EUDR – European Deforestation Regulation

Introduction

Coming into effect on 30th December 2025, the object of the new EU Law is to ensure that products entering the EU supply chain are sourced without unauthorised deforestation. This applies to a large range of products covered under cattle, cocoa, coffee, palm oil, rubber, soy, and wood.

For the purposes of our industry, when books (or the materials that make books) are entering the EU, they must carry with them an audit trail of where the timber was sourced from, and that the timber was sustainably sourced.

Quick Summary

In essence, the book industry is expected to declare the source (geocoordinates and species of tree) of each of the paper components of a given book being sent into the EU. Anything that does not have traceability (including because it is just unknown) cannot be imported into the EU as of 30th December 2025. The fact that the book may have been made from sustainably sourced timber is not enough on its own.

There are exemptions, and these include paper sourced from entirely recycled paper pulp, or product that was already manufactured and in the supply chain before June 2023. For these there are new additional Taric (Tariff) exemption Codes.

As we know, any book is manufactured from more than one type of paper. A simple paperback book will have at least one paper being used for the cover, and another for the content. A hardback would have at least three types of paper, slip, cover, and content.

Furthermore, each may have more than just two paper types, i.e. glossy image paper etc.

However, each paper type for each book must be declared.

Each time a book is reprinted (a new impression run), the paper types for the book will have changed, requiring a fresh registration.

The EU have created a system (called traces) for registering the details for each product, and then assign a DDS (Due Diligence Statement) reference number. This number must be declared as part of the customs declaration by the importer of the product (or the exemption Taric Code) prior to entering customs. Attempting to import anything that does not have a genuine exemption, or DDS will result in refusal and fines, and harm to reputations.

Gardners obligations for customers within the EU

Both Gardners UK and Gardners EU have a great many customers within the EU, and in order to continue selling publishers titles into the EU we will require the EUDR data from you.

We will need to initially filter our range of content being made available to EU customers to titles that;

1. Have a stated DDS reference
2. Have sufficient details for Gardners to create a DDS,
3. Categorically will have either of the above when printed (NYP’s and POD’s), or
4. Are exempt, and the reason, i.e. made from 100% recycled paper.

When Gardners prepares to ship an order to an EU customer we will be required to supply either the customer or their shipper with the DDS references (or exemption codes) for everything prepared. The customer or shipper will then submit these as part of their customs declaration. Without this information, we will not be able to ship the products.

The customer will then be required to retain this information in order to fulfil any audit requests they may have from their country’s authorities in the future.

Gardners will be providing this data in the following ways;

1. Product Onix feeds
2. Product Price and Availability Feeds
3. Automatic Shipping Notices (ASN’s)
4. Shipping Manifests
5. Electronic Commercial invoices.

Individual customers will have other specific ways or workflows that they require, and as ever we will accommodate those.

Gardners requirements of Publisher/Distributor

In order to offer and fulfil orders to the EU, through either Gardners UK or Gardners EU, we will require the EUDR data from you the publisher (or distributor).

Gardners are expecting this data to be supplied in one or more of the following:

1. 1. Onix 3.1

   For “traditionally printed” books, the primary method of transmission is Onix 3.1. the following Onix snippet offers some examples of how that might be described:

   

   The highlighted section shows a DDS reference declaration in use. This is our preferred declaration.

   If, however, Gardners are going to generate the source DDS, the two entries above that show how the geocoordinates and tree species might be described for each type of paper (two in this case) used within the book.
   Where a book is either forthcoming, being reprinted, or is manufactured on demand, and therefore the paper details are not currently known, we will still expect a statement to be supplied within the Onix to confirm that the DDS will be supplied as soon as known (before despatch to Gardners). Gardners will require this information in order to offer these titles for backorder to EU customers.Product Onix feeds

   1. Product Price and Availability Feeds
   2. Automatic Shipping Notices (ASN’s)
   3. Shipping Manifests
   4. Electronic Commercial invoices.
   5. Other electronic feed.

If you would like to discuss further, please contact the Gardners Data Services Team at: dataservices@gardners.com