To meet the requirements of the EU Deforestation Regulation (EUDR), your EU importer (referred to as the “operator” in the regulation) will need to request a set of comprehensive and verifiable documents from you as the manufacturing factory. This documentation is the cornerstone of their mandatory Due Diligence Statement (DDS), which is required to place your paper products on the EU market legally.
While there is no single, universally fixed list of documents, manufacturers will typically be required to provide the following three core categories of files and data:
Category 1: Product & Supply Chain Traceability Documents
These documents aim to establish a clear and unbroken evidence trail from the final product back to the original timber harvesting plots.
- Detailed Product Information:
- Product Description & HS Code: An accurate description of the product and its classification code under the EU’s Harmonised System (CN/HS) (e.g., paper products are typically found under Chapters 47 and 48).
- Quantity: The net weight in kilograms and any other relevant units (such as the number of items).
- Timber Species: The standard and scientific (Latin) names of the timber species contained in the product, where applicable.
- Chain of Custody (CoC) Documents:
- All transaction records that link a specific batch of paper products to the pulp and woodchips used. This includes, but is not limited to, purchase orders, invoices, contracts, delivery notes, and shipping documents. The key is to prove that the raw material sources for your finished exported goods are clearly traceable.
- Supplier Information:
- The names, addresses, and contact details of the direct suppliers who provide you with pulp or woodchips.
Category 2: Core Data for “Deforestation-Free” Proof
This is the most transformative requirement of the EUDR. The central goal is to prove that the raw material did not originate from land deforested after 31st December 2020.
- Precise Geolocation Data:
- This is mandatory and the most critical piece of information. You must provide the geographic coordinates of all plots of land where the timber used to produce the specific batch of products was harvested.
- A single GPS coordinate point is required for plots smaller than four hectares.
- For plots larger than four hectares, you must provide polygon data (e.g., in KML or GeoJSON format) to define the plot’s boundaries.
- Date of Harvesting/Production:
- The date or time range of timber harvesting associated with the geolocation data provided. This will verify that harvesting took place after the cut-off date of 31st December 2020.
Category 3: Documents Proving “Legality” in the Country of Production
These documents are intended to prove that the timber’s harvesting, transport, and processing complied with all relevant laws and regulations in its country of origin.
- Proof of Land Use Rights: Documents that confirm the legal right to use the harvesting plot, such as land title deeds, lease agreements, or official government authorisations.
- Harvesting Permits & Forest Management Documents:
- Official, government-issued harvesting permits or approvals.
- Associated forest management plans or licences, where applicable.
- Environmental Protection Compliance: Documents showing that production activities adhere to local environmental regulations, such as environmental impact assessment reports or emissions permits.
- Proof of Third-Party Rights:
- Documents demonstrating that the timber harvesting did not infringe upon the rights of local communities or indigenous peoples. Where applicable, evidence of Free, Prior and Informed Consent (FPIC) is required.
- Proof of compliance with local labour and human rights laws.
- Trade & Tax Documents:
- Proof that relevant harvesting and export taxes have been paid.
- Legitimate customs declaration forms.
Important Additional Notes:
- The Role of Sustainable Forestry Certifications (e.g., FSC/PEFC): While holding a certification like FSC or PEFC provides strong supporting evidence of good supply chain management and reduced risk, it is not a direct substitute for the due diligence required by the EUDR. Your client will still need you to provide the above geolocation and legality documents.
- Supplier Declarations: Your EU client may ask you or your upstream pulp suppliers to sign a formal declaration, confirming that the products supplied comply with EUDR requirements.
- Cooperation in Risk Assessment: If your client assesses your factory or timber source as presenting a higher risk, you may be required to provide additional documentation or be subject to an independent third-party audit to help mitigate that risk.
Navigate EUDR with Confidence: Your Partner in Compliance
We understand that navigating the complexities of the EUDR can seem daunting. At Harmony, we have proactively structured our supply chain and documentation processes to meet these rigorous standards. We are fully prepared to provide our partners with the complete, verifiable traceability and legality documents required for seamless market access.
Don’t let regulatory hurdles disrupt your business. If you are looking for a reliable partner who can guarantee a transparent, deforestation-free, and EUDR-compliant paper product supply, our expert team is ready to help.
Contact us today to learn more about our compliance processes and secure your pathway into the EU market.
