Compliance with EUDR

EUDR update December 2025

European Commission, Parliament, and Council reached an agreement on amending the EU deforestation regulation (EUDR), announced by EU on December 4. The agreement reached introduces the following changes:

Implementation of EUDR has been postponed to December 30, 2026 for large and medium operators and for micro and small operators already covered by the EU Timber Regulation (EUTR)
Printed products are excluded from the regulation scope
Due diligence limited to the first operator placing the wood-based commodity or product on the market
Forthcoming assessment to carry out simplification review by April 30, 2026

The provisional agreement must be formally ratified by both Parliament and Council before it replaces the current EUDR. It is expected to happen before December 30, 2025.

We at UPM Specialty Papers continue to work with our customers and suppliers, to implement the necessary adjustments and to ensure EUDR compliance by the application deadline.

The European Union Regulation on Deforestation-free Products (EUDR) marks a significant milestone in the EU's ongoing efforts to combat deforestation and forest degradation globally. This regulation replaces the EU Timber Regulation, extending the mandatory due diligence requirements to cover a broader range of commodities.

The aim of the regulation is to secure that the use of forests as a raw material is transparent throughout the value chain and that the forest is used in a responsible way. At UPM, we are deeply committed to sustainable forestry practices, and we support the regulation’s overall targets. 

UPM’s EUDR implementation

UPM’s Due diligence system description

UPM’s due diligence system description is available.

EUDR: What Does It Mean? 

The regulation entered into force on 29 June 2023 and is currently in a transition period that ends on 30 December 2026.

Under the regulation, it is prohibited to place or make available on the EU market, or to export from the EU, any relevant commodities or products made using such commodities unless they meet the following criteria:

Deforestation and Forest Degradation-Free

Compliance with Country Legislation

Due Diligence Statement

Recognizing the obligations set forth by the EUDR, UPM paper businesses are proactively preparing for full compliance by December 30, 2026. During this transition period, the company is taking necessary measures, such as:

- Engaging with Suppliers and Customers: Actively collaborating with suppliers, customers, and competent authorities to share information and ensure a seamless transition to the new regulation.
- Implementing Compliance Measures: Adapting internal processes and systems to meet EUDR requirements effectively.

EUDR FAQ

Please be aware that our comments refer to EUDR compliance related to the supply of paper materials to our direct customers based on UPM’s interpretation of publicly available information on EUDR. We recommend customers consider their own EUDR obligations when selling products to their own customers. UPM does not offer legal advice or consult on EUDR compliance. We recommend requesting guidance from the EU or a third party when determining the impact of the regulation to your own business activities.

Content

Scope & timeline

Understanding my company’s position in the supply chain

UPM’s role and solution for implementation

UPM sharing relevant EUDR information: reference numbers and verification numbers

Compliance with EU Deforestation Regulation (EUDR)