EUDR for timber, pulp and paper: sector-specific due diligence

How EUDR impacts timber importers, pulp processors and paper manufacturers. FLEGT, certification and plot-level traceability combined.

Pillar context

Timber, pulp and paper form the most complex EUDR category. Traceability must pass through multiple processing steps back to the original plot — and that is where the chain usually breaks.

What falls under EUDR for this sector?

• HS chapter 44 — wood, wood products, wooden furniture (partial)
• HS chapter 47 — pulp (chemical and mechanical)
• HS chapter 48 — paper and paperboard
• HS chapter 94 — wooden furniture (partial)

Recycled content is exempt but must be documented per batch.

FLEGT licences: still valid?

Yes — FLEGT (Forest Law Enforcement, Governance and Trade) licences from countries like Indonesia remain legally valid and are recognised by EUDR as proof that timber was legally harvested. But FLEGT does not cover the deforestation angle. You still need plot-level geolocation to prove the plot was not deforested after 31-12-2020.

The pulp traceability chain

A typical pulp supply chain:

1. Plantation / forest — plot coordinates, harvest date
2. Sawmill or chipper — batch log per supplier
3. Pulp mill — batch mixing (traceability usually breaks here)
4. Paper mill — recipe with % virgin pulp vs recycled
5. Importer — DDS submission at EU import

Step 3 is the critical one: if the pulp mill mixes batches without traceability, the whole chain is broken for EUDR.

Practical steps for importers

1. Contract update: explicitly require plot coordinates per shipment
2. Batch discipline: pulp suppliers must offer first-in-first-out or batch segregation
3. Third-party certification: FSC and PEFC are not sufficient for EUDR but help with risk assessment
4. Supplier pilot: start with your top-three timber suppliers

Overlap with origin evidence

Timber chapter 44 often falls under preferential FTA rules. The LTSD you already use for preferential origin contains:

• Supplier identity
• Country of origin (not plot — this is the gap)
• Wood species and grade

The only real EUDR addition: plot geolocation. All other documents can be reused.

What PSRA automates

PSRA's LTSD module has an optional geolocation field. Once suppliers provide it (JSON/CSV import), it links automatically to the corresponding BOM line and becomes available for EUDR DDS generation.

Related articles

• Audit-proof operations: 7 principles for compliance officers: Learn the seven fundamental principles that make your compliance organisation audit-proof, from documentation standards to automated controls.
• Compliance as competitive advantage: how leaders win: Discover how forward-thinking companies deploy compliance as a strategic weapon rather than a cost centre.
• From customs penalty to compliance advantage: a case study: How a mid-size importer turned a six-figure customs penalty into a structural compliance advantage through automated origin determination.

Related downloads

• Whitepaper: 30-minute demo to trial: 14-day plan from demo to trial outcomes for origin, LTSD, and CBAM workflows.
• Comparison: Excel workflows vs PSRA: Finance-oriented ROI framing and migration checklist for operations teams.
• Case study template for compliance outcomes: Reusable structure to document measurable compliance impact, audit outcomes, and workflow improvements.

Related definitions

• Audit trail: An audit trail records who did what, based on which source data, and with what decision logic.
• BOM: A BOM is the bill of materials: the structured composition of a product.
• Supplier declaration: A supplier declaration captures the origin information a supplier provides for supplied goods.
• Customs declaration: A customs declaration is the formal notification to customs declaring goods for import, export, or transit, available in five procedure types.