EUDR: Looking Back, Looking Forward
The week of December 15, governing bodies for the European Union voted multiple times to ratify a set of proposed changes to the European Union Deforestation Regulation (EUDR), a set of requirements first proposed more than three years earlier. The changes delayed implementation another year. The changes also remove printed books from reporting requirements, although other aspects of the paper and printing industries are still subject to the law.
The book industry reacted largely with a sense of relief. Although the regulations were adopted in 2023, with a mechanism to convey sourcing information for paper added to ONIX in mid-2024, many companies were not prepared to meet the requirements by the end of 2025. The collective reaction, akin to "Christmas comes early," included the regular refrain that book publishing is a unique industry that regulators struggle to understand.
Looking back, several things about the response to EUDR are encouraging for the book business. EDItEUR reviewed the law upon its release, found ways to modify ONIX to meet the law's requirements, and implemented those changes months ahead of the initial deadline, which was the end of 2024. When requirements were updated, EDItEUR again updated ONIX, providing publishers and metadata recipients with the tools needed to respond to the regulations.
This fall, when there was a push to "simplify" EUDR, EDItEUR was an early and vocal advocate for careful consideration of the impact on book publishing. A draft recommendation to eliminate the ability to nest due diligence statements (DDS) would have significantly impaired the ability of book publishers to report sourcing information. With EDItEUR's help and direction, organizations like BookNet Canada, U.K.-based BIC, and BISG were able to work with their counterparts to amplify our concerns about the proposed changes.
Outreach on EUDR fostered a stronger engagement with industry associations like the AAP, BMI, and AUPresses. Until the middle of 2024, EUDR was a "below-the-radar" issue, with supply-chain organizations aware of it and working to address its implications. As the initial deadline approached, that small circle had to expand, and other associations played an important role in spreading the word.
Although the book industry no longer needs to meet EUDR requirements, there may be some lessons we have yet to learn. The first is response time. The regulations imposed reporting burdens on paper mills, printers, publishers, and importers who might also be distributors in the E.U. Although there are exceptions, many companies operating across these segments were indifferent to the requirements even in the second half of 2024, when the initial implementation deadline was months away.
The second is the the need to focus on what can be controlled. After the deadline was moved back a year, too much of the industry's energy went toward arguing that the regulations should not apply to book publishing. While industry advocacy is a natural part of law-making, much of the discussion in 2025 focused on overturning the regulations, which at their heart make a case for understanding the sources and uses of materials in the industry. This time, advocacy worked. Had it not, the deadline would have arrived with much of the industry unprepared to meet the requirements.
As a marketing tool alone, clearly stating that "all fiber used in book publishing is sourced in a way that protects forests around the world" is a good thing. We need data to show that the book publishing supply chain operates in a way that protects and serves the planet. The industry may see the EUDR exception for books as necessary, but what are we doing as an industry to demonstrate our commitment to sustainability?
Answering this question may be the final lesson we have yet to learn. EDItEUR's executive director, Graham Bell, has made the argument that book publishing's market position depends in part of a network of exceptions. Copyright, reduced or zero tax status, exemptions from tariffs, and this most recent exemption from EUDR requirements are all examples. It's useful to look at these exceptions as ones that we don't control. They are given to us. At some point, they can also be taken back.
Every industry makes the argument that it is special in some way. Book publishing certainly has the right and duty to make the best arguments we can for protected status when it comes to the rules of the road. At the same time, market and consumer expectations for a demonstrated commitment to sustainability will likely grow in the years to come. With the concerns about EUDR now in the rearview mirror, what are we prepared to do to show that commitment?