EUDR's 3 Practical Boundaries for Printing Companies: Due Diligence Statement, Geolocation, and Pulp Origin Evidence for EU Orders

In October 2026, a customer that manufactures furniture components for export to Europe and North America sent us an inquiry for a batch of color boxes. The attachment was a document titled “Paper Source Declaration.” The customer wrote on WeChat: “Please fill this out for me. We need it for procurement, and we do not know how to handle it.”

The document requested, among other things, the geolocation of the forest plots supplying the pulp, the tree species, harvesting permit numbers, and confirmation of whether any trees had been felled after 31 December 2020.

The customer’s exact response was: “How would we know where the forests are? We simply buy paper.”

This statement lies at the center of the issue. The EUDR governs the traceability of wood and wood-containing products from forest plots to finished products; it does not govern printing. Paper and paperboard fall within its scope, but the obligated parties are operators and traders who place wood, pulp, paper, or products containing these materials on the EU market. A printing company occupies a distinctive position in this chain: we normally operate further downstream, using paper and paperboard to produce packaging for delivery, and we are often not operators within the meaning of EUDR.

That does not mean printing companies can ignore the regulation. The customer is the operator and must establish an evidence chain demonstrating that the paper used for the packaging comes from compliant plots. The starting point for that evidence chain is precisely the set of documents that a paper mill can provide but a printing company generally cannot obtain on its own.

The First Boundary: The Operator Issues the Due Diligence Statement; Printing Companies Should Not Sign on Their Behalf

The core EUDR obligation is due diligence. For each relevant consignment entering the EU, an operator must confirm that the product contains no commodities associated with deforestation, assess the risk, and prepare a due diligence statement.

One structural change is particularly important for printing companies. Under the original regulation, downstream traders and operators, including printing and packaging businesses, had to submit their own complete due diligence statements, with the information passed upstream throughout the chain. The revised regulation effective in December 2025 simplified downstream obligations. Downstream operators and traders no longer need to submit due diligence statements or pass declaration numbers down the chain on a tier-by-tier basis. Instead, the first downstream entity in the supply chain collects the due diligence reference number and passes it onward.

What does this mean in practice? In most cases, printing companies do not need to register in the EU information system, submit a statement, or upload geolocation data. These are the customer’s responsibilities.

Nevertheless, printing companies encounter a practical problem: customers often assume that preparing the due diligence statement is the printing company’s responsibility, because the supplier views the printer as the source of the packaging. This is how the request to complete the Paper Source Declaration arose.

Our approach is clear: we do not complete or sign documents on the customer’s behalf, and we do not issue anything that appears to be a due diligence statement. This is not simply a matter of avoiding extra work; there are two legal reasons:

• The obligated party is incorrect. The operator owes the statement, not the packaging manufacturer. If a printing company signs the document, it places itself in a legal position it does not occupy.
• We do not have the data. Plot-level geolocation, harvesting permit numbers, and forest ownership information reside in the upstream paper mill’s supply chain and are generally inaccessible to the printing company.

When customers ask us to prepare a template they can complete themselves, we can help. Providing a checklist of the documents customers should request from their paper mills falls within our professional scope. Completing and submitting the declaration remains the customer’s responsibility. We include this boundary in quotations: “The factory assumes no responsibility for the compliance declarations of products entrusted to it. The client shall ensure that the raw-material evidence provided to the factory is truthful, complete, lawful, and valid.”

The Second Boundary: Geolocation Is the Hardest Requirement and the One Printing Companies Should Not Attempt to Handle

One of the core requirements under Article 9 of the EUDR is the geolocation of the plots where relevant commodities originated. It is the most demanding element of the system because the required precision is plot-specific rather than company-specific or forest-region-specific.

In practical terms, the declaration cannot merely state that the paper came from a particular company in Sweden. It must establish that the wood pulp in the paper came from a specific plot at a specific coordinate.

For upstream suppliers, this is highly complex because wood pulp is blended at the pulping stage. A single pulp tank may contain wood from several forest concessions and multiple batches. Tracing it to individual plots requires a plot-level raw-material traceability system extending through the supply chain, often down to forest concessions or even smallholders.

For printing companies, the key point is: this workload belongs upstream, not to us. During the quotation stage, we ask three questions:

1. Has the paper supplier implemented or prepared plot-level geolocation traceability, and is it feasible to apply it to this specific order?
2. If multiple suppliers are involved, can the traceability chain be followed all the way to individual forest plots? If it cannot reach plot level, the EUDR due diligence will be incomplete.
3. Will the evidence be supplied by upstream suppliers, or are we expected to verify it ourselves? This determines the printing company’s role in the compliance chain.

On the second exchange, the customer told us: “Our upstream supplier is a trader, and they said there is no problem.”

We have heard this many times. A trader’s assurance that there is no problem is not equivalent to a due diligence statement that can pass EU customs review. There may be several breaks in the traceability chain between the two. For this reason, we now include the following in our risk notice: If the customer cannot explain how the traceability chain reaches plot level, we recommend obtaining written confirmation from upstream suppliers before placing the order and specifying in the contract that raw-material compliance is the client’s responsibility.

One timeline must also be made clear to every customer. EUDR applies in two stages: large and medium-sized operators must comply from 30 December 2026, while micro and small enterprises must comply from 30 June 2027. Micro and small enterprises already covered by the EU Timber Regulation (EUTR) must comply from 30 December 2026. The European Commission reaffirmed the 30 December date in its simplified review published in May 2026.

In other words, less than three months remain before the EUDR becomes applicable to large and medium-sized operators. Customers within this size category should already be progressing their preparations rather than waiting until a supplier raises the issue.

The Third Boundary: Whether a Printing Company Is Responsible Depends on How the Paper and Paperboard Enter the Packaging

To clarify a printing company’s position under EUDR, three scenarios must be distinguished:

The third scenario is the easiest to overlook. The EUDR definition of an operator includes a person who first makes a relevant product available on the EU market. If a Chinese printing company sends finished color boxes directly to an EU customer for sale in the EU, the act of making the product available may fall within the printing company’s responsibilities.

Our factory operates as a contract manufacturer. Finished packaging is handed over to a domestic customer, which exports it or passes it to the customer’s European branch. Under this arrangement, the printing company generally does not fall within the sequence of operators. One exception must be monitored: if the printing company assumes responsibility for export, customs clearance, or delivery to EU buyers in its own name, it may become an operator.

Accordingly, in practical communications, we tailor our guidance to three types of customers:

“You are a brand owner exporting directly to the EU. You are the operator and must prepare the complete due diligence statement, obtaining material evidence from your paper mill or other upstream suppliers.”

“You have a European subsidiary. The declaration obligation belongs to that entity, and we will support it by providing accurate material information.”

“You are a trader to whom we deliver the goods. You must determine your position in the chain, but we will provide truthful material information without endorsing compliance.”

After hearing these explanations, customers generally understand what they need to do. Last year, one customer asked: “We do not use wood pulp ourselves; someone else makes the paper. Why is this our responsibility?”

Our response was: “You may not make the paper, but you are placing the packaging on the EU market. You are the furthest from the forest and the closest to customs. You do not need to track the forest yourself. You need to make sure your upstream suppliers can trace the chain to individual plots, then submit the declaration through the EU system.”

The Three Documents to Request Before Accepting an EU Order

For every EU-bound order involving paper packaging, we require three documents. If any one is missing, we state the risk in the quotation:

• First: an upstream paper mill raw-material origin declaration. It must identify the pulp source plots, tree species, and harvesting permit information. We do not assess the compliance conclusion; we verify whether the document exists, who issued it, and whether it covers the specific order.
• Second: the client’s written confirmation of the EUDR obligated entity. It must identify the operator, the trader, and the party responsible for submitting the due diligence statement. The printing company is responsible only for providing accurate material information.
• Third: confirmation that the traceability chain reaches individual plots. If upstream suppliers include multiple trading layers, each transition point must be clearly identified. If the chain cannot reach plot level, we must warn the customer in advance.

Once these documents have been received, we include the following language in the production sheet and contract: “The factory uses paper designated by the client. Raw-material compliance is the client’s responsibility, and the factory makes no declaration or warranty regarding the deforestation compliance of the relevant goods.”

When customers respond, “We are just an ordinary printing company, so none of this is our concern,” our standard response is now: “You are correct, so we will not sign the declaration on your behalf. However, we do need the three documents because they establish our own compliance record and provide the evidence needed for the client to clear the applicable requirements.”

Further Reading

• The 3 Practical Impacts of Europe’s New PPWR Regulations on Printing Companies in 2026—Within the same EU packaging compliance framework, PPWR governs the packaging itself, while EUDR governs raw-material origin. Both can apply to the same order.
• 4 Packaging Compliance Requirements for EU Exports: REACH / EC 1935/2004 / 94/62/EC / EN 13427—Compliance on the chemical side and compliance on the raw-material origin side must both be addressed.
• The Real Ledger for 3 Types of FSC Chain-of-Custody Management in Printing Companies—An FSC certificate demonstrates chain of custody, while EUDR requires plot-level geolocation. They are not interchangeable.
• The 3 Practical Boundaries of the EU General Product Safety Regulation—Another responsibility line that must be implemented for the same EU-bound orders.
• 3 Common Packaging Company Compliance Violations and Penalty Standards—A practical view of the real consequences of non-compliance.