EUDR: what a tissue buyer has to hold, and what we can send

The dates that matter

Regulation (EU) 2023/1115, as amended, applies to pulp and paper products from 30 December 2026 for large, medium and downstream operators, and from 30 June 2027 for micro-enterprises and natural persons. The deforestation cut-off date is 31 December 2020: material harvested from land deforested after that date cannot be placed on the EU market. The application date has already been postponed twice — check the current text before you plan, and check it again before you order.

What the regulation asks of you, the importer

• Collect information on the product, the quantity, the supplier and the country of production
• Geolocate the plots of land where the raw material was produced
• Assess and mitigate risk, and keep the evidence
• File a due-diligence statement in the EU information system before placing the goods on the market
• Keep the statement and the supporting documents for the retention period, and pass the reference down the chain

What we provide, and what we do not

We provide the converter-side documents: the pulp grade and its origin as declared by our mill, the mill and supplier names, the production information for your order, and any chain-of-custody or certification documents the mill holds. EUDR-ready: we pass on the upstream documents your due-diligence statement needs — pulp grade and origin as declared by our mill, the mill and supplier names, the production record for your order, and any chain-of-custody certificate the mill holds.

Questions worth asking any tissue supplier

• Which mill supplies the pulp, and what is its EUDR position?
• Is the pulp virgin or recycled, and can you show the declaration?
• Where were the fibres harvested, and can you geolocate the plots?
• Which HS code is the product declared under?
• Who signs the documents, and how fast can they be issued?

What the timeline looks like for a buyer

The regulation applies in two steps, and most importers are in the first one. Plan backwards from the date that applies to you.

What we can put in your file

• Pulp grade per item, and the origin as declared by the mill that supplied it
• Mill and supplier names for the lot in your order
• Production record: dates, quantities, packing, container reference
• Any chain-of-custody or certification the mill holds, in the form the mill issues it

Recycled fibre, virgin fibre and the questions to ask

Recycled material is not automatically out of scope, and virgin fibre is not automatically a problem. What matters to your filing is whether the origin and the plot can be evidenced for the fibre actually in the sheet. That is why the question to ask a supplier is not "are you EUDR compliant?" but "which mill, which grade, and what can you show me in writing?"

If your specification allows either grade, ask for both versions in the quotation. The EUDR position can change the choice as much as the price does.

Bamboo: outside the scope, and why that matters to you

Products made exclusively from bamboo fall outside the scope of the EUDR — the regulation covers wood, and bamboo is a grass. A 100% bamboo article therefore needs no due-diligence statement for that fibre. That is a useful fact if you are choosing fibre for an EU-bound order — and it is the reason we offer bamboo as a third grade alongside wood pulp.

We are telling you because the choice is yours, not ours: a bamboo article avoids the due-diligence file for the fibre, but it still has to meet your customer’s paper specification, print quality and price. If your product can work on bamboo, say so in the enquiry and we quote both grades side by side so you can see the difference.

Two things we will not do: call a bamboo product "EUDR certified" (it is simply outside the scope, which is a different statement), and let you file on the assumption that a mixed sheet is bamboo. If a sheet contains any wood pulp, the wood declaration applies to that part, and we will say so on the documents.

Questions we answer most often