Information on EUDR

Current status

On 2 October 2024, the European Commission submitted a proposal to postpone the entry into force of the EU Regulation on Deforestation (EUDR) by 12 months (more information available here). The postponement has not yet been approved. It is a proposal/communication document that must go through the standard legislative process. Until a new amendment is adopted, the dates listed below remain valid.

Over the past year, we have been actively preparing to meet the EUDR requirements. On 23 September 2025, the European Commission announced its intention to postpone the implementation of the regulation by another year. The reason is based on findings from testing — the central EUDR information system still needs to be further supplemented and stabilized due to the large volume of transmitted data (more information available here).

Whati is EUDR?

EUDR (Regulation (EU) 2023/1115) – The EU Regulation on Deforestation aims to prevent products originating from deforested or degraded areas after 31 December 2020 from being placed on the EU market.
The regulation applies to the following commodities: wood, coffee, cocoa, palm oil, rubber, soy, and beef (including products derived from them).

Effective date

• Large and medium-sized enterprises: from 30 December 2025.
• Micro and small enterprises: from 30 June 2026.

Our role

• GRASPO CZ processes paper-based materials — we purchase already processed inputs.
  
•           Within the EUDR framework, we are not an “operator” (first placing entity) but a “trader” (subsequent trader / downstream).
• We are classified as a medium-sized enterprise.

Which products are affected

• The EUDR applies to specific items listed in Annex I of the regulation — for example, to pulp and paper from CN Chapters 47 and 48 (excluding bamboo and recycled/waste products), and to selected printed products from CN Chapter 49.

Our role as a printing house

• We act as a trader (downstream entity) because we purchase already processed paper and use it to produce printed materials. As an SME trader, we do not submit our own Due Diligence Statement (DDS) for products already covered upstream. Our obligation is to register in the EU EUDR Information System (TRACES), obtain and retain our suppliers’ DDS reference and verification numbers, ensure traceability, and keep these records for at least five years.

What we receive from suppliers and what we record

• Reference number of the Due Diligence Statement (DDS) from TRACES, along with supporting documentation on origin and classification (HS/CN).
• This information is recorded and archived for at least five years for traceability and audit purposes. 

 We are prepared to maintain and, upon request, provide the relevant EUDR documentation (RN/VN) for your order.

This text is continuously updated in line with the development of legislation and the TRACES system.
If you have any questions regarding your specific order, please contact us.

Last updated: 3 November 2025

Sources:

-          Regulation (EU) 2023/1115

-          Regulation (EU) 2024/3234 – oficiální roční odklad

-          European Commission – EUDR implementation (Green Forum/TRACES)

-          CEPI Guidance