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Paper is in; most print is out

This is the whole distinction, and it is easy to get backwards. Wood is one of the seven commodities, and paper is a wood product. Annex I covers pulp (chapter 47) and paper and paperboard (chapter 48, headings 4801–4823) — the reels, sheets and board you print on. [Reg. 2023/1115, Annex I] What was taken out is chapter 49: printed books, newspapers, journals, magazines, brochures, calendars, maps, prints, postcards and similar finished printed products. Those were originally in Annex I, and Regulation (EU) 2025/2650 deleted them in December 2025. [Reg. 2025/2650]

That is a live-law change, not a draft — it is in force and you can rely on it. The reason it matters day to day: the thing the regulation follows is the substrate. Print a magazine in the EU on paper an EU merchant sold you, and the paper is what carried the obligation, and it was already discharged upstream.

Which role are you? (Printing rarely makes you the operator)

Because print itself is out and paper is in, your position turns on how the paper reaches you. [Reg. 2023/1115, Art. 4]

• You print in the EU on paper bought from an EU merchant or mill. The upstream operator placed that paper on the EU market and filed the DDS. You are downstream: collect and keep the reference numbers. A non-SME must also register in the information system. [Reg. 2025/2650]
• You import your own paper — reels, sheets or board — from outside the EU. Now you are the first operator for that paper. You run due diligence and file the DDS before it clears customs, because chapter 48 is in scope. The printing afterwards does not change that. [Reg. 2023/1115, Art. 4(2)]
• You get books or magazines printed outside the EU and import the finished copies. Finished printed matter of chapter 49 has been removed from Annex I, so importing those copies is generally out of EUDR scope now — but confirm the customs classification, because a product that reads like "print" to you may sit in chapter 48 (for example certain paper articles) and still be caught. [Reg. 2025/2650]

The classification is the whole game

Whether you owe anything comes down to the customs heading of what you hold or import, not what you call it. Annex I keys on the Combined Nomenclature code. [Reg. 2023/1115, Annex I] A printed book is chapter 49 — out. A printed label, printed carton or printed wrapping can be a paper article of chapter 48 — in. So a "print job" that is really packaging or labels may keep you inside scope even after the chapter 49 removal. Get the CN code confirmed before you decide you are clear.

Which deadline applies if you are caught

If any part of your business is an operator — typically because you import paper — the timing matters. 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 fixed at 31 December 2024). [Reg. 2025/2650] Paper is a wood product, so the timber exception applies: a micro or small operator already covered by the old EU Timber Regulation does not get the later date and applies from 30 December 2026. A small printer that imports its own stock should check that timber history, not just its headcount.

What to keep on file

For the paper you buy or import, hold the origin trail so you can evidence your position. [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• DDS reference numbers for each paper grade from your EU supplier — this is your main obligation as a downstream printer.
• Plot geolocation for the fibre where you are the operator — coordinates, and polygons for plots over 4 hectares.
• Country of production, which sets the origin risk tier under Implementing Regulation (EU) 2025/1093. [Impl. Reg. 2025/1093]
• Recovered-content evidence for recycled stock, since recovered paper is excluded by Annex I.

Most EU paper origins — the EU itself, plus the US, Canada and China — sit in the low-risk tier, which allows simplified due diligence; some producing countries are standard risk. [Impl. Reg. 2025/1093]

What this determines — and what it doesn't

Screening your print and 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. For most EU printers the useful output is confirmation that you are downstream and a clean record of paper reference numbers.

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 product's customs classification and your position with counsel before relying on it for a market-access decision.

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