In June 2023, the European Union introduced the EU Deforestation Regulation, a sweeping replacement for the EU Timber Regulation that had been in place for the previous decade. While the EUTR focused only on timber, the EUDR covers a broader range of products and their raw materials, including but not limited to: cattle, wood, and cocoa. The regulation aims to track and hold accountable everyone in the supply chain of these products. The EUDR presents a challenge for book publishers in particular and some are already preparing to meet them. If you’re worried about understanding the legalese and when to comply, have no fear! There are plenty of resources to help. 

The EUDR asks operators and traders placing their products in the EU market to take responsibility in ensuring that they are not contributing to deforestation, especially in high-risk areas. Operators are publishers, paper mills, printers, and EU representatives. Traders are small retailers. Most of the responsibility falls on operators as the main ones handling the raw materials, although traders must be able to access the tracking information. So how is the EU enforcing this traceability? They have an online data portal, the Deforestation Registry, where operators are required to upload information about raw materials. The registry houses the Due Diligence Statements submitted by operators. A DDS is completed for each separate ISBN and it is likely that different print runs will require a different or updated DDS. 

What is unique about this system is that it presents a new level of communication between paper mills and printers to the publishers they supply. Most publishers already use ONIX, a metadata input system. The process of inputting data into ONIX is a little too complicated for this blog post, but systems that have been updated to 3.0 or higher should be able to start this process. With ONIX, publishers can input the DDS record in the EU registry, and it will then be available to other operators and traders downstream. This puts particular pressure on publishers to make sure they are receiving the correct information from their printers and paper mills. They must assess the risk that a record was falsified and the paper used in their book contributed to deforestation. If the paper does come from a high-risk area, publishers can face repercussions and will need to mitigate the damage they have caused. Paper from lower-risk areas may be exempt from risk assessments and mitigation. 

For many smaller publishers, like Ooligan Press, there is still plenty of time to comply. The European Commission delayed the timeline for micro and small operators to June 30, 2026. However, medium and large operators need to comply by December 30, 2025. In order for these companies to be in compliance, smaller operators have to be ready to provide information in accordance with the earlier deadline. The best advice is to start speaking with the paper mills and printers in your supply chain, as well as speaking with a lawyer!

It is important to note that some of the issues in the system still need to be worked out. Questions about reprints, lot control, and how to upload multiple forest data points into ONIX are likely to be unanswered until compliance is fully enforced. EDItEUR has several resources on understanding the regulations and how to update your ONIX system. The Forest Stewardship Council presents their updated risk assessment and regulation modules. If you’re curious about forest information and the degree to which some have been deforested, you can check out the European Commission’s Forest Observatory. Even though this is a lot to take in, keep in mind that it is happening for a good cause! By managing and mitigating deforestation, we can sustain our planet and keep making books.

Back Matter

Source: European Commission Webpage

Fact: Deadlines for EUDR compliance

Source: EDItEUR instructional video

Fact: Presentation included the links at the end of the blog.