Cepi Unveils Updated Guidance on EU Deforestation Regulation, Bringing Greater Clarity to Europe's Pulp and Paper Industry

New industry guidance outlines revised compliance obligations, simplified due diligence procedures and clearer rules for businesses across the European forest-based value chain.

Cepi, the European association representing the paper industry, has released its updated Guidance on the Revised EU Deforestation Regulation (EUDR), providing essential clarity on the implementation of the revised regulatory framework and its implications for Europe's pulp and paper sector.

The updated guidance reflects the targeted amendments introduced through Regulation (EU) 2025/2650 in December 2025, alongside the European Commission's May 2026 simplification package, updated guidance, FAQs and subsequent secondary legislation.

Developed to establish a common understanding of EUDR obligations across the pulp and paper industry, the document addresses practical compliance challenges and clarifies the responsibilities of operators, downstream operators and traders throughout the value chain.

A MORE CLEARLY DEFINED REGULATORY FRAMEWORK

The revised EUDR introduces important distinctions in the responsibilities of companies depending on their position in the supply chain and their business size.

Cepi's guidance explains how these changes affect first-time operators, downstream operators, traders and micro or small primary operators. It also provides practical scenarios to help companies identify their regulatory responsibilities and navigate the requirements more effectively.

A significant development is the simplification of obligations for downstream operators and traders. First downstream operators and traders are required to collect and retain relevant due diligence reference numbers, where applicable, while further downstream businesses have more limited information-retention responsibilities.

CLEARER RULES FOR RECYCLED MATERIALS AND PACKAGING

The guidance also provides important clarification on product scope, particularly for recovered and recycled materials.

Products produced entirely from material that has completed its lifecycle and would otherwise have been discarded as waste are excluded from EUDR requirements. This clarification is particularly relevant to the paper recycling value chain, including post-consumer and pre-consumer recovered paper.

Further distinctions are provided for packaging materials, clarifying when packaging is excluded from the Regulation and when it remains subject to compliance obligations.

Printed products under Chapter 49 of the Combined Nomenclature, including books and newspapers, have also been removed from the scope through the December 2025 amendments.

SIMPLIFIED PROCEDURES, WITHOUT COMPROMISING TRACEABILITY

The guidance outlines the responsibilities of operators undertaking due diligence, including information collection, risk assessment, risk mitigation and submission of Due Diligence Statements (DDS) through the EU's TRACES Information System.

It also clarifies that operators sourcing exclusively from low-risk countries may benefit from simplified due diligence procedures, subject to the applicable conditions. Information collection, including plot-level geolocation, remains necessary.

For downstream operators and traders, the updated framework reduces the need to duplicate upstream due diligence, while maintaining essential supply-chain information and record-keeping requirements.

IMPORTANT IMPLEMENTATION DEADLINES

The guidance highlights the revised application timeline:

• 30 December 2026: Application of the main EUDR obligations for medium and large operators.

• 30 June 2027: Application for qualifying micro and small undertakings established by 31 December 2024, subject to the applicable provisions.

For the forest-based value chain, including pulp and paper, the guidance identifies 30 December 2026 as the key implementation date irrespective of company size.

It also explains the transitional arrangements for timber and timber products placed on the EU market during the transition period, emphasising the importance of maintaining appropriate documentation to demonstrate when products were first placed on the market.

SUPPORTING A RESPONSIBLE AND COMPETITIVE EUROPEAN INDUSTRY

Europe's pulp and paper industry plays a significant role in the transition towards a renewable, circular and climate-conscious economy.

According to Cepi, 85% of the industry's raw materials are sourced within the European Union, while 70.5% of paper is recycled. The sector represents approximately €25 billion in value addition to the European economy and invests €5 billion annually.

Through this updated guidance, Cepi seeks to support businesses in understanding the revised regulatory framework, strengthening supply-chain transparency and implementing their obligations with greater clarity.

The document is intended as a practical industry reference and should be read alongside the EUDR legislation and the European Commission's official guidance and FAQs.