EUDR for paper and pulp importers: what's actually in scope

Pulp and paper classified under Chapters 47 and 48 of the Combined Nomenclature are in Annex I of the EUDR and must comply by 30 December 2026, whatever the size of the business. Printed matter — books, newspapers, brochures — was removed from Annex I entirely by Regulation (EU) 2025/2650, so a printer or publisher using that paper has no EUDR obligation of its own for the printed product it sells.

Which paper and pulp products are actually in Annex I

Annex I's wood entry covers "pulp and paper of Chapters 47 and 48 of the Combined Nomenclature", with one stated exception: bamboo-based and recovered (waste and scrap) products. That is a broad sweep across two full tariff chapters, not a short list of named headings.

Product	CN chapter/heading	In Annex I
Mechanical and chemical wood pulp	4701–4706	Yes
Recovered (waste and scrap) paper or paperboard	4707	No — expressly excluded
Newsprint	4801	Yes
Printing and writing paper, uncoated	4802	Yes
Paper and paperboard, coated, cartons, boxes, tissue and the rest of Chapter 48	4803–4823	Yes
Pulp or paper made from bamboo	any heading, bamboo-sourced	No — expressly excluded
Printed books, newspapers, brochures and similar printed matter	ex 4901 (Chapter 49)	No — removed by Regulation (EU) 2025/2650

The practical effect is that almost everything a paper mill, converter or merchant handles as raw or semi-finished material — pulp, newsprint, writing and printing paper, packaging board, tissue, cartons — is caught. The two carve-outs that matter are recovered fibre and bamboo, and both were in the original 2023 text, not added later.

Printed products: out of scope since the 2025 amendment

Chapter 49 covers printed books, newspapers, brochures, manuscripts and similar printed matter. The original 2023 regulation caught part of it, with the Annex I line reading "ex 49 Printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper". Regulation (EU) 2025/2650 deleted that line from Annex I outright.

That means a publisher or printer placing a printed book, magazine or brochure on the EU market has no due diligence statement to file for the printed product itself, regardless of where the paper it was printed on came from. What changed under Regulation (EU) 2025/2650 covers the amendment's other changes — who files, and the new dates — but does not currently mention this Annex I deletion, which is worth knowing if you had assumed printed matter was still caught.

The obligation does not disappear, it just moves up the chain. Whoever first placed the paper itself on the EU market — the pulp or paper mill, importer or merchant — still had to file a due diligence statement for that paper under the Chapter 48 entry, before it was ever printed on. Chapter 49's removal is about the printed product, not about the paper inside it.

Why paper and pulp sit on the earlier deadline, not the SME one

Regulation (EU) 2025/2650 gives most micro and small operators until 30 June 2027. It withholds that extension from operators whose products were already within the scope of the EU Timber Regulation (Regulation (EU) No 995/2010, "EUTR") — and pulp and paper were already in EUTR's own Annex, under the same exception for bamboo-based and recovered products. EUDR for furniture and timber importers after the Timber Regulation repeal sets out the reasoning in full: EUTR already required species and legality due diligence on these products since 2013, so the regulation does not see a case for extra time to build systems that should already exist.

Operator	Deadline
Large and medium operators and traders, any commodity	30 December 2026
Micro and small operators handling pulp or paper (Chapters 47–48)	30 December 2026
Micro and small operators handling most other commodities	30 June 2027

A small independent paper merchant does not get the same six months as a small cocoa importer. Which EUDR deadline applies to you walks through the staff, turnover and balance-sheet thresholds that decide size band in the first place.

Who is the operator in a pulp-to-paper chain

The due diligence statement sits with whoever first places the Annex I pulp or paper product on the EU market — typically a pulp mill, paper mill or import merchant bringing Chapter 47 or 48 material in from outside the EU. A converter buying already-placed paper from an EU mill or merchant to make boxes, tissue products or stationery is a downstream operator or trader: it does not file its own statement for that paper, but it must collect and keep the reference number the first operator obtained, for at least five years.

An EU-based pulp mill using domestically grown wood is placing a product made from EU-harvested timber, which still falls within Annex I's deforestation-free test — the cut-off date applies regardless of where the wood was grown.

A paper merchant that only trades already-placed stock between EU customers, without being the business that first brought it onto the EU market, is a trader rather than an operator under the amended regulation, not an operator with a filing obligation of its own. The headline point from the 2025 amendment is that only the first operator files a statement, and everyone after them collects and keeps the reference number rather than filing one of their own.

Paper packaging follows a different test from paper the product

A paper or board box, carton or wrapper used only to carry another product to market is not itself a relevant product under Annex I — the same rule that exempts wooden pallets used to ship goods rather than sell them. The distinction that matters here is that the exemption looks at function, not material: a cardboard box shipped full of someone else's goods is packaging and out of scope, while the same box sold empty, as a product in its own right, is paperboard under Chapter 48 and squarely in Annex I. A paper mill or converter selling cartons, boxes or other finished paperboard products as the thing being sold needs to treat them as in scope, even though an identical item used purely to ship something else would not be.

Country of origin still decides how much due diligence you do

Country benchmarking under Implementing Regulation (EU) 2025/1093 sets one risk tier per country of production across all EUDR commodities; there is no paper-specific tier. The tier still drives the workload.

Origin	Risk tier	What it means for a pulp or paper importer
Sweden, Finland	Low	Simplified due diligence: no risk assessment or mitigation step required by default
Brazil	Standard	Full due diligence, including risk assessment and mitigation
Russia	High	Full due diligence, same as standard risk, plus a 9% competent authority check rate rather than 1% or 3%

Most EU pulp and paper demand is met from EU-grown and Nordic and North American wood, which tends to sit at low or standard risk, but a mill sourcing market pulp more widely needs to check the country its fibre was actually grown in, not just where it was processed. EUDR country benchmarking explained covers how the three tiers work and what the 1%, 3% and 9% check rates mean in practice.

Geolocation for pulp and paper: the standard rule, no shortcut

Pulp and paper get no commodity-specific geolocation easement. Every plot the wood was harvested from needs a geolocation point if it is 4 hectares or smaller, or a full polygon above that threshold, under the standard rule in EUDR geolocation requirements. For pulp aggregated from many forest holdings before processing, that means plot-level origin data has to survive pooling into a single batch of chips or pulp — a due diligence statement covering a mixed-origin consignment still has to reference every plot, not an averaged source region.

Recovered (waste and scrap) paper under CN 4707 is excluded from Annex I in the first place, so recycled-fibre content carries no geolocation burden at all — only virgin wood fibre does.

What to ask a pulp or paper supplier for

1. Confirmation of the CN heading the shipment is sold under, since that decides whether it is Chapter 47/48 virgin material (in scope) or Chapter 47 waste and scrap (CN 4707, out of scope).
2. Geolocation points or polygons for every plot the wood was harvested from, not an aggregate forest region.
3. Confirmation the wood was harvested from land that was not deforested or degraded after 31 December 2020.
4. Evidence of lawful harvesting — land tenure, harvesting permits, and compliance with local environmental and labour law in the country of harvest.
5. If your supplier is not the first operator, the due diligence reference number for the specific consignment, to hold against your own five-year record-keeping obligation.

Where a supplier cannot say which forest, region or even country a batch of market pulp came from because it was pooled at a mill with multiple fibre sources, that is a sourcing gap to close now rather than a detail to assume away.

Check what the EUDR requires for your paper or pulp business and get a dated list of what to ask suppliers for, rather than working it out shipment by shipment.