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Is your paper in scope? (Yes, with two carve-outs)

Wood is one of the seven commodities, and paper is wood run through a mill. Annex I brings in wood pulp under chapter 47 (chemical, mechanical and semi-chemical pulp, headings 4701–4706) and paper and paperboard under chapter 48 (headings 4801–4823) — kraft, newsprint, coated stock, corrugated board, tissue, cartonboard and the articles made from them. [Reg. 2023/1115, Annex I] Annex I lists these by chapter and heading, and its own text carves out two categories:

• Recovered paper — waste and scrap of paper and paperboard (heading 4707) is excluded. Paper genuinely made from recovered fibre does not have to be traced back to a forest.
• Bamboo-based pulp and paper is excluded, because bamboo is a grass, not a forest tree.

Everything else in chapters 47 and 48 is caught. Note what is not here: printed matter of chapter 49 — books, newspapers, magazines and similar finished print — was removed from Annex I by Regulation (EU) 2025/2650 and is no longer in scope. [Reg. 2025/2650] That change is settled law, in force since December 2025 — not a proposal. If you buy printed products rather than paper stock, read our guide for printers and publishers.

Which role are you? (This decides everything)

The regulation does not ask what you make with the paper. It asks where you sit in the chain. [Reg. 2023/1115, Art. 4]

• You import pulp or paper into the EU yourself. You are the first operator: you run due diligence and file the DDS before the goods clear customs. That includes importing pulp and converting it — turning pulp (ch. 47) into paper (ch. 48) is a new product, so the mill or converter placing it is an operator. [Reg. 2023/1115, Art. 4(2)]
• You buy paper that is already on the EU market. The upstream importer or mill filed the DDS; you are downstream and collect and keep the reference numbers. A non-SME downstream operator or trader must also register in the information system, and may not place goods it knows to be non-compliant. [Reg. 2025/2650]
• You export EU paper or board out of the EU. Exporting also counts as placing on the market for these purposes, so an exporter is an operator too. [Reg. 2023/1115, Art. 4]

Which deadline applies — and why paper is different

Two application dates run. Medium and large operators and traders apply from 30 December 2026; micro and small ones from 30 June 2027, if they meet the SME size test (broadly under 50 staff and up to €10m turnover, with SME status set by 31 December 2024). [Reg. 2025/2650] Paper needs care here. Because it is a wood product, the timber exception applies: a micro or small operator that was already covered by the old EU Timber Regulation does not get the later date and applies from 30 December 2026 like everyone else. [Reg. 2025/2650] So a small firm that assumes June 2027 on the strength of its headcount can be six months late. Check the timber history, not just the size.

What to ask your paper supplier for

Whatever your role, you want the origin trail in the chain. For each grade or lot, request: [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• Plot geolocation for the wood behind the fibre — coordinates, and polygons for plots over 4 hectares.
• Harvest and production dates.
• Country of production (which sets the risk tier — see below).
• Recovered-content evidence where a grade is sold as recycled, so you can rely on the recovered-paper carve-out.
• The DDS reference number, where the supplier is the operator that filed it.

Origin risk tiers for pulp and paper

Fibre sources span the tiers. Under Implementing Regulation (EU) 2025/1093, most large pulp and paper origins — the EU, the US, Canada and China — are low risk, which allows simplified due diligence; Brazil and Indonesia are standard risk, which means full due diligence. [Impl. Reg. 2025/1093] Mixed-furnish grades muddy this: a sheet blending pulp from several countries can pull the whole lot to full due diligence, so knowing your furnish origins is worth doing before you assume the simplified route.

The pending draft act (know it, don't act on it yet)

On 4 May 2026 the Commission published a draft delegated act to amend Annex I. As at 10 July 2026 it is not adopted and not in force, and the text may change. [Commission EUDR implementation page] For paper it matters in two ways. It proposes an "ex" prefix on some chapter 47/48 codes to clarify that only the wood-derived version is caught. And it proposes horizontal exemptions that would touch paper items — single-use and reusable packing materials, marketing materials and catalogues, correspondence, product samples and waste. Those are proposals. Until the act is adopted, treat your chapter 47/48 stock as in scope and do not stand your compliance work down on the strength of a draft.

What this determines — and what it doesn't

Screening your paper tells you scope, role, deadline and the documentary obligations you owe. It does not verify that any forest behind the fibre is deforestation-free — that depends on the geolocation-plus-evidence your suppliers provide and any satellite check. You don't need a traceability platform to begin; you need to know your position and exactly what to ask your mill or merchant for.

General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free. Confirm your classification with counsel before relying on it for a market-access decision.

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