EU Deforestation Regulation (EUDR) introduces new requirements for the trade of wood and wood-based products. Read on to learn more about the implementation of EUDR at UPM Plywood.
EUDR at UPM Plywood
What is EUDR?
The EU Regulation on Deforestation-free Products (EUDR) is the EU’s latest initiative to combat deforestation and forest degradation worldwide. Effective from 29 June 2023, it replaces the EU Timber Regulation (EUTR) and expands due diligence requirements to a wider range of commodities, including wood (Regulation (EU) 2023/1115).
EUDR update: Key Changes and impact on UPM Plywood
On December 19, 2025, the EU approved amendments to the European Deforestation Regulation (EUDR) (Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115). These changes affect compliance timelines and obligations for operators and traders across the supply chain.
New application date:
The EURD application for medium and large companies is postponed by 12 months. The new date is December 30, 2026.
New category - Downstream operator:
The obligation to submit and communicate due diligence statements and reference numbers is limited to the first downstream operator
- The first operator submitting a due diligence statement must pass the reference number to the first downstream operator
- The first downstream operator has no obligation to pass reference numbers further down the supply chain
Simplification Review:
The European Comission will review the regulation for simplification by April 30, 2026.
Impact on UPM Plywood:
- UPM Plywood will stop sending EUDR reference and verification numbers as invoice attachements.
- We will continue to ensure compliance with all EUDR requirements and keep customers informed of any further changes
Deforestation and Forest Degradation-Free
Compliance with Country Legislation
Due Diligence Statement
UPM Plywood’s commitment to EUDR
UPM Plywood is aware of the obligations set in the EUDR. During the transition period, we are taking necessary measures to ensure compliance when the regulation enters into application in December 2026.
Before placing its products on the market, UPM Plywood will submit a due diligence statement (DDS) to the EU Information System, Traces. The system will generate a reference number, which UPM Plywood will provide to its customers.
Implementation of the EU Regulation on Deforestation-free Products at UPM Plywood
Frequently asked questions on EUDR
The information in this section reflects UPM Plywood’s interpretation of publicly available information on the EUDR from EU sources. Please note that UPM Plywood does not provide advice on EUDR compliance. We recommend seeking guidance from the EU or a third party to determine regulation impact on your own business activities. For further information on EUDR, please visit the EU Commission's official website.
This section will be updated as new information becomes available (current update: 26.1.2026).
Regulation (EU) 2023/1115 on deforestation-free products (EUDR) aims to prevent products entering or leaving the EU market from contributing to global deforestation or forest degradation. The regulation also seeks to reduce greenhouse gas emissions and biodiversity loss caused by EU consumption and production.
The regulation is applicable to products listed in its annex, including those that contain, have been fed with or have been made using cattle, cocoa, coffee, oil palm, rubber, soya and wood. For UPM, wood is the most relevant commodity, and many UPM products such as timber, pulp, paper, plywood, and paper-based labels fall within the scope of the EUDR.
The regulation requires companies to exercise due diligence before placing or making relevant products available on the EU market or exporting them and, prohibits placing or making available on the market or exporting relevant products unless they are
- deforestation-free,
- have been produced in accordance with the relevant legislation of the country of production of the commodity in question,
- and are covered by a due diligence statement whereby the companies assume responsibility of the compliance of their products.
In addition, the regulation requires traceability of the commodities falling in the scope of the regulation. The due diligence statement (DDS) must contain information about the country of production and geolocation of all the plots of land where the commodity contained in the product associated to the due diligence statement was produced.
The regulation entered into force on 29 June 2023 and, will be fully applicable from 30 December 2026.
UPM Plywood is following closely the simplification review work done in EU comission and modifying processes accordingly.
UPM Plywood is a Downstream operator under EUDR.
UPM Plywood is a Downstream operator. In cases where we act as the first downstream operator, we have an obligation to store the reference numbers received, but no obligation to pass them down to the supply chain.
In cases where we act as a second or third downstream operator, we do not have any obligations.
As UPM Plywood is acting as a Downstream operator, we are not passing any information for our customers.
When sourcing raw materials covered by EUDR, UPM Plywood expects that the raw materials supplied are compliant with the regulation.
When sourcing raw materials from the EU market, UPM Plywood will only accept goods that have been subject to a due diligence statement and will verify that due diligence is exercised by its suppliers.
When sourcing raw materials from outside of the EU, UPM Plywood will require its suppliers to provide all the data needed to exercise due diligence, including information about tree species, country of production, geolocation of plots of land where the raw material was harvested, harvesting time, as well as adequately conclusive and verifiable information that the raw materials are deforestation-free and produced in accordance with the relevant legislation of the country of production.
The entry into application for large and medium enterprise operators and traders is on December 30, 2026. This means that operators and traders do not have to comply with the requirements for products placed on the Union market before that date. See more information on this EU website on timelines.
Please get in touch with your company’s sales representative.