EUDR and paperboard
Do you work with paperboard and packaging products? Here’s what you need to know about EUDR, the European Union’s Deforestation Regulation.
How to ensure EUDR compliance for your paperboard and packaging
EUDR, the European Union’s Deforestation Regulation, focuses on the origin of the raw material for commodities and products derived from cattle, cocoa, oil palm, coffee, rubber, soy and wood. To comply with EUDR, the relevant commodity or product must be deforestation free, legally produced, and covered by a due diligence statement.
“Does EUDR apply to packaging?” is a question we often get. The answer is yes, if you work with packaging as a standalone product, but no, not if you use packaging only to transport and protect another product.
Quick links to find your product
To determine your role and whether your product falls under the EUDR scope, identify the Harmonized System (HS) codes related to your business and check them against the list in EUDR Annex I.
Continue reading on this page if you work with products related to paperboard, such as Invercote® or Inverform® from Iggesund Mill or Incada® from Workington Mill.
Or click the following link to read more about EUDR for paper and printed products.
Here's how the traceability works
The first operator that places a relevant product on the EU market, or exports it, is called the upstream operator. The upstream operator submits a due diligence statement (DDS) including the geolocations of the commodity's origin, into the EU information system. By doing this, the operator assumes the legal responsibility for the commodity being compliant with EUDR.
For paperboard products, the commodity is wood. There is no conversion on Holmen land from forest to agriculture and we have long-standing procedures in place for tracing all timber purchased. The upstream operator for all our mills in Sweden, within the EU, is Holmen Forest. In our mill in Workington, UK, our process for acquiring raw material is equally strict. Since we follow a process aligning with the EUDR, we can
provide the reference number and verifications or the geolocations needed to fulfil the obligations of the upstream operator.
The general process is that every downstream operator or trader will refer to the reference and verification numbers that they get from the supplier who made the latest due diligence statement in the EU information system. The system will keep track of how all the references and verifications are related back to the original geolocations, provided by the upstream operator.
However, there are some administrative differences, depending on your role and whether you trade within, to, or from the EU. Please read more about this in the section “How to find and use your paperboard reference number”.
EUDR implementation timeline
Follow the most recent news and coming steps to align with the EUDR administration process.
15 April 2025 – The EUDR FAQ 4th iteration was released, entailing simplifications
The fourth iteration of the EUDR guidance document "Frequently Asked Questions - Implementation of the EU Deforestation Regulation" was released, and can be downloaded here.
The document clarifies that the submission of the due diligence statement which includes geolocation is a requirement for a product covered by EUDR to be placed on the EU market or exported from the EU. The operator first placing the product on the market needs to verify and be able to prove that the geolocation is correct. This geolocation information is to be provided in a due diligence statement for the product in the EUDR Information System. Downstream operators and traders will then be able to provide the necessary information by including the relevant reference number for the parts of their relevant products that have already been subject to a due diligence (see FAQ 1.13, 3.4 and 3.5). Depending on their role, they may or may not be required to submit a new due diligence statement into the system. However, if downstream operators or traders obtain or are made aware of information pointing to non-compliance, they must immediately inform the competent authorities and offer all necessary assistance to facilitate checks.
This process has been simplified compared to what was stated earlier. The fourth iteration of this implementation FAQ also highlights that it is the responsible authorities that enforce the EUDR by checking the information submitted into the system. All the geolocation data is stored within the EUDR information system and referred to by the reference number. This means that it will no longer be required of downstream operators and traders to gather and store all information that was stated in the regulation's article 9 (see FAQ 3.4 and 3.5).
Furthermore, it will be sufficient for the downstream operator or trader ton provide the reference number and verification number for the product, and they do not have to access or review the actual geolocation data (see FAQ 3.6 and 7.7).
30 June 2025 – Holmen's Swedish units can offer EUDR reference for deliveries on request
Holmen's paper is produced within EU, at Braviken and Hallsta paper mills. This applies to graphical paper, book paper, notebook paper, gift paper, trayliner, void fill and containerboard components.
Holmen's Invercote paperboard is also produced within EU, at Iggesund mill.
For these products, after June 30, 2025, you can obtain the EUDR reference number, which is to be entered into the EUDR platform Traces, on request.
This will be the reference number and verification number from the Acceptance server. Data in the due diligence statement at this stage will be based on information about the raw material that Holmen Group is in control of, which is the wood harvested by Holmen Forest. Suppliers from outside of the Holmen Group will be onboarded and integrated into the Holmen's platform during second half of 2025.
Q3-Q4, 2025 – Holmen Board and Paper will submit DDS to the live server
Holmen Board and Paper will begin submitting Due diligence statments (DDS) to the Live server of the Information system during second half of 2025.
During Q3 2025, onboarding of suppliers outside Holmen Group will be initiated.
During Q3-Q4 2025 due diligence statements by Holmen Board and Paper will be submitted to the Live server of the Information System, where suppliers from outside of Holmen Group will also be referenced. Reference numbers and verification numbers from the Live server will be possible to include in the delivery information.
30 December 2025 – EUDR in effect for large and medium enterprises
EUDR enters into effect for medium and large operators and traders, 30 December, 2025.
For products which were placed on the market before 30 December, but produced after 29 June 2023, there is a transition period where special rules apply. The time of harvest of the commodity will be referred to as the production date.
Wood is placed on the EU market when it is harvested. Paper and paperboard is a derived product of wood. During the transition period and until EUDR enters into effect, wood and timber products produced within the EU have to comply with the rules of EUTR, the European Timber Regulation. The forest raw material used in Holmen's Swedish mills has been harvested inside the EU market and in compliance with EUTR.
30 June 2026 – EUDR in effect for micro and small enterprises
EUDR enters into effect for micro and small enterprises, 30 June, 2025. Micro and small enterprises are defined as companies with less than 50 employees and a turnover less than 10 million Euro or a balance sheet size of less than 10 million Euro.
Read more about EU:s definition of small and medium-sized companies.
Find and use your EUDR reference number for paperboard products
Holmen develops and sells world-leading paperboard on the global market. Our solid bleached board (SBB) product Invercote® is produced at Iggesund Mill in Sweden, and our folding box board (FBB) Incada® is produced at Workington Mill in the UK. Our products are traded within the EU as well as to and from the EU.
We have control over the traceability within all parts of Holmen and our supply chains. When you buy paperboard from us, the reference and verification numbers from the EU information system, referring to the origin of the raw material associated with your order, will be sent to you as part of the delivery documentation. It will be in form of an EDI integration or a .csv file which you can import directly into a system of your choice.
You will need to keep track of these numbers to refer to the origin of your own products if you are to make your own due diligence statement in the EU Information system. In doing that, you will get the next reference and verification numbers from the EU Information system, to send to your customers, so that you can provide them with traceability for your products.
Read under the headline that applies to your business below, to learn what’s behind the administrative process flow and see how you can use the reference number to comply with EUDR for your future trade.
Buy paperboard within the EU, sell within the EU
Holmen’s paperboard products Invercote and Inverform are made at Iggesund Mill in Sweden. The wood raw material is supplied by Holmen Forest. This wood originates from Holmen’s own land or is purchased by Holmen Forest from other forest owners. In total, 90–95 percent of the timber flow to Holmen’s Swedish production originates from Swedish forests, and the remainder is sourced from countries within the EU or Scandinavia: Finland, Norway, Estonia, and Latvia.
For all harvesting operations and purchases Holmen Forest has a due diligence process to secure that national laws and guidelines are followed, in accordance with EUDR. This includes risk assessment and risk mitigation activities. Each harvesting operation is assigned a unique identity that follows the timber throughout the entire flow.
Since Holmen Forest is the upstream operator, they submit their declaration of due diligence (DDS, in Swedish FOTA) for the specific harvesting operation to assume the legal responsibility for the commodity being compliant with EUDR. They get a reference and verification number in the EU Information system, which they share with us, Holmen Board and Paper.
The wood raw material we use is traceable from the origin of the harvest to forwarding, transport, and delivery to our industry. In our production, we assign the incoming reference number to the paperboard tambour made from the incoming material. All reels and sheets made from this tambour will inherit the reference number, and when products from this tambour are part of your order, the reference number will be connected to your order. Depending on the complexity of your order, it will encapsulate one or many reference numbers to convey its origin.
Now, we at Holmen Board and Paper will submit our own due diligence statement to the EU Information system, which automatically gives us the new reference and verification numbers to send you. During Q3-Q4, 2025, the process will be fully implemented so that these numbers will be part of our delivery documentation.
You will need to keep track of these numbers to refer to the origin of your own products, when selling them on the EU market. With an exception – if the paperboard that you acquired from us will serve only as packaging for another product (and no longer be a product in its own right). In that case it will no longer be required to comply with the EUDR.
Buy paperboard within the EU, sell outside the EU
The same procedure as under the previous headline is followed, up to the point where we at Holmen Board and Paper submit our own due diligence statement to the EU Information system and get new reference and verification numbers. We will send these numbers to you as part of the our delivery documentation, and the process for this will be fully implemented during Q3-Q4, 2025.
It may seem unnecessary for you to need to keep track of these numbers to refer to the origin of your own products, if you are not planning to sell them on the EU market. But the numbers are needed to fulfil the EUDR obligations for the exporter of products from the EU to a non-EU market. Therefore, we will always provide the reference and verification numbers with the delivery, also for products sold outside of the EU, regardless of whether we are the exporter or someone else is.
However, please note that we can only provide these reference and verification numbers to the customer that we deliver the products to. It is up to you as a buyer to decide whether you choose to uphold the traceability and take on the next step for EUDR compliance as a service to your potential downstream customers. Even though your operations may take place outside of the EU, you may have reasons to uphold the traceability, in case the paperboard will be part of products that later will be reimported to an EU market. One typical example of this is paperboard used for book or magazine covers for books and magazines that has been printed outside of the EU and are sold on EU markets.
As mentioned before, there is still an exception for paperboard that will serve only as packaging for another product (and no longer be a product in its own right). In that case it will no longer be required to comply with the EUDR.
Buy paperboard outside the EU, sell within the EU
Holmen’s paperboard product, Incada, is made at Workington Mill in the UK. The fibre raw material used in 2025 originates from Holmen’s own land in Sweden or is purchased by Holmen from forestry commissions and private owners in Northern England, Scotland, Spain, or Portugal.
Holmen has a responsible approach to the purchase of all fibres for paperboard production at the Workington Mill. We only purchase fibres which originate from well-managed forests. In doing this we ensure that fibre sources present a low risk in accordance with:
- Illegally harvested wood
- Wood harvested in violation of traditional or civil rights
- Wood harvested from forest in which high conservation values are threatened by management activities
- Wood harvested from areas being converted from forests or other wooded ecosystems to plantations of non-forest use
- Wood from forests in which genetically modified trees are planted
In addition, we require all our fibre suppliers to demonstrate a responsible attitude towards environmental issues in general and to provide evidence of on-going developments to reduce any negative impacts of their operations.
Even though there is no upstream operator until a product is placed on an EU market, our Workington mill works in alignment with the EUDR process, and we make sure that all the fibre raw material comes with full information about its origin.
We register our produced paperboard tambours in the EU information system. In that process, we connect them to the earlier reference and verification numbers for their incoming material that has already been inside the EU, and we upload the geodata for their additional incoming material that has originated from the UK. When doing this, we get a new reference and verification number from the system for the tambour.
All packages with reels or sheets made from a tambour will inherit its reference number, and when products from this tambour become part of your order, the reference number will be connected to your order. Depending on the complexity of your order, it will encapsulate one or many reference numbers to convey its origin.
The upstream operator, which is the first legal entity that place a product on an EU market, will need to submit their declaration of due diligence (DDS) for the product, including the reference and verification numbers from the EU information system, to assume the legal responsibility for their product being compliant with EUDR.
We will provide our direct customers with these reference and verification numbers on delivery of the products. You will need them for your own due diligence, to sustain traceability throughout your own value chain, and for making the customs declaration.
During Q3-Q4, 2025, this process will be fully implemented, and the reference and verification numbers will be part of our delivery documentation.
As mentioned before, there is still an exception for paperboard that will enter the EU serving only as packaging for another product (and no longer be a product in its own right). In that case it will no longer be required to comply with the EUDR.
Buy paperboard outside the EU, sell outside the EU
If you buy the material outside the EU and sell to someone outside the EU, it may seem unnecessary to follow a process to comply with the EUDR, but we’d like to urge you to consider whether any derivations of your product may enter the EU at a later stage.
In that case you will need the reference and verification numbers that you will get from us in your delivery documentation to uphold your own internal traceability system for your products. We can only provide these reference and verification numbers with the delivery to our direct customers, so that they, in turn, can choose to take on the next step for EUDR compliance as a service to their customers.
As mentioned before, there is still an exception for paperboard that will enter the EU serving only as packaging for another product (and no longer be a product in its own right). In that case it will no longer be required to comply with the EUDR.
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