What steps is VPK taking to comply with the EU Deforestation Regulation (EUDR)?
The paper that VPK produces is fully recycled and therefore does not need to comply with EUDR regulations. A smaller part of the consumed paper in the packaging divisions is virgin fibre based and needs to comply to EUDR regulations.
According to current information, the required changes at VPK Group mainly apply to information requirements in the supply chain and connectivity with the EU Information System (TRACES). TRACES is the digital repository that the European Commission is developing for the required due diligence statements (DDS).
To meet the European Commission’s requirements, VPK decided to work with the software Osapiens which will be the link between our ERP system (SAP) and TRACES. Initially to be implemented by the end of 2024, the European Commission decided to postpone the implementation of it to end 2025, with reviewed rules. In September 2025, the European Corrugated Association got the information the EU Commissioner wants to postpone (again) the implementation date and would suggest December 2026 to be the new deadline. At the same time, received feedback indicates conditions might be reviewed as well. In October 2025, new information has been communicated indicating strong simplification of the requirements with a grace period as from 01/01/2026.
November 26th 2025 the EU Parliament voted to postpone and simplify the EUDR requirements as follows:
- Traceability of reference numbers limited to first downstream operator. This means that the first operator has to submit a DDS and pass the reference number to the first downstream operator. After that (e.g. 2nd, 3rd downstream operators) there is no obligation to pass down reference numbers, but only to keep record of suppliers’ and client’s name and address for 5 years. Also, the exporter does not have to communicate reference numbers to customs. Nothing changes for imports from non-EU countries. VPK is a large downstream operator: this means that VPK needs to continue to do a risk assessment of its suppliers but does not need to follow-up on DDS statements nor communicate these to customers. During the implementation of EUDR compliance, VPK is committed to exclusively source materials through verified CoC certified supply chains. For the production of our paper, corrugated boxes and sheets, we only accept materials that are 100% FSC-certified. Furthermore, all our paper mills are FSC-certified[1] and utilize recycled CoC certified fibres. More information can be found in our EUDR statement you can find on our website.
- Review clause: by 30 April 2026, the Commission shall carry out a simplification review of the Regulation and on this basis present a report to the European Parliament and the Council accompanied, where appropriate, by a legislative proposal (AM 62 ECR, AM 123 EPP). This means that the exact requirements can still change by April 30th, 2026.
- Postponement: entry into application is 30 December 2026 for medium and big companies (AM 63 ECR, 128 EPP) and 30 June 2027 for small and micro companies, excluding companies subject to EUTR (AM 64 ECR, AM 129 EPP). EUTR is repealed from December 2026. VPK is considered as a big company, hence the rescheduled implementation for VPK is December 30th 2026.
Why did VPK to decide to proceed so?
- Between the initial timeline of December 2024 postponed to December 2025, the EU reviewed a high number of conditions of what is in the scope and what is out of TRACES’ scope. According to the latest information, there is a high probability the scope might be reviewed all over again. As long as the scope is not clear, VPK cannot indicate its supplier what direction to go.
- The reason given by the EU Commissioner to potentially review scope & timeline, has to be explained by the technical issues with the TRACES system.
Hence, VPK fully endorses and commits complying with the EU Deforestation Regulation. Meanwhile, the EU has disclosed the list for countries of origin risk assessment. Based on that assessment, VPK can confirm that all sourcing of virgin fibre based paper has as only origin low risk countries and within the European Union. Consequently, no satellite images need to be provided.
