EUDR DDS for Paper & Pulp Supply Chain in the UK 

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, 12 minute read

Quick summary: TraceX helps paper and pulp companies in UK achieve EUDR compliance through automated Due Diligence Statement (DDS) generation, blockchain-based fibre traceability, and real-time deforestation risk monitoring

The EU Deforestation Regulation (EUDR) DDS for Paper & Pulp Supply Chain in the UK requires companies exporting or supplying paper, pulp, and wood-based products to EU markets to prove that their materials are deforestation-free and legally sourced. Operators must provide geolocation data, legality documentation, and submit Due Diligence Statements (DDS) through the EU’s information system. Although the UK is outside the EU, exporters must support EU buyers’ compliance by ensuring upstream traceability, supplier verification, and digital documentation, making transparent, verifiable data management essential for maintaining market access and sustainability leadership. 

Stay ahead of the 2025 regulation with our expert guide on Due Diligence Statements, traceability workflows, and category-specific obligations for operators, traders, and downstream entities.

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The EUDR Landscape for Paper & the UK 

What is the EU Deforestation Regulation (EUDR)? 

The EUDR (Regulation (EU) 2023/1115) sets out to ensure that certain commodities and products placed on the EU market are deforestation-free and legally produced. It builds on previous timber legislation, extending due diligence to additional wood-derived products 

Why paper and pulp matter under EUDR. 

Wood and its derivatives—such as pulp, paper, board, and packaging are explicitly listed in Annex I of the EUDR. For UK-based paper and pulp producers, merchants and exporters, this means that their supply chains must comply whether they place products into the EU market or support EU buyers who do. 

Why the UK is a critical part of this picture. 

Although the UK is outside the EU, any UK-based company whose paper or pulp products are exported to the EU or whose UK-made products enter the EU distribution chain must supply compliant due diligence data to enable the EU buyer’s compliance. Many UK firms, therefore, act as critical upstream suppliers, meaning they will be under pressure to align with EUDR requirements. 

Key deadlines & scope you need to know. 

  • The regulation entered into force on 29 June 2023.  
  • The full obligations for medium and large operators apply from 30 December 2025.  
  • For micro and small enterprises, the deadline is extended to 30 June 2026.  
  • Paper, board and other wood-derived products fall under “relevant products” in the scope; recycled fibre exclusively may be exempt if entirely from waste. 

How this applies to the paper & pulp supply chain in the UK. 

From forest origin (outside EU) to pulp mill, paper/board manufacturing in the UK (or imported), through UK distribution and onward to EU markets, the chain must demonstrate traceability back to the forest plot, legality of the harvest, and absence of deforestation post-cut-off (31 December 2020). UK operators supplying EU-bound products must ensure their upstream suppliers provide geolocation data, legal permits, and due diligence statements (DDS). 

This landscape means UK paper & pulp stakeholders must address: 

  • Mapping upstream raw fibre or pulp origins and verifying them. 
  • Classifying products correctly (virgin fibre vs recycled content) to determine applicability.  
  • Building traceability systems capable of capturing forest plot geolocation, harvest dates, legality documentation, and integrating with EU systems. 
  • Ensuring that, as a non-EU supplier or exporter, they provide the necessary data to EU buyers (or act as the “operator” where applicable). 

Master the step-by-step process of submitting Due Diligence Statements under the new EUDR rules. 
Read the blog on filing DDS for EUDR compliance 

Curious how the EUDR will reshape the paper and pulp industry?  

The regulation is more than a compliance requirement; it’s a turning point for transparency, traceability, and sustainability in fibre-based value chains. 

Read our blog: The Impact of EUDR on the Paper & Pulp Industry 

What are the Key Challenges Faced by UK Paper & Pulp Companies 

The EU Deforestation Regulation (EUDR) presents several operational and data-related hurdles for UK-based paper and pulp companies exporting to the EU. These challenges stem from both the nature of the global fibre supply chain and the UK’s position outside the EU regulatory perimeter. 

1. Complex Sourcing Networks 

Most UK producers and traders depend on imported pulp and fibre aggregated from multiple origins, Scandinavia, Latin America, Asia, and North America. Each region operates under distinct forest-management systems, creating fragmentation in data quality, legality verification, and certification coverage. Blended sourcing through intermediaries and brokers further complicates mapping fibre back to the forest plot, as required by EUDR. 

2. Geolocation & Traceability Difficulties 

Paper and pulp production often involves a mix of virgin and recycled fibres, where virgin fibre may originate from several concessions or forest owners. Establishing plot-level geolocation for each input is particularly difficult when mills process bulk shipments from different regions. Recycled content adds a layer of ambiguity since it is partly exempt, yet mixed compositions make documentation classification challenging. 

3. Documentation & Legality Variations 

Countries exporting pulp to the UK such as Brazil, Indonesia, or Canada maintain divergent legality frameworks, forest codes, and deforestation definitions. As a result, UK importers must reconcile multiple documentation standards, from national legality certificates to private sustainability labels, while ensuring that all meet the EUDR’s legal production and deforestation-free criteria. 

4. Product Complexity & Derivative Chains 

The paper value chain is characterized by significant transformation: fibre → pulp → paper → packaging or print material. Each conversion step potentially involves new blending or processing that can obscure the origin of fibre inputs. Furthermore, harmonized system (HS) codes for certain semi-finished goods are ambiguous, creating classification uncertainty for EUDR reporting. 

5. Export & Market-Access Risk 

EUDR compliance is becoming a market entry requirement for the EU. Failure to provide adequate DDS data or traceability could lead to blocked shipments, heightened inspection frequency, or even buyer withdrawal. EU publishers, packaging firms, and retailers are prioritizing verified deforestation-free suppliers, making traceability a commercial differentiator. 

6. UK-Specific Nuance 

While the UK is no longer an EU Member State, its companies remain integral to EU supply chains. This means they must supply compliant data and traceability evidence to support their EU partners’ Due Diligence Statements, even if they are not the “operator” under the regulation. Practically, this requires UK firms to adopt digital traceability systems compatible with EU reporting platforms, ensuring seamless data exchange and credibility. 

In essence, the UK paper and pulp sector faces the dual challenge of aligning globally sourced raw materials with EU regulatory demands while digitally transforming legacy documentation systems to achieve EUDR-level traceability. 

How TraceX Simplifies EUDR DDS for Paper & Pulp in the UK 

As the EU Deforestation Regulation (EUDR) deadlines approach, UK paper and pulp companies are under pressure to ensure full traceability, legality verification, and due diligence compliance across multi-origin fibre networks. The TraceX EUDR Compliance Platform offers an intelligent digital solution designed to simplify and automate the entire compliance process, enabling UK exporters, converters, and distributors to maintain smooth trade with EU markets. 

End-to-End Digital Traceability from Forest to Finished Product 

TraceX enables plot-level visibility across the UK paper and pulp value chain from forest concessions and pulp imports to UK mills and downstream converters. Each fibre batch or shipment is digitally linked to its verified forest origin, ensuring compliance with EUDR’s deforestation-free and legal production criteria. 

Automated DDS Generation and Submission 

TraceX automates the creation, validation, and submission of Due Diligence Statements (DDS) for every EU-bound shipment. By integrating supplier declarations, legality certificates, and geolocation data, the platform ensures that UK operators can submit compliant DDS documents seamlessly to the EU’s reporting system, eliminating manual effort and reducing audit preparation time. 

Blockchain-Backed Chain of Custody 

Each transaction in the fibre journey from forest harvest to UK processing and export is recorded on a secure blockchain ledger, creating a tamper-proof proof of origin. This immutable digital record strengthens transparency, helps UK exporters demonstrate verified sourcing, and reassures both regulators and EU buyers. 

Supplier and Forest Concession Onboarding 

TraceX simplifies the onboarding of global suppliers and forest owners through its multilingual, mobile-enabled platform. Suppliers can upload documentation, capture GPS coordinates, and register forest plots digitally, enabling full compliance with EUDR traceability standards even for small or remote forestry operators. 

AI-Powered Risk Assessment and Monitoring 

TraceX’s real-time dashboards provide AI-driven insights into legality verification, deforestation exposure, and supplier performance across key sourcing regions. UK mills and exporters can monitor supply chains proactively, flag non-compliance, and take corrective actions long before inspections or border checks occur. 

Use Case: UK Paper & Packaging Manufacturer 

A leading UK-based paperboard manufacturer sourcing pulp from Brazil and Scandinavia uses TraceX to map supplier plantations, verify legality documents, and auto-generate EUDR DDS reports for EU-bound shipments. Within weeks, the company can achieve full supply chain traceability, cut compliance time by 60%, and enhance sustainability disclosures for its European retail partners. 

By combining AI analytics, blockchain-backed traceability, and automated DDS workflows, TraceX transforms EUDR compliance from a regulatory burden into a competitive advantage. UK paper and pulp companies can ensure deforestation-free supply chains, build buyer confidence, and strengthen their sustainability leadership in global trade.

Simplify EUDR DDS generation for UK paper and pulp exporters.

See how TraceX can help your business achieve transparent, compliant, and future-ready supply chains.

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Strategic Implications & Business Benefits for the UK Paper & Pulp Sector 

The implementation of the EU Deforestation Regulation (EUDR) is more than a compliance requirement it’s a defining moment for the UK’s paper and pulp industry to strengthen its position as a trusted, sustainable partner in global trade. While meeting EUDR standards is essential for continued EU market access, forward-thinking companies are realizing that it can also unlock strategic business advantages across multiple dimensions. 

Competitive Advantage through Verified Transparency 

UK paper and pulp companies that achieve deforestation-free and fully traceable supply chains will be the first choice for EU buyers under growing regulatory and consumer scrutiny. Transparent sourcing data builds credibility, ensures smoother customs clearance, and reduces the risk of shipment delays. Companies that can demonstrate verified origin data and digital DDS documentation will not only maintain access to the EU market but also attract long-term procurement contracts with sustainability-driven customers. 

ESG & Sustainability Credentials 

EUDR compliance aligns directly with the Environmental, Social, and Governance (ESG) priorities of global brands and financial institutions. By embedding deforestation-free assurance within their fibre sourcing and production processes, UK firms can integrate EUDR alignment into broader sustainability narratives such as net-zero targets, circular economy commitments, and biodiversity protection. Linking EUDR readiness to ESG reporting enhances brand reputation, investor confidence, and alignment with global sustainability frameworks like the Science Based Targets initiative (SBTi) and the Taskforce on Nature-related Financial Disclosures (TNFD). 

Risk Mitigation & Supply Chain Resilience 

The EUDR introduces strict verification and enforcement mechanisms meaning that non-compliance could result in shipment seizures, fines, or loss of buyer confidence. By adopting digital traceability systems and standardized data-sharing frameworks, UK companies can proactively reduce exposure to these risks. Moreover, traceable sourcing improves supply chain resilience by giving businesses clear visibility into raw material flows, allowing them to detect disruptions early and diversify sourcing away from high-risk regions. 

Market Leadership & Sustainable Trade Positioning 

The UK’s paper and pulp sector has an opportunity to emerge as a regional leader in responsible fibre sourcing. By embracing digital traceability, blockchain-based verification, and AI-driven risk assessment tools, UK manufacturers and exporters can position themselves ahead of EU competitors. Demonstrating proactive compliance shows leadership in climate-positive, deforestation-free trade, helping companies secure preferential supplier status with global packaging, publishing, and FMCG brands that increasingly demand verified sustainability credentials. 

In short, EUDR readiness is not just about regulation it’s about reputation, resilience, and relevance. 
For UK paper and pulp companies, early adoption of digital traceability tools like TraceX can transform compliance into a strategic differentiator, enabling them to lead the next era of transparent, sustainable, and deforestation-free global trade. 

EUDR DDS for the Paper & Pulp Supply Chain in the UK: The Road Ahead 

The EU Deforestation Regulation (EUDR) marks a pivotal shift for the UK paper and pulp industry from traditional documentation-based compliance to data-driven, digitally verified transparency. As the December 2025 deadline approaches, UK importers, manufacturers, and exporters must move quickly to embed traceability, legality verification, and due diligence into their sourcing and operational frameworks. 

Digital platforms like TraceX are helping UK companies turn these regulatory demands into strategic strengths, automating Due Diligence Statement (DDS) creation, linking fibre to verified forest origins, and enabling real-time compliance monitoring. Beyond meeting EU trade obligations, this transformation strengthens brand trust, investor confidence, and ESG performance. 

By adopting proactive EUDR compliance today, the UK’s paper and pulp sector can secure continued EU market access, reinforce its global sustainability leadership, and ensure that every sheet, carton, and package it produces contributes to a truly deforestation-free future. 

Understand the key components of EUDR compliance and how to streamline your DDS process efficiently. 
Read the blog on EUDR Due Diligence 

Learn how AI-driven automation and intelligent workflows simplify data collection, verification, and reporting. 
Explore the blog on Agentic AI for EUDR 

Unpack the biggest hurdles faced by importers under EUDR — and how technology can turn compliance into a competitive edge. 
https://tracextech.com/eudr-compliance-importers-checklist/ 

Frequently Asked Questions (FAQ’s)


What is the EU Deforestation Regulation (EUDR)? 

The EUDR is an EU regulation designed to prevent deforestation-linked commodities such as wood, pulp, and paper products from entering the EU market. It mandates full traceability and submission of Due Diligence Statements (DDS) to verify that materials are legally harvested and deforestation-free. 

What is a Due Diligence Statement (DDS) under EUDR?

A DDS is an official declaration that confirms the origin of wood or pulp-based products. It includes geolocation data for forest plots, legality verification, and deforestation-risk assessments for each batch or shipment. 

Who needs to comply with the EUDR for paper and pulp in UK? 

All UK importers, pulp mills, paper manufacturers, converters, and traders that place wood-based products on the EU market must comply with EUDR DDS requirements. 

What are the biggest challenges for UK paper and pulp companies under EUDR?

Companies face difficulties collecting geolocation data, managing complex supply chains with mixed fibre sources, verifying legality documentation from multiple countries, and manually preparing DDS reports for submission. 

 Can TraceX handle multi-source or recycled fibre inputs? 

Yes. TraceX’s system is designed for hybrid supply chains. It can track both virgin and recycled fibres, document mixed sources, and maintain full transparency for EUDR audit and reporting purposes. 

How does TraceX support Italian companies in EUDR readiness?

By digitizing due diligence, providing real-time risk analytics, and automating DDS submissions, TraceX enables Italian paper and pulp companies to stay compliant, minimize risk, and strengthen their sustainability credentials.

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Download your EUDR DDS for Paper & Pulp Supply Chain in the UK  here

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