Publishing industry participants following the news out of the European Union will recall an update earlier this month sharing that “the European Union will delay launching its anti-deforestation law for a second time.”

Rather than confirming the one-year delay as supported by the EU Environment Commissioner, the European Commission (EC) instead proposed a series of "targeted simplifications" amending EUDR but not agreeing to a blanket delay.

The publishing industry has been busily preparing for the implementation of EUDR since it came into force in June 2023. As “wood” is one of the commodities identified in the legislation, it would impact paper products.

These proposed targeted simplifications, or changes:

A postponement until December 30, 2026 for the implementation date for micro and small enterprises (as defined by the EU).
For medium and large enterprises, the EUDR would enter into force on December 30, 2025, with a six-month grace period until June 30, 2026, for enforcement.
A new type of operator, “micro and small primary operators,” could be created, classified as micro and small operators from low-risk countries (which includes Canada, the United Kingdom, the United States, EU members, China, Saudi Arabia, Vietnam, Switzerland, Japan, and India) placing products directly on the market which they themselves have produced. These micro and small primary operators would be exempt from full due diligence but would be required to submit a one-time simplified declaration.
A new type of operator, “downstream operators and traders,” could be created and would no longer be required to submit due diligence statements, and the responsibility for such due diligence would lie solely with the first operator placing the product on the EU market. Non-SME (small- and medium-sized enterprise) downstream operators would still be required to register in the EU’s planned IT system Traces and retain supply chain information (including reference numbers).

Further information and links to the full proposed amendments are available on the European Commission website.

BookNet Canada and our partners at the Green Book Alliance will continue to provide updates through this and other channels. Subscribe to our newsletter to receive updates.

FAQ

With this update on the horizon, we wanted to take the moment to address some frequently asked questions:

What are micro-, small- and medium-sized enterprises?

These definitions are defined by the European Union in their online documentation, available at: https://eur-lex.europa.eu/EN/legal-content/summary/micro-small-and-medium-sized-enterprises-definition-and-scope.html

What has the Canadian government’s response been?

In their relaying of the news, Natural Resources Canada (NRCan) issued the following statement:

At this time, NRCan, in collaboration with Global Affairs Canada, Agriculture and Agri-Food Canada, and the Canadian Mission to the EU, continues to analyze the full impacts of these proposed changes, including how the newly created categories may impact fair treatment between the EU and trading partners.
Industry should be aware that the EC proposal must still undergo approval or amendment by the European Parliament and Council. The timing of the process could mean a further period of uncertainty.
We will continue to keep you informed of further developments.

What does BookNet recommend?

As these changes have not yet been formalized, and there are just over two months before the current implementation date of December 30, 2025, BookNet recommends that publishers exporting to the European Union continue to operate under the assumption that the current dates for EUDR’s implementation apply. Moreover, if the changes are formalized and the documentation updated, BookNet encourages publishers to continue to prepare for the legislation while using the additional time to develop rigorous supply chain workflows to support the dynamic exchange of products and data into the EU. Publishers should endeavour to have the necessary conversations with supply chain partners as soon as possible to increase confidence levels and knowledge as it pertains to the expectations of importers to the EU. BookNet’s Bibliographic Manager Tom Richardson flags that, “a foreign [i.e., Canadian] company's success in placing a book into the EU likely depends on their EU trading partner's ability to articulate their needs.” The delay, if finalized, will provide welcome additional time for necessary communications.

Recall that the delay announced in October 2024 for the original implementation date was only confirmed December 19, 2024, less than two weeks before the expected deadline. Failure to prepare could have had disastrous effects!