EU Deforestation Regulation (EUDR) 2025: What Due Diligence Statements Mean for Wood Pulp Importers from China

This guide is written for the Chinese wood pulp and paper exporter who is preparing for the EUDR compliance cycle — the mill-side operations manager, the export sales lead, the sustainability documentation owner, and the trading-company representative who buys and re-sells Chinese paper into EU member-state markets. The framework below is built around the EUDR text, the European Commission guidance, and the practical documentation that a Chinese paper mill needs to be ready to deliver to an EU importer on the first shipment after the December 2025 deadline. The product reference point is the Bincheng tissue parent roll program for the household-paper scope and the Bincheng industrial paper program for the industrial-paper scope, both of which sit inside the EUDR wood-product perimeter under the European Commission’s published scope guidance. Authoritative references for the EUDR framework include the Regulation (EU) 2023/1115 text on EUR-Lex, the European Commission’s EUDR overview and due diligence guidance, the European Commission information system for due diligence statements, the Forest Stewardship Council chain-of-custody certification, and the Programme for the Endorsement of Forest Certification chain-of-custody standard.

Quick Read

• EUDR’s first operational deadline is 30 December 2025 for large operators and 30 June 2026 for SMEs, after a 12-month postponement agreed in late 2024. The regulation was adopted as Regulation (EU) 2023/1115 and entered into force in June 2023.
• The seven in-scope commodities are cattle, cocoa, coffee, oil palm (palm oil and palm kernel oil), rubber, soya, and wood. Wood includes wood pulp, charcoal, and a range of wood-derived paper products under Commission guidance.
• Every EU importer of in-scope products must file a due diligence statement in the EU Information System before placing the product on the EU market or exporting it. The statement is a binding legal document, not a customs form.
• The hardest part is geolocation. Every plot of land that produced the wood in the product must be identified with polygon coordinates or a centroid point, and the geolocation must cover the full supply chain back to the country of harvest.
• Penalties scale to 4% of EU annual turnover, plus confiscation of the products and potential temporary exclusion from EU public procurement.
• For a Chinese wood pulp mill, the practical compliance package is a five-step documentation program that starts with FSC/PEFC chain-of-custody certification and ends with the shipment-level data exchange the EU importer needs to file the due diligence statement.

What EUDR is and what 2025 means

The EU Deforestation Regulation is Regulation (EU) 2023/1115 of the European Parliament and of the Council, adopted on 31 May 2023 and published in the Official Journal of the European Union on 9 June 2023. It entered into force on 29 June 2023, twenty days after publication. The original compliance dates — 30 December 2024 for large operators and 30 June 2025 for SMEs — were the dates set in the text of the regulation.

In October 2024, the European Commission proposed a 12-month postponement to address the readiness of the EU Information System, the available benchmark countries, and the supply-side documentation infrastructure. The European Parliament and Council adopted the postponement in late 2024, which moved the first operational dates to 30 December 2025 for large operators and traders, and 30 June 2026 for small and medium-sized operators. The postponement is a one-year shift, not a removal; the regulation’s substantive obligations — due diligence, geolocation, risk assessment, risk mitigation — are unchanged.

The 2025 window is the year in which every Chinese paper exporter with an EU customer is expected to have the documentation system in place, the supply chain mapped to the country of harvest, and the shipment-level data exchange ready to support the EU importer’s due diligence statement. Exporters who arrive at the December 2025 deadline without the documentation system in place are not compliant, and the EU customer cannot lawfully import the product.

Which products are in scope

The regulation’s Annex I lists seven commodity categories: cattle, cocoa, coffee, oil palm (including palm oil and palm kernel oil), rubber, soya, and wood. Each commodity has an associated CN code list (combined nomenclature) that determines which specific products fall inside the regulation. Wood is the most relevant category for a Chinese paper exporter, and within wood the relevant CN codes cover wood in the rough, wood worked, wood charcoal, wood pulp, and a set of paper products that the Commission has identified as wood-derived.

The Commission’s published Commodity Guidance, released in 2024 and updated through 2025, is the most authoritative current reference for which specific paper products are inside the perimeter. The guidance distinguishes between products that are unambiguously wood-derived (such as virgin-wood-pulp printing paper, tissue paper, and folding box board made from virgin wood pulp) and products whose classification depends on the fibre source (such as recycled paper, where the original fibre source is not in the chain of custody for the recycled product). For a Chinese exporter, the practical question is: does the specific product being shipped contain wood fibre that originated in a harvested forest plot, and is the chain of custody back to that plot documented. Where the answer is yes — and the Bincheng tissue parent roll program using 100% virgin wood pulp is a clear yes — the product is inside the perimeter.

The Commission has not closed the perimeter definitively; guidance has been updated through 2024 and 2025, and the final classification of borderline products (such as paper products with mixed virgin and recycled content) is established through Commission implementing decisions and the EU Customs Code. A Chinese exporter should treat the current Commission’s commodity guidance as the working perimeter and monitor updates. Background context on the international forest governance framework that preceded EUDR is available through the European Forest Institute policy resources, and country-level forest-risk benchmarks are published by the Global Forest Watch country dashboards and the World Bank Forest Data.

The due diligence statement and what it requires

The due diligence statement is the core operational document of EUDR. It is filed in the EU Information System by the EU operator or trader — the importer, in the case of an import from a non-EU country like China — before the product is placed on the EU market or exported. The statement is a structured dataset with three required sections.

The first section is product information: the commodity, the CN code, the product description, the quantity, the supplier, the country of production, and the country of harvest. For a Chinese paper exporter, the country of production is China; the country of harvest is the country from which the wood fibre originated, which may be a different country if the pulp was imported from another jurisdiction before being processed in China.

The second section is geolocation data: polygon coordinates (or a single centroid point with a tolerance) for every plot of land that produced the wood in the product. The geolocation must be precise enough to confirm that the plot is not in a country or area classified as high-risk under the Commission’s country benchmarking. The Commission has published country benchmarking for the major wood-producing jurisdictions, and the data is available through the EU Information System.

The third section is the risk assessment and, where the assessment is non-negligible, the risk mitigation measures taken by the operator. The risk assessment is a documented analysis of whether the product complies with the relevant legislation of the country of production, whether the wood was harvested in a way that is consistent with the sustainability criteria, and whether the supply chain is verifiable back to the plot of land.

The due diligence statement is a binding legal document. Misstatements expose the operator to administrative penalties, and in serious cases to criminal liability in some member states. The EU importer carries the legal obligation to file the statement, but the practical data collection is shared with the non-EU supplier, because the EU importer cannot produce a compliant statement without accurate, plot-level data from the supplier.

Geolocation data — the hardest piece

Geolocation is the operational bottleneck for most wood-product supply chains. The regulation requires every plot of land that produced the wood in the product to be identified with polygon coordinates or a centroid point, and the geolocation must extend back through every intermediate party in the supply chain to the country of harvest. For a Chinese paper mill that sources virgin wood pulp from a pulp manufacturer in another country, the geolocation chain runs from the mill’s pulp input back through the pulp manufacturer’s wood input to the forest management unit that harvested the wood.

The Commission’s position on geolocation precision has hardened through 2024 and 2025. The benchmark is a polygon map of the plot, with a 4-hectare tolerance for low-risk countries and tighter tolerance for high-risk countries. A single point coordinate is acceptable where the plot is small enough to be represented by a point, and the geolocation can be aggregated at the country level for very small producers under specific conditions. The Commission’s published geolocation guidance, released in 2024, is the reference.

For a Chinese paper mill, the practical path to geolocation compliance is to source from a pulp supplier that operates a chain-of-custody certification scheme recognised under the EUDR’s third-country recognition framework. The most widely recognised schemes are the Forest Stewardship Council (FSC) and the Programme for the Endorsement of Forest Certification (PEFC), both of which maintain plot-level geolocation data for certified forestry operations. A mill that sources FSC-certified or PEFC-certified virgin wood pulp can pass the geolocation chain back to the certified plot, which dramatically simplifies the EU importer’s due diligence work.

Risk assessment tiers, mitigation paths, and the penalty schedule

The risk assessment under EUDR is a three-tier system: low risk, standard risk, and high risk. The Commission’s country benchmarking assigns one of these three tiers to every country for every in-scope commodity. A low-risk country is one where the Commission has assessed the risk of deforestation as low; a high-risk country is one where the risk is high. Standard risk is the default. The list of countries and the risk classifications is published and updated by the Commission.

A high-risk classification triggers an enhanced due diligence obligation: the operator must carry out a more thorough risk assessment, must collect additional geolocation data, must consult with indigenous peoples and local communities where relevant, and must obtain independent third-party verification of the risk assessment. A low-risk classification simplifies the process to a baseline due diligence check. Standard risk sits in the middle.

If the risk assessment concludes that the product carries a non-negligible risk of being non-compliant, the operator must adopt risk mitigation measures before the product can be placed on the market. The Commission’s guidance lists the typical measures, and a Chinese exporter can be prepared to support all five. The first path is independent third-party verification, where the operator commissions an audit of the supply chain by an accredited body. The second path is enhanced supplier due diligence, where the operator requests additional documentation from the supplier beyond the baseline. The third path is supply chain mapping and segregation, where the operator maintains a separate chain of custody for compliant material and physically segregates the compliant fibre from non-compliant fibre at every stage of production. The fourth path is capacity building at the supplier level, where the operator invests in the supplier’s compliance capability. The fifth path is diversification of the supplier base, where the operator shifts sourcing away from the high-risk country toward low-risk or standard-risk countries.

The penalty schedule for EUDR is set by each member state in national implementing legislation, but the regulation’s upper bounds are binding. The maximum administrative fine is the higher of 4% of the operator’s total annual EU turnover or a member-state-set floor (typically several million euros). The minimum administrative fine is the higher of 1% of annual EU turnover or a member-state-set floor. The penalty framework also includes confiscation of the products, confiscation of the revenues from the products, and the possibility of temporary exclusion from EU public procurement. The practical enforcement risk for a Chinese paper exporter is mediated through the EU importer: if the EU customer stops ordering because the documentation is insufficient, the EU market is closed to the Chinese product until the documentation system is in place.

A five-step compliance program with five paper-product case studies

For a Chinese paper mill that is preparing for EUDR, the practical path is a five-step program that builds from the certification base to the shipment-level data exchange. The first step is the certification baseline: the mill holds an FSC or PEFC chain-of-custody certificate covering the SKUs that will be exported to the EU, and the certificate is current with the certification body’s website confirming the scope. The second step is the supplier documentation: the mill’s pulp and fibre suppliers hold their own FSC or PEFC chain-of-custody certificates, and the chain of custody from the forest management unit to the mill is documented. The third step is plot-level data access: the mill can, on demand, produce the geolocation data for the plots that produced the fibre in a specific lot through the FSC or PEFC database. The fourth step is a risk assessment template: the mill has a documented template that covers the country-of-harvest risk classification, the supplier’s compliance history, the chain-of-custody integrity, and the labour-rights screening. The fifth step is shipment-level data exchange: the mill delivers a per-shipment data package to the EU importer, in a format the EU importer can load into the EU Information System to file the due diligence statement.

The five-step program applies differently to the five product categories a Chinese paper mill might export to the EU. For virgin wood pulp tissue parent roll, the mill holds an FSC chain-of-custody certificate, sources FSC-certified pulp from a Chinese pulp manufacturer that holds its own FSC certificate, and retrieves plot-level geolocation data through the FSC database; the Bincheng household paper program operates this documentation path for the virgin-wood-pulp SKUs. For recycled tissue parent roll, the mill is in a different position because the recycled fibre has no original plot of harvest, and the Commission’s 2024 commodity guidance is that recycled products are typically outside the wood commodity scope, though the practical position is more nuanced and may change. For kraft paper jumbo roll for industrial packaging, the mill holds an FSC certificate, sources from a low-risk or standard-risk country, and has the geolocation data ready; the Bincheng industrial paper program operates this documentation path for the kraft and food-grade paper board SKUs. For food-grade paper board, the documentation package is dual-track — EUDR for the wood-fibre origin, and the EU food contact materials regulation (Framework Regulation 1935/2004) for the food-safety end use. For ivory board and art board for printing and packaging, the FSC certification and plot-level geolocation chain are the same as for kraft paper, and the product’s intended use does not change the EUDR obligation.

Sourcing a due-diligence-ready paper supplier

For an EU buyer, the question of which Chinese paper supplier to source from is increasingly a question of which supplier has the EUDR documentation system in place. A supplier that has the FSC or PEFC chain-of-custody certificate, the supplier documentation chain, the plot-level data access, the risk assessment template, and the shipment-level data exchange can be onboarded into the EU importer’s EU Information System workflow. A supplier that lacks any one of these five pieces cannot be onboarded, and the EU importer’s only option is to find a different supplier.

The Bincheng paper program operates the five-step documentation system described above for the household paper and industrial paper programs. The export sales team is the direct intake for the EU customer’s EUDR documentation question, and the team is structured to deliver the per-shipment data package to EU customers within the response window the EU Information System filing requires. The Bincheng about-us page and the factory-tour page document the production and certification base that supports the documentation program, and the Bincheng certificate page lists the certifications held across the household paper and industrial paper SKUs. The Contact Us channel is the direct intake for EU customers to begin the documentation dialogue.

About the Author

Liam — Export Sales Manager, Ningbo Bincheng Packaging Materials Co., Ltd.

Liam leads export sales at Bincheng Paper, a professional paper manufacturer with 20 years of industry experience. The company specializes in parent rolls and jumbo rolls, serving the household tissue, industrial paper board, and cultural paper markets. The product range includes tissue parent rolls, ivory board, art board, duplex board, food-grade paper board, kraft paper, and copy paper. With reliable supply capacity and competitive pricing, Bincheng helps global paper traders and converters source quality paper products from China.