligence statements by Holmen Board and Paper will be submitted to the Live server of the Information System, where suppliers from outside of Holmen Group will also be referenced. Reference numbers and verification numbers from the Live server will be possible to include in the delivery information.

30 December 2025 – EUDR in effect for large and medium enterprises

EUDR enters into effect for medium and large operators and traders, 30 December, 2025.

For products which were placed on the market before 30 December, but produced after 29 June 2023, there is 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 is a derived product of 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 has been harvested inside the EU market and in compliance with EUTR.

30 June 2026 – EUDR in effect for micro and small enterprises

EUDR enters into effect for micro and small enterprises, 30 June, 2025. Micro and small enterprises are defined as companies with less than 50 employees and a turnover less than 10 million Euro or a balance sheet size of less than 10 million Euro. 

Read more about EU:s definition of small and medium-sized companies.

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.

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, 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 find and use the reference number

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 normal delivery documentation, in print or pdf, and as an .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.

EUDR traceable paper reel at Holmen Hallsta mill

Do you have questions?

Sign up to get an invite to our next free EUDR webinar.

Find your contact

Holmen Paper Nordic & International

+46 11 235000

Vattengränden 2

SE-60188 Norrköping

Sweden

Holmen Paper Nordic & International

+46 11 235000

Vattengränden 2

SE-60188 Norrköping

Sweden

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Holmen Board and Paper produces premium paperboard and innovative paper products for everything from cosmetics, electronics, pharmaceuticals and food to books, magazines, advertising and transport packaging. Our products are appreciated by conscious customers due to their exceptional properties and low climate footprint. We use fresh fibre from sustainably managed forests and have a total of four production facilities in Sweden and in the UK.

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