Yes – you need Track & Trace (Due Diligence) for paper under the EUDR, but only for certain types of paper and under specific conditions.

The EU Deforestation Regulation (EUDR) applies to products listed in Annex I, including several categories of wood and paper-based products. These include:

• Raw paper and paperboard (CN code 4801, 4802, etc.)

• Toilet paper, packaging paper, graphic paper, and some coated papers

• Carton boxes and some processed forms of paper may also be in scope

When do you need Track & Trace (DDS)?

You must comply with EUDR if all of the following apply:

1. The paper is made from virgin wood-based material (not 100% recycled).

2. You are placing it on the EU market (as an operator or first placer).

3. The CN code of the paper is listed in Annex I of the EUDR.

4.  It is placed after 30 December 2024 (EUDR enforcement date).

Then you must:

•  Collect geolocation data of the land where the wood was harvested.

• Perform risk assessment and mitigation.

•  Submit a Due Diligence Statement (DDS) to the EU Information System.

You do NOT need Track & Trace for paper if:

• It is made from 100% recycled material (clearly documented – Article 1(3)).

• It falls outside the scope of Annex I (e.g. processed paper products not listed).

• You are not the operator (you only handle, use or consume the product after it was placed on the EU market).

• It was placed before the cut-off date (30 Dec 2024).

Recommendation for the process in the company:

• Check the CN code of your paper products.

• Ask your supplier for DDS or upstream geolocation data (if they are in scope).

• Integrate with systems like the osapiens HUB, SAP, or custom tools to automate the DDS process.

• For complex value chains (e.g. impregnated paper, coated board), ensure traceability back to the forest origin of the wood pulp.

Conclusion:

Yes – if your paper is made from virgin wood, falls under an EUDR-relevant CN code, and is placed on the EU market, you need full Track & Trace (DDS) under the EUDR.