EUDR guides

EUDR for paper, board and packaging: what is in scope

By Juan Cantón (Francodesystems) ·

Wood pulp (chapter 47) and paper, paperboard and articles of them (chapter 48) are in Annex I of the EUDR as wood products. Out of scope are books and other printed matter of chapter 49, recovered paper and products made from it, used goods, and packaging that only supports, protects or carries another product.

Which paper and board are covered by the EUDR?

Regulation (EU) 2023/1115 treats pulp and paper as products derived from wood. In Annex I, as amended by Delegated Regulation (EU) 2026/2102 (in force since 18 September 2026), they appear as ‘ex 47’ (pulp of wood) and ‘ex 48’ (paper and paperboard; articles of paper pulp, of paper or of paperboard). The ‘ex’ means not the whole chapter is covered: the exclusions are written into the Annex line itself.

For chapter 48 the Annex excludes five groups: waste within the meaning of Directive 2008/98/EC; used and second-hand products; recovered (waste and scrap) products and products derived from them; packing material and containers that only support, protect or carry another product; and items of correspondence and marketing or information material that accompany another product or are handed out free of charge. Everything else is in: office paper, newsprint, kraft, corrugated board, tissue, boxes, bags, envelopes, notebooks and labels.

An example: a stationery wholesaler in Valencia that imports kraft reels from Brazil and reams of office paper from Indonesia needs a due diligence statement (DDS) for each shipment. If you are unsure about a code, the CN code checker tells you whether it is in Annex I.

Product by product

The most common cases. The Annex I description and the tariff classification of your goods are what count:

Pulp, paper and board in Annex I (checked November 2026)
ProductCN codeIn scope?Note
Chemical or mechanical wood pulp4701 to 4705YesTrace back to the forest of origin
Recovered paper and recycled-fibre pulp4706, 4707NoRecovered products
Newsprint, office paper, kraft4801 to 4805Yes
Toilet paper, napkins, tissues4803, 4818Yes
Paper or board boxes, sacks and bags4819Yes, if sold as goodsNo, if they only pack other goods
Envelopes, notebooks, diaries4817, 4820Yes
Paper or board labels4821Yes
Books, newspapers, catalogues, calendarsChapter 49NoOut since Regulation (EU) 2025/2650
Bamboo-based paper productsChapters 47 and 48NoBamboo is not wood

Packaging: when it is in and when it is out

The rule depends on what the packaging is used for, not on what it is. Annex I excludes ‘single use packing material and packing containers used exclusively to support, protect or carry another product’ placed on the market or exported and presented with that product. Packaging clearly suitable for repeated use is also out from the moment it is used for that purpose.

In practice: the cardboard boxes around the televisions you import need no DDS; empty boxes you buy from a manufacturer in China to pack your own product in Spain do, because they are the goods. The same applies to the instruction manual or leaflet inside the box: it is information material accompanying another product and is out of scope.

At customs these exclusions have their own document codes on the customs declaration. They are explained in the guide on EUDR TARIC codes in the customs declaration.

Books, recycled paper and bamboo

Books, newspapers, catalogues and other printed matter of chapter 49 were in the original Annex I. Regulation (EU) 2025/2650 deleted that line, so a publisher printing books in Asia does not submit a DDS for them. The blank paper they are printed on is still covered: if a Spanish printer imports it, the DDS is the printer’s.

Recovered paper (heading 4707) and products made from it, such as recycled-fibre pulp of heading 4706, are out of scope. If a paper mixes recycled and virgin fibre, the virgin part remains subject to the Regulation, so ask the mill for the composition and the origin of that fibre.

Bamboo, rattan and similar woody materials do not count as wood, as Delegated Regulation (EU) 2026/2102 recalls. The CN code does not separate bamboo paper from wood paper: the evidence is the mill’s composition sheet. If a paper mixes bamboo and wood fibre, the prudent approach is to treat the wood part as covered.

What a paper importer has to collect

Paper is handled like any other wood product. The DDS of the operator, the company that first places it on the EU market, needs:

  • Species with common and scientific name (Annex II). Paper from Indonesia is usually plantation acacia or eucalyptus; ‘tropical hardwood’ is not enough.
  • Geolocation of the forest plots or concessions the fibre comes from, not the mill’s address. These are almost always polygons, because they exceed 4 ha. Details in the guide on geolocation.
  • Quantity in net kilograms and the CN code of what you import.
  • Supplier data and evidence of legality: harvesting licences or permits for the concessions and documents for the chain between forest and mill.

A large mill sources fibre from many concessions at once, so the file can hold hundreds of polygons. A real case handled in Sourevo: a paper mill in Indonesia sent a GeoJSON file with 551 polygons from 7 concessions. Twelve were the same polygon repeated under two place names, which left 539 plots. Sourevo skips identical outlines and stores the producer (the concession) on each plot to send it to TRACES. In the TRACES test environment, that 539-polygon DDS took about 3.5 minutes to become available.

Deadlines: no SME delay for paper

Pulp and paper of chapters 47 and 48 were already covered by the EU Timber Regulation (EUTR, Regulation (EU) No 995/2010), which the EUDR repeals. That is why the EUDR applies to these products from 30 December 2026 for every company, including micro and small ones. The delay to 30 June 2027 does not apply to timber already under the EUTR. All dates are in the guide on EUDR deadlines.

If you buy the paper from an EU importer or manufacturer that has already submitted the DDS, you are a downstream operator or trader and do not submit a DDS: you keep supplier and customer data for 5 years. A printer buying reels from a Spanish distributor is in that situation.

Frequently asked questions

Do imported books need a DDS?
No. Regulation (EU) 2025/2650 removed the printed products of chapter 49 from Annex I: books, newspapers, catalogues and pictures. Unprinted paper of chapter 48 is still covered.
Are empty cardboard boxes I import for packing in scope?
Yes. If the box is the goods you buy, it is a heading 4819 product and needs a DDS. Only packaging that supports, protects or carries another product it is presented with is out.
What about recycled paper?
Recovered paper and products made from it are outside Annex I. If the paper also contains virgin fibre, that part is still covered and its origin must be documented.
I am a micro or small company and only import paper. Do I have until 2027?
No. Pulp and paper were under the EUTR, so the EUDR applies to you from 30 December 2026, as it does to large companies.
Do I have to geolocate the paper mill?
No. You geolocate the forest plots or concessions where the wood in the paper was harvested. The mill is a link in the chain, not the origin.

Want to see it with your own shipments?

Sourevo collects your suppliers’ plots, validates the geolocation and submits the DDS in TRACES. If it fits, we try it with one of your shipments.

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Sources: Regulation (EU) 2023/1115, consolidated version (EUR-Lex) · Delegated Regulation (EU) 2026/2102 amending Annex I (EUR-Lex) · Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115 (EUR-Lex) · Regulation (EU) No 995/2010, EUTR (EUR-Lex). This is general information; for a specific case, follow your adviser or the competent authority.