– The EU wants to combat deforestation and forest degradation, and the document that defines its approach to this challenge is the EU Forest Strategy, which is part of the European Green Deal. It emphasizes the protection of primary and old-growth forests in EU countries. At the same time, it promotes forest management practices that are most friendly to the climate and biodiversity. One of the EU's actions for the protection of forests is also the EUDR, or the EU Regulation against Deforestation – Michał Kotarski, Market Development and Communication Manager at the Forest Stewardship Council (FSC), tells the Newseria Biznes agency.
The whole world will feel the EUDR regulation
The new regulation came into force at the end of June 2023. In Poland and other EU member states, it will come into force on 30 December this year for large companies, while small and medium-sized enterprises will have until 30 June 2025 to adapt to the new regulations. However, the consequences of the introduction of the EUDR will be felt worldwide.
The regulation prohibits the introduction or export of seven product groups from the EU market that do not meet legality and sustainability requirements. In practice, this means that companies will be required to exercise due diligence to ensure that the products they source – such as palm oil, soy, cocoa, coffee, cattle and rubber, and above all timber and products containing timber, such as board, plywood, cardboard, waste paper and paper – are legal and not linked to areas that have been deforested or degraded (after 31 December 2020). If a company produces or trades such products, it will be required to provide evidence that its supply chain complies with EUDR requirements.
– According to government estimates in Poland, this regulation may cover up to 120,000 companies, which will have to, among other things, indicate the exact geographical coordinates of the plot of land from which the product comes, and also demonstrate that it was manufactured in accordance with the law of the country of origin. Additional obligations also include due diligence, including in the context of assessing and mitigating the risk associated with deforestation – says the expert.
Paper processing mainly uses recycling
As he points out, the paper and cardboard processing industry uses mainly recycled raw material. He cites data from the European Federation of Corrugated Board Manufacturers, according to which over 80 percent of paper and cardboard packaging in Europe is recycled, and their production process is in principle consistent with the principles of the circular economy.
– Forest management certification helps protect forests and people associated with them – emphasizes Michał Kotarski. – Thanks to certification, the forest manager gains confirmation from an independent third party that they are obtaining wood with respect for the environment, as well as workers' rights and the rights of the local community. It also increases the transparency of forest practices, because FSC audit reports are publicly available, and anyone can participate in such an audit. Thanks to this, we, the consumers, when buying an FSC certified product, can be sure that we are contributing to the protection of forests and people associated with them.
The paper industry's long preparations for EUDR
The Forest Stewardship Council points out that while certification schemes can help to meet the new requirements of the EUDR, they do not automatically exempt companies from their obligations under it.
– We started preparing to implement the EUDR strategy over two years ago, when a working group dedicated to topics related to deforestation was established within DS Smith – emphasises Michał Zawistowski.
Within this framework, it is essential for our company and corrugated board manufacturers to source 100% recycled paper or paper from certified sources. At the same time, we ensure that DS Smith's forests are 100% sustainable and that all packaging products are FSC certified.
The Polish feed industry has a problem
In turn, the issue of importing soy or soybean meal remains important for the Polish agricultural sector. As we have written before, it is not entirely clear who is to administratively collect and verify data on the origin of imported raw materials. Additionally, collecting geolocation data from many entities may be difficult in practice, and sometimes impossible to do, with many suppliers of raw materials. On the other hand, failure to meet the requirements may result in severe penalties, which are to amount to at least 4% of annual turnover, which in practice is the annual profit for such companies.
Read more
EUDR regulation will shake up the soybean and soybean meal market 
Read more
If nothing changes, soybean meal prices will increase from 2025. All because of deforestation
We are not ready for the EUDR regulation
Therefore, both the industry and the agricultural self-government point out that Poland is unprepared to implement the EUDR regulation.
As Dr. Przemysław Tronina, country representative of USSEC, explained to us earlier – The level of preparation for the implementation of new requirements in both the EU and Polish administration is low and multi-threaded.
– On the one hand, the government is working on actually appointing an appropriate body in Poland that will supervise the implementation of the requirements of this regulation. On the other hand, the European Commission should provide a special IT system in which this information will be entered for products imported to the European Union. This data will be collected and it will be checked whether a given raw material actually came from areas affected by deforestation or not – says the expert. For now, there is no such system.
