The EUDR and Sustainability Metadata

What is the EUDR?

The European Union's Deforestation Regulations aim to tackle deforestation, forest degradation and loss of biodiversity by mandating 'deforestation-free' products.

They were passed into law in June 2024, and the deadline for compliance is the end of December 2024. The European Commission has proposed to extend this deadline to 30th December 2025. Whilst the European Parliament has agreed to this delay, and it is likely that this will become effective, it has not yet been publishing in the Official Journal of the EU (https://ec.europa.eu/commission/presscorner/detail/en/ip_24_5009).

After that date, all products sold in the EU market (EEA + Northern Ireland) must be able to show that they do not originate from recently-deforested or degraded land. This also applies to any product sourced in the EU. If this cannot be done, then these products must be excluded from the EU market.

For SME's, there is some leeway until 30th June 2025. This applies if you meet any of the following conditions:

• < €4m on the balance sheet
• < €8m turnover
• < 50 staff

Operators must collect and retain data that allows for the provenance of a product's raw materials to be traced to a specific plot of land. It is the responsibility of everyone in the supply chain to ensure that this data is available, and communicated. Even if you are a trader, rather than an operator, you must be able to refer back to DDS' prepared by operators. In most cases, publishers count as operators.

Editeur have put together a useful video that provides more depth on this topic, which you can find using the following link:

https://www.editeur.org/files/videos/20240903%20EUDR%20Lunch%20and%20Learn%20720p.html 

What information do publishers need to include in their Metadata?

There are two key pieces of information that publishers must now include in their metadata, in order to comply with the EUDR.

EUDR Due Diligence Reference

The EUDR Due Diligence Reference (DDR) is a series of numbers and letters which refers to a Due Diligence Statement that has been generated in order to prove compliance with the EUDR. For more information on these statements and how to generate them, please visit the following link:

https://green-business.ec.europa.eu/deforestation-regulation-implementation/deforestation-due-diligence-registry_en

Please note that registration to use the system will begin in November 2024 and the system will be opened to all users in December 2024.

It may be either your organisation, or an organisation further up the supply chain that is required to produce the DDR. Either way, you must provide this data. Everybody in the supply chain is legally responsible for ensuring compliance with the EUDR, and providing the data that proves this compliance.

EUDR Raw Material Location

The second piece of information required is the GPS coordinates detailing where the trees used to produce the product come from.

Here, you can enter the GPS coordinates for the binding, the interior or full product, or 'other', where these component parts derive from different sources. This information should be made available to you by your printer or paper mill. This information can contain 1, 2 or 3 sets of GPS coordinates:

• ONE point defines the centre of a 4 hectare plot (200m × 200m)
• TWO points define a line joining opposite corners of a ‘square’ plot bounded by two lines of latitude and two of longitude
• THREE or more points define a simple polygon outlining the plot

You must also provide the country code (see List 91) of the country from which the trees originate, as well as an optional date of harvest. We have provided more detail on how to present this information, and where later on...

Inputting this data into Stison

N.B: Please note that you can only send this data using Onix 3.0 or later. If you wish to send this data to a destination that is currently set to receive Onix 2.1, you will not be able to do so.

In Title Management, you can now include the EUDR due diligence reference, and EUDR raw material location, as a Product Form Feature.

Please note that this will have to be entered for each product form.

Under Further Product Details --> Product Form Feature, you can now select the following EUDR data fields:

When inputting the EUDR due diligence reference, you will only need to input a value, and can leave the description blank.

When inputting the EUDR raw material location data, you will need to fill in both the value and the description.

The Value will be a country code from List 91, indicating the country from which the materials came, followed by a space and a date of harvest (YYYY, YYYYMM or YYYYMMDD).

The Description is a list of points defining the plot from which the raw material was harvested, using GPS coordinates with 6 decimal places of precision. Latitude and Longitude for each point are space-separated, and multiple points are comma-separated. ONE point defines the centre of a 4 hectare plot (200m × 200m). TWO points define a line joining opposite corners of a ‘square’ plot bounded by two lines of latitude and two of longitude. THREE or more points define a simple polygon outlining the plot. In cases where your coordinates draw a polygon, please remember to repeat the first coordinate at the end in order to 'close' the polygon.

In the example below, we have provided one coordinate, detailing the centre of a 4 hectare plot, as well as an EUDR due diligence reference.

Subsequent Print Runs

It likely that you will have more than one print run for a product form across a titles lifespan. The GPS coordinates for the raw materials will also likely be different between these print runs. Please ADD this data to the existing GPS coordinates held against a product form, rather than replacing the existing data. To do so, simply separate the coordinates using a semi-colon.

Including this data at the Production stage

We have created space to include this information at the Print Run level, to better reflect the stage at which you may generate some of this data. In the Print Runs tab, you can now see the following fields:

As you enter this information in Production, it will automatically link to the Further Product Details tab, and create the relevant Product Form Feature information. The information that you enter here is the same as described above, but split up into its component parts.

If you update the information entered in the Print Runs tab in Production, this will update the information stored in Title Manager. If you remove the Product Form Features from Title Manager, this will not delete the data from the Print Run. If you wish to re-copy the data (eg if you delete it in Title Manager by accident), simply re-enter the same data in the Print Run, and it will copy across again.

In the example below, we have entered a set of data in the Print Runs tab:

This information has then copied across to the Product Form Feature fields in Title Manager:

N.B: We have introduced all of the features that we understand to be necessary to comply with the EUDR, but as this is a new set of regulations that has not yet come into effect, there may well be further developments. If you feel that there are further adjustments that need to be made, please do contact [e-mail].