What the EU Deforestation Regulation Means for the Publishing Industry

The European Union Deforestation Regulation (EUDR) is reshaping how products containing materials derived from forests are sourced, tracked, and sold in and out of the EU. Whilst the publishing industry might be several steps downstream from where trees are harvested, the regulation's reach extends directly to books, paper, and packaging - all of which rely on wood-derived materials.

At its core, the EUDR aims to ensure that certain commodities (including wood and its derivatives) are deforestation-free and compliant with local legal requirements. This means every company placing books or printed materials on the EU market must be able to prove that the materials used can be traced back to the specific plot of land where the trees grew.

Why Publishers Should Take Note

Even if your business doesn’t buy wood-products directly, or you yourself are not based in the EU, if you are trading into, from or through the EU, you’re still part of the supply chain. Publishers, printers, distributors, and retailers all have a role to play in ensuring compliance.

Printed materials such as books, newspapers, and guides made from paper or paperboard fall within the scope of the EUDR if they are distributed in a commercial context - meaning not for private use or personal consumption. Even if provided free of charge, these materials must be compliant, as they are considered relevant products when made from or containing wood-based materials.

That said, a draft Delegated Act proposes that certain products be excluded from EUDR, including:

• User manuals, information leaflets, catalogues, brochures, marketing materials, and labels accompanying other products - unless they are placed or made available on the market or exported in their own right (FAQ 2.5).
• Samples of negligible value and quantity, used only to solicit orders for goods, including items used for examination, testing, or analysis (FAQ 2.14).

It’s worth noting that the publishing sector has not previously been subject to the EU Timber Regulation (EUTR) or the UK Timber Regulation (UKTR) - however, many of the industry’s key suppliers, such as paper and pulp mills or paper merchants, have been. This means that while EUDR introduces new obligations for publishers themselves, their upstream supply chains are likely already familiar with traceability requirements and due diligence processes. In many cases, the foundations for compliance are already in place.

Key Obligations for Publishers

• Due diligence: You must be able to demonstrate (and prove) that your suppliers are sourcing paper, board, covers (such as leather) or packaging from deforestation-free origins.
• End-to End Traceability: You need visibility back to the geolocation of the forest where the raw material originated.
• Risk assessment: You should evaluate the likelihood of deforestation,  illegality or mixing / circumvention in your supply chains and take mitigating actions if needed.
• Record-keeping: EUDR requires companies to retain verifiable data and make it available to competent authorities upon request.

What This Means in Practice

The Book Industry Communication (BIC) initiative has been leading collaborative efforts to help the publishing sector prepare. Their EUDR Practicalities – Fast Track Project provides valuable resources such as:

• Data flow maps for typical publishing supply chains (e.g. print-on-demand, non-EU printing, international imports).
• Guidance documents explaining how to gather and share the necessary data across publishers, printers, and suppliers.
• FAQs and updates as the EU clarifies implementation details.

Although discussions continue around potential amendments and phased implementation , publishers should not wait. Implementation - from data collection to supplier engagement - takes time and coordination.

Questions We’re Hearing from Publishers

As the sector digests what EUDR means in practice, several common questions are emerging. One we often hear is:

“We’re a UK publisher with export copies of books already circulating in EU markets. If our books are already sold in Germany and Spain, why would they be considered ‘first placed’ when we ship the same title to Italy?”

The confusion is understandable. However, the European Commission’s Guidance Document (section 1.3(a)) makes clear that “the concept of ‘placing on the market’ refers to each individual relevant commodity or product, not to a type of product.”
This means that EUDR obligations are triggered each time an individual physical copy is first made available on the EU market - regardless of whether identical copies of the same book are already available in other Member States.

So, while some copies from your print run may already be on the EU market, any additional copies stored in a UK warehouse and newly imported into another Member State (for example, Italy) are considered to be placed on the Union market for the first time.

This distinction, though frustrating, is key for understanding how existing UK stock will be treated under EUDR.

How Interu Can Help

At Interu, we specialise in digital traceability that helps industries like publishing navigate complex regulations such as the EUDR.

Our technology enables:

• End-to-end data verification: Securely connect all participants in your supply chain, from paper mills to printers, ensuring data integrity and accuracy.
• Geolocation validation: Capture and manage geolocation evidence for materials derived from wood.
• Risk visibility: Gain clear insights into which suppliers or regions may pose compliance risks and identify gaps in your supply chain.
• Audit readiness: Create, store and share due diligence statements with authorities and partners in one secure platform due to our integration with TRACES NT.

EUDR compliance is not just about avoiding penalties, it’s about demonstrating leadership in responsible sourcing and sustainability. Publishers who prepare now will strengthen their relationships with environmentally conscious readers and retail partners alike.

Stay Ahead

Interu will be attending publishing industry events throughout the year to support businesses preparing for EUDR. If you’d like to understand how the regulation applies to your supply chain, or to see a demo of our traceability platform, get in touch with us today.

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