Europe wanted to send a message. With the EUDR, the EU Deforestation Regulation, the world was supposed to become a little fairer, supply chains a little cleaner, and the planet a little greener. No more products on the European market that come from deforestation – that not only sounds reasonable, it’s long overdue. After all, global deforestation accounts for around ten percent of greenhouse gas emissions, and a single market with 450 million consumers can indeed set an example. Only, and this is the problem: the good idea got lost along the way. Somewhere between ambition, administration, and absurdity.
Because what looks like a logical, morally unassailable measure on paper has turned, in practice, into a textbook example of European bureaucracy. The EUDR is a prime example of how a simple statement – “No products from deforestation!” – can be turned into a digital labyrinth of deadlines, roles, declarations, and IT interfaces. And right in the middle stands the paper and printing industry, now expected to prove nothing less than that it knows exactly which forest its raw materials came from.
A Law with Good Intentions but Poor Structure
The EUDR was adopted in June 2013 and will come into force at the end of 2025. It is part of the European “Green Deal.” Its goal is to reduce the EU’s global footprint. It applies to raw materials such as soy, palm oil, coffee, cocoa, cattle, rubber – and wood. And because wood is found in paper, the printing industry is caught squarely in the middle of this regulatory trap.
Every company that places such products on the market for the first time must now submit a due diligence statement. That sounds like standard compliance, but in practice it means that for every product batch, geodata of production areas, risk assessments, and proof of origin must be recorded and digitally stored. From the tree to the book.
So much for the theory. In practice, what’s missing are functioning standards, clear definitions, coordination between member states – and above all, realism. Because the supply chains of the printing and paper industries are already global, complex, and multi-layered: pulp from Finland, carton from Austria, printing in Germany, shipping to France – that’s everyday reality, not an exception.
The only way to make such structures transparent is through the consistent digitalization of the entire supply chain. But that’s precisely where politics has failed – at least so far.
September: The Month of Major Confusion
The story of the EUDR drama began in late summer 2025 with a simple realization: the central EU platform TRACES, through which all due diligence statements are supposed to be processed, apparently does not work for large volumes of data and very high numbers of submissions.
On 23 September, EU Commissioner Jessika Roswall raised the alarm. She proposed postponing the EUDR by one year. Officially because of technical issues, unofficially because it had become clear that the member states were organizationally overwhelmed. Her German counterpart, Alois Rainer, responsible for agriculture and food, immediately welcomed the proposal – as did the German Printing and Media Industries Federation. Both simultaneously called for a fundamental simplification of the regulation, including the introduction of a so-called zero-risk category. The idea: those sourcing from demonstrably sustainable origins should automatically be considered low risk.
That would have simplified many things. Perhaps too many. Because hardly had the proposal been published when Commission Vice President Teresa Ribera Rodríguez spoke up. She stated that IT problems must not be a reason to put political decisions on hold. “Companies that invest in compliance must not be punished just because the administration is still learning,” she said in essence.
This made the political stalemate complete: some call for postponement, others insist on pushing ahead. And the business sector? It stands in the middle, wondering whether to keep investing or to wait.
When Simplification Makes Things More Complicated
While the Commission was busy debating itself, the industry was already working on solutions. Leading the way was my IOP board colleague, Dominik Haacke, Chief Commercial Officer at mediaprint solutions GmbH and ESG specialist of the Initiative Online Print e.V. (IOP). He was quick to recognize that the EUDR is, in reality, not an environmental issue but a digitalization challenge. I spoke with Dominik about this topic, also to better understand what it is really about.
“We are not just talking about trees here, but about the largest digitalization project of supply chains in the entire world,” says Haacke. “The EU wants transparency, but it is providing too little structure. We realized early on that the law focuses on the initial market participants but has simply forgotten the many downstream operators.”
To resolve this contradiction and increase efficiency for the roughly 370,000 affected companies, Haacke, together with the IOP and several industry associations, developed the data exchange standard EUDR-X – an open, machine-readable format that enables companies to collect and share EUDR-relevant data more easily along the supply chain. Instead of Excel sheets and a lot of manual effort: structured data sets for import and export into companies’ existing IT systems. Instead of chaos: a unified approach.
“EUDR-X is not a political project but a practical aid for the many downstream, often small and medium-sized enterprises that do not import or export outside the EU at all,” explains Haacke. “We are demonstrating how EUDR requirements can be implemented more easily and transparently from a technical standpoint – and we are doing it now, not in 2027. A standardized data exchange format for downstream operators should already have been provided by the EU in 2024,” Haacke adds.
This EUDR industry initiative and EUDR-X gained real momentum just as Brussels presented a new proposal.
On 21 October, the Commission introduced amendment proposal COM(2025)652. The goal: simplification. The effect: confusion and even more uncertainty. The proposal introduced a new category of market participants – the so-called downstream operators. These include all those who further process materials but do not import them directly: printers, paper converters, packaging manufacturers, publishers. For them, the workload was supposed to decrease. “It was at that point I realized that the EU had truly forgotten or significantly underestimated this group in the first legislation,” says Haacke.
On paper, it sounds like a relief. In practice, it means that in the future everyone will “only” have to collect their suppliers’ reference numbers and pass them on to their customers. Where previously reference numbers from upstream suppliers could be combined into a new reference number within a company, everything now breaks down again into hundreds of individual numbers. The planned pooling model developed by the associations – a joint declaration for entire material groups – was effectively abolished as a result.
“They wanted to reduce bureaucracy but managed to make it worse,” Haacke comments dryly. “From my perspective, the EU has put itself in ‘checkmate’ with this short-term new proposal and the already known challenges of the TRACES IT system.”
The reactions from the associations were correspondingly clear: the German Printing and Media Industries Federation (BVDM) spoke of a “half-hearted attempt,” while Intergraf warned of “administrative overkill.”
Stop the clock – and everyone keeps an eye on the clock
After the publication, there was radio silence for two weeks. Fifteen days in which neither the EU Commission nor the Council gave any direction. Then 25 European associations called for the “clock to be stopped” – literally. Stop the clock became the slogan of October. They said that time was needed to make the system workable.
After many other associations, in addition to the printing and media industry, spoke up and called for the “emergency brake” to be applied, a clear majority of member states also supported the idea at the EU Agriculture Council meeting in Luxembourg at the end of October: Austria, Poland, Czechia, Estonia, Croatia, Bulgaria, Latvia, and Finland.
On 5 November, the EU Environment Council met. Austria submitted a resolution calling once again for a stop-the-clock rule and a separate proposal for simplification. Fifteen countries supported the motion: Austria itself, the Czech Republic, Greece, Luxembourg, Latvia, Estonia, Lithuania, Slovakia, Portugal, Finland, Ireland, Hungary, Italy, Poland, Slovenia, and Sweden. Germany, France, Belgium, Bulgaria, Romania, Croatia, Cyprus, and Malta did not comment. Spain was the only country to support the Commission’s proposal and called for it to be adopted in its entirety without reopening the legislation.
EU Commissioner Jessika Roswall remained adamant: a separate “stop-the-clock proposal” was not politically feasible. Her proposal, COM(2025)652, was “the only solution that creates legal certainty.” The result: no one knows what applies. The EUDR continues on paper, but in practice everything is at a standstill.
“We look at the game board and are at a loss as to what the next sensible and economically viable move is,” Haacke summarizes the situation.
The consequences are dire: Companies that have long since begun to implement EUDR processes do not know whether they are relying on the correct version. Others are waiting and hoping for a postponement. This creates stagnation while the clock continues to tick.
The industry delivers, Brussels hesitates
Despite the political deadlock, the industry continues to work. Many printing companies and paper manufacturers have begun to structure their supplier data so that they can clearly document proof of origin. Major players are testing EUDR-X in practice, while smaller companies are using pilot tools to link data between purchasing, production, and sales.
“The political back-and-forth is slowing us down,” says Haacke. “Digitization along the entire supply chain and product compliance make sense, but only if there is political predictability.”
He is right. Because the EUDR is more than just an environmental law. It is a compulsion to digitize – and thus the greatest opportunity since industrialization. If any industry has learned to deal with complexity, it is the printing industry. It thinks in terms of processes, print runs, series, and material flows. In this sector, transparency is not a moral issue, but rather daily practice. FSC, PEFC, ISO – all familiar, all routine. The EUDR is just the next step, this time in digital form.
Except for the fact that Brussels apparently does not understand that a law that requires digitalization must itself function digitally.
“We could be much further ahead by now, even global pioneers in terms of digitalization in the supply chain and the resulting goal of a sustainable economy. But the reality feels as if the EU changes the Wi-Fi password every day and only informs a few people,” says Haacke with a smile that lies somewhere between irony and exhaustion. And he hits the nail on the head: It’s not the idea of the EUDR that’s the problem, but its administration. Every week that passes costs money. Companies are postponing investments because the framework conditions are lacking. Software manufacturers are developing systems into a void because interfaces and specifications are changing. Suppliers and customers are unsettled because no one knows who will ultimately be liable.
This creates the opposite of sustainability: resources are tied up, time is wasted, and capital is blocked.
Conclusion: The forest is still standing, but patience has been cut down
The EUDR is Europe’s most ambitious environmental regulation – and at the same time a symptom. It shows how far apart aspirations and implementation are in the EU.
The printing and paper industry has understood that regulation can be a driver rather than an enemy. The industry has moved forward, developed solutions, and taken responsibility. Politics, on the other hand, is stuck in the rearview mirror, caught between voting loops and system tests.
The Commission’s proposal is to be presented to the European Parliament’s ENVI Committee (Committee on the Environment, Public Health, and Food Safety) in November. On 13 November, the plenary will decide on an urgent procedure. If this happens, decisions will be made between 25 and 27 November. However, it is likely that political groups will also submit amendments. This means that new adjustments could be decided by the end of the year – with an uncertain outcome.
Until then, the EUDR remains a paradox: a law that is supposed to provide clarity is causing confusion. An instrument that aims to promote sustainability is destroying resources. And a project that is supposed to save the planet could ultimately achieve one thing above all else—showing once again how Europe stands in its own way. But the industry remains pragmatic. It acts, it develops, it implements. Because giving up is not an option.
Or, in the words of my IOP board member colleague Dominik Haacke: “Brussels must clear the board of the EUDR disaster and reorganize it in a new and sensible way. This will take time, both for the Commission and for commercial enterprises. At the same time, we have long been building the future of digital and sustainable transformation (twin transformation) because it simply makes sense. When you finally get started, we’ll be there. Provided that still makes sense for the paper processing industry.”
