EUDR & the Print Exemption: What’s Actually Covered - and What Isn’t

As the European Union Deforestation Regulation (EUDR) continues to take shape, the European Commission, Parliament, and Council has issued new clarification around printed materials - and at first glance, it sounded like welcome news: “Print is exempt.”

But as ever, the reality is more nuanced. Not all printed items fall under the exemption, and with Christmas approaching, a number of high-volume festive products remain firmly in scope working as a stark reminder of the number of organisations affected. 

This update also lands alongside the EU’s recent decision to delay EUDR enforcement by one year, pushing full implementation to December 2026 for Enterprises and June 2027 for SMEs. But this delay doesn’t remove obligations, it simply gives businesses more time to prepare.

Let’s break down what’s exempt, what isn’t, and what this means for Interu users and their suppliers in a variety of sub-sectors. 

What Has the EU Clarified?

The 3 institutions have confirmed that printed materials classified under HS/CN Code 49 are exempt from EUDR. These products are considered to derive their essential value from the printed content, not the paper or other substrate they’re printed on. 

HS/CN Code 49 - Exempt Materials

Examples include:

• Books
• Newspapers and magazines
• Children’s colouring books
• Pictures and art prints
• Maps and technical plans
• Stamps and banknotes
• Greeting cards and postcards
• Calendars
• Photographs
• Catalogues
• Commercial printing products
• Trade advertising materials

If your business handles these materials, this exemption removes what would otherwise be a significant administrative burden.

But That Doesn’t Mean Everything Printed Is Exempt

Here’s where many organisations risk misunderstanding the update. Not all printed products qualify for the exemption. In fact, a large portion of printed goods sit under a different classification entirely.

HS/CN Code 48 - Not Exempt

This category includes products where the print is not the primary purpose. Instead, the printed surface supports another use - packaging, decoration, or functional application.

Examples include:

• Wrapping paper 
• Printed packaging of all kinds
• Printed labels
• Wallpaper and wall coverings
• Stationery products including printed notebooks, pads, envelopes

All HS 48 products remain fully in scope of EUDR. This means the first downstream operators and must still demonstrate:

• The goods are deforestation-free
• They were legally produced
• They can be traced back to their plot of origin

For businesses handling high-turnover, low-margin goods - particularly festive packaging, home décor, or stationery lines - this is an important distinction.

Note: You may notice that traders are no longer included. That is because following the December 2025 update, downstream obligations have changed. The first downstream operator must collect and pass on due diligence statements, while further downstream traders are no longer required to conduct full due diligence.

What About the One-Year EUDR Delay?

The EU’s recent decision to delay enforcement to December 2026 gives businesses more breathing room. But it does not change product classifications or the underlying requirements.

Here’s what the delay does:

• Gives operators additional time to implement traceability systems
• Allows sectors handling high-turnover goods (like packaging and stationery) to adapt

Here’s what it doesn’t do:

• Remove HS 48 products from scope
• Change what’s exempt under HS 49
• Eliminate the need for due diligence - it simply shifts the deadline

For seasonal goods manufacturers, importers and retailers, this is valuable lead time, but not a reason to pause preparations.

Why This Matters for Seasonal Supply Chains

Christmas products, from wrapping paper to decorative packaging, are often produced in massive volumes, sourced globally, and used instantly. These supply chains can be complex, fast-moving, and reliant on low margins.

That makes clarity around HS codes critical. Misclassifying a product as exempt could lead to compliance failures once enforcement begins.

Wallpaper, party supplies, stationery, gift packaging, and decorative prints also see sales spikes during the holiday season, yet remain under Code 48. These are precisely the categories that need robust traceability plans well before 2026.

What Businesses Should Do Now

If you handle any HS 48 products, seasonal or otherwise, now is the time to ensure you can:

• Correctly classify your printed goods
• Work with suppliers to access fibre origin data
• Collect, verify and store due diligence records
• Build a system that can scale during seasonal spikes

At Interu, we’re supporting companies across packaging, paper, and wood-products to prepare for EUDR with confidence - even through evolving guidance and deadlines.

If you’re unsure whether your product is exempt, get in touch with our team today. We’ll guide you through it with confidence.

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