As the EU increases its efforts to reduce the environmental footprint of its activities, more and more legislation is adopted in this domain, which very often affects the book sector. One prominent example of this is the EU Deforestation Regulation (full name: Regulation on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation). Entered into force in June 2023, the Regulation will start applying at the end of 2024 and will have important consequences for publishers, since books are in its scope. It is therefore paramount for all publishers and other players of the book value chain, both based in the EU or doing business with EU operators, to be aware of the requirements of the EUDR, but also to start right now the preparations to ensure that compliance mechanisms are in place in time.

This is why the topic was in the spotlight at the latest General Assembly of the Federation of European Publishers, which took place on 13 and 14 June in Vilnius, Lithuania. A professional session organised with support from Aldus Up saw FEP provide a detailed explanation of the EUDR to its members, which were invited to disseminate the information to all publishers in their constituencies. FEP later circulated an information package and organised a dedicated webinar on the subject (all materials are available exclusively to FEP members).

In a nutshell, the EUDR aims to prevent the placement on the EU market of products from deforestation and forest degradation. This objective is pursued through the obligation for economic operators to set up and maintain a Due Diligence System, which consists of three steps. As step one, they have to collect certain information on the commodity or product they intend to place on the EU market, including, among other things, quantity, supplier, country of production, evidence of legal harvest. A key requirement, in this step, is to obtain the geographic coordinates of the plots of land where the relevant commodity was produced – for book publishers, the coordinates of the place where the trees were cut to make the paper that ended up in their books. The relevant information must be provided through a due diligence statement, which is then made available to other players along the value chain and to surveillance authorities. In step two, companies have to carry out an assessment of the risk of non-compliant products entering the supply chain, based on the information gathered under the first step. In step three, they have to take adequate and proportionate mitigation measures in case they find under step two more than a negligible risk of non-compliance, in order to make sure that the risk becomes negligible. If entities subject to the Regulation cannot collect the required information or are not satisfied that the risk of non-compliance is negligible, they must refrain from placing the products on the market; failure to comply can lead to potential significant sanctions.

By imposing such strict requirements to all players in the value chain (with certain differences based on role and size) and by making everyone liable, the EU legislators aim to “clean up” global supply chains and curb the phenomenon of deforestation and forest degradation. Compliance, however, will inevitably introduce elements of complexity in publishers’ operations – especially if they print or buy paper outside of the EU. The European Commission is developing a series of tools to facilitate compliance with the EUDR and accompany its implementation (such as FAQs, and an information system that will serve as a registry for the due diligence statements). Nevertheless, several questions regarding various aspects of the EUDR implementation remain open. Once again, it is essential for publishers to get prepared and start conversations with their suppliers in order to meet the application deadlines (30 December 2024 for medium and large companies, 30 June 2025 for micro and small ones).