Handling raw materials and processing steps - EUDR obligations using the example of paper products & disposable aprons

Executive Summary

The EUDR not only affects traditional commodity traders, but increasingly also companies in the paper and healthcare industry that place paper products and disposable items such as disposable aprons on the market. The key question is to what extent these products will remain subject to reporting under the EUDR - an issue that is particularly relevant for compliance and supply chain management.

The EUDR lists seven primary raw materials (including wood) and products made from them as relevant for the reporting obligation. The decisive factor here is the tariff classification according to the Combined Nomenclature (CN). For paper products, the CN headings of chapters 47 (pulp), 48 (paper and paperboard) and 4818 (hygiene articles, e.g. disposable aprons) are particularly relevant. Paper-based products, including disposable medical aprons, fall under the EUDR if they are assigned to these product groups.

The EUDR follows the raw material trail from timber harvesting to the end product. Processing steps - such as the production of pulp, paper and further processing into disposable aprons - do not automatically lead to the elimination of the obligation to declare. The customs CN heading of the end product is decisive. Even in the case of complex hybrid products, the EUDR relevance remains as long as the product is assigned to one of the listed product groups. This applies regardless of the number and type of processing steps. Exceptions only exist if it can be proven that the product no longer falls under an EUDR-relevant CN heading.

Current FAQ documents from the EU Commission emphasize that it is not technical processing steps, but exclusively the CN position that determines the EUDR reporting obligation. Companies must therefore carry out an EUDR due diligence process for all paper-based products and disposable items such as disposable aprons, ensure complete documentation of the supply chain and prove that the wood used is legal and deforestation-free. Traceability back to the parcel of origin is mandatory.

Recommendations for companies

• Relevance check: Companies should systematically check for each product whether it falls under an EUDR-relevant CN heading, regardless of the degree of processing.
• Internal cooperation: Technical, legal and logistics departments must cooperate closely to ensure compliance with the EUDR. Training and standardized testing processes are recommended.
• Documentation: The EUDR requires comprehensive documentation and reporting obligations, including proof of the origin, composition and sustainable management of raw materials. Digital solutions for supply chain documentation make sense.
• Customs tariff information: In case of uncertainty, it is advisable to obtain binding customs tariff information to confirm the correct CN position and minimize compliance risks.

EUDR compliance along the entire supply chain remains a key issue for companies in the paper and healthcare industry. The reporting obligation does not cease to apply as a result of technical processing, but remains in place until the product is clearly classified according to CN heading. Proactive management of product classification, documentation and internal processes is essential in order to avoid regulatory risks and fines. The dynamic development of the EUDR makes it necessary to continuously maintain knowledge and use official guidelines and industry standards in order to implement the requirements in a legally compliant and efficient manner.

EUDR and raw materials: What counts as a relevant raw material?

Overview of the raw materials listed in the Deforestation Ordinance

The EUDR (EU Deforestation Regulation, Regulation (EU) 2023/1115) explicitly links its obligations to certain raw materials and products made from them. It requires that only deforestation-free products enter the European market. Annex I of the regulation lists seven primary raw materials: Beef, cocoa, coffee, palm oil, soy, rubber and wood. All products obtained from these raw materials, whether new or imported, are potentially subject to the EUDR obligations - provided they are listed under the corresponding CN heading. Wood in particular is a central focus here, as an enormous range of end products are made from it.

Wood as the basis for paper products

Wood is at the heart of most paper-based supply chains and the packaging industry. The industrial manufacture of modern paper products is predominantly based on the processing of pulp, which in turn is obtained from wood. According to a report by DIE PAPIERINDUSTRIE e.V., around 23 million tons of paper, cardboard and paperboard were produced in Germany in 2021. A significant proportion of this was based on virgin fiber wood, supplemented by waste paper as a secondary raw material. The output stage covered by the Deforestation Ordinance concerns both raw wood and further processed semi-finished materials such as pulp (CN 4703), paper and cardboard (CN 4801-4823) and special materials for disposable medical products (HS code 48189010). The delimitation and continued EUDR reporting obligation is particularly relevant for these further processing stages.

Latex gloves, absorbent pads and surgical material, for example, are also subject to EUDR. Latex gloves and absorbent pads are among the most frequently used products in the medical sector. As they are usually made of natural rubber or cellulose (wood), they are subject to the Deforestation Regulation. The same applies to some disposable products used in operating theaters. Companies that trade in, manufacture, import or export these products are highly likely to fall under the EUDR Regulation.

Role of CN headings for classification

How the product is coded in the customs tariff is central to the applicability of the EUDR. The Combined Nomenclature (CN) lists the relevant product groups and sub-groups with numerical codes. The regulation refers to these CN headings in order to create clarity in the classification of the reporting obligation. In contrast to the technical understanding of processing steps, the customs classification is therefore decisive. For paper products, the EUDR CN headings of chapters 47 (pulp), 48 (paper and paperboard) and in particular 4818 (including hygiene articles such as paper towels and toilet paper) are decisive. Depending on the material composition, disposable aprons can also fall under paper-based product groups covered by the EUDR.

Particularly in view of ongoing technical innovations and material specifications, tricky classification issues can arise in day-to-day business. The CN heading determines whether or not an EUDR due diligence procedure applies to a product and, accordingly, whether or not a reporting obligation under the Deforestation Regulation applies.

Processing steps: When does the EUDR relevance change?

Exemplary processing chain from wood to disposable aprons

If you look at the classic development of a tree through to a disposable apron in a clinic, the scope of the regulation quickly becomes clear: the chain begins with the harvesting of wood (e.g. from sustainable forestry) and continues through debarking, shredding and chemical processing to pulp. This is then turned into paper, which is further processed into rolls or sheets. In the production of disposable aprons, the paper is coated with polyethylene, cut to size and finished before it is used as a sterile end product in the medical environment.

Each of these processing steps changes the material structure, but this does not necessarily mean that the EUDR reporting obligations no longer apply. On the contrary: the EUDR keeps track of the originally imported raw material throughout the entire supply chain. For imported end products in particular, it requires companies to be able to provide complete documentation of their purchased primary products.

Does the product remain EUDR-relevant despite further processing?

A key uncertainty for many companies is whether and to what extent the EUDR requirements still apply to highly processed products. Let's take the disposable apron as an example: If it is predominantly made of paper, it generally falls under the relevant CN headings (e.g. 481890, "Sanitary and medical articles of paper or cellulose wadding"). This means that it remains EUDR-relevant - and is subject to the reporting obligation in terms of the EUDR due diligence process, regardless of how many processing steps the source material has already undergone.

Even hybrid products made of paper and plastic, for example, can be subject to the EUDR as long as the product labeling (tariff classification) indicates this. The technical content of the wood remains decisive as long as the product does not move into a product group that is not covered by the EUDR. For companies, this means In case of doubt, a thorough look at the CN table is no substitute for a technical gut feeling - and the difference between paper and plastic aprons can be essential from a compliance perspective.

Principle of the regulation: processing does not generally exempt from compliance with the reporting obligation

The main lesson to be learned from the EUDR system and the accompanying interpretations of the EU Commission is that the obligation to declare does not automatically cease as a result of processing or technical change of the originating raw material. Rather, every product remains EUDR-relevant as long as its CN heading is listed in the Annex to the EUDR. This also means that paper, pulp and paper products made from them, such as disposable aprons, disposable towels or packaging products, continue to be treated as subject to EUDR, regardless of complex processes and any finishing. Disposal or upcycling products are exceptional cases, for example if the wood content is no longer functionally verifiable or the goods description clearly no longer falls under an EUDR heading.

One point that is often overlooked is that not only importers and manufacturers, but also distributors of end products are obliged to comply with the EUDR reporting obligation. This underlines the depth and scope of the regulation, which goes far beyond previous due diligence obligations.

Obligations from the new FAQs - what has changed?

Key findings from the EU FAQs

With increasing uncertainty in practice, the European Commission published extensive FAQ documents on the EUDR in 2024 and early 2025. The clarification is particularly important for the paper sector: the technical processing steps or the degree of finishing are not decisive for the obligation to declare a product. Only the classification under the applicable CN heading at the time of import or placing on the market is decisive.

Many companies previously assumed that with sufficient processing and added value - for example in the production of coated disposable aprons - the responsibility for the raw material trace would end. It is now clear: as long as the end product corresponds to an "EUDR-KN item", the compliance and reporting obligation remains in place.

In practice, this means that it may be possible to make partial reference to due diligence declarations for the raw material. However, the due diligence obligations also apply to the further processing of raw materials.

CN position instead of technical processing as test standard

This clarification puts a stop to misleading practices in which companies rely on technical arguments such as chemical changes, structural loss of the wood or offcuts of recycled content. Ultimately, EUDR relevance is always and exclusively determined by the CN classification for customs purposes. For paper products, cellulose and all hygiene articles derived from them, it is therefore important to classify them precisely in the customs tariff system.

Traditionally, for example, pulp obtained from wood for the manufacture of disposable medical textiles is classified under CN 4818. Even if additional plastic layers are processed, the product remains EUDR-relevant as long as the main product content and the CN classification require this. Particularly in the case of complex composite products, a careful look at the applicable CN heading is essential. The classification can also differ from country to country, as the EU member states can request national advance rulings in the event of uncertainties regarding the classification of the products.

Effects on paper products and disposable aprons

What are the consequences of these FAQ clarifications for companies that import or process paper products or disposable aprons? The result is a de facto tightening of reporting obligations: Companies must also carry out a valid EUDR due diligence process for processed paper products and disposable items made from them, such as aprons, gloves or packaging. When supplying the source material, the legality and deforestation-free nature of the wood must be confirmed. Every processor must document the evidence along the entire value chain. In other words, traceability back to the plot of land must be guaranteed. Reliable internal processes are the only way to avoid fines and delivery stops.

Recommendations for companies

Perform relevance check also after processing steps

For companies that manufacture, trade or import products made from paper, pulp or other EUDR-relevant raw materials, a systematic relevance check is essential. Contrary to what many supply chain managers previously assumed, the due diligence obligation does not automatically end with further processing. The relevant question in terms of the EUDR is always: Under which CN heading does my (intermediate or end) product fall at the time of import or marketing within the EU?

For example, anyone who purchases and resells coated disposable aprons (e.g. made of paper and polyethylene, typically under CN 4818) remains subject to the reporting obligation even if the product has been given a "completely different face". Legally compliant processes therefore require complete documentation of the entire processing chain - and ideally digital proof of delivery that goes back to the origin of the wood or pulp.

In case of doubt, binding tariff information should be obtained to confirm the correct CN heading. Companies are well advised to check their technical data sheets, goods descriptions and delivery documents for EUDR conformity at an early stage.

Organize and implement collaboration internally

Technical, logistics and legal departments must work closely together - because the classification of the product, the import process and the documentation require cross-departmental cooperation. In addition to pure product development, the purchasing, sales, supply chain management and customs departments in particular should be involved in checking and managing EUDR-relevant obligations.

Training and awareness-raising measures for employees in the area of product classification and materials science are recommended in view of the complexity of the regulation. A standard process for the EUDR relevance check is particularly useful for new product launches to ensure timely internal coordination and avoid misunderstandings.

EUDR compliance: Observe documentation requirements for end products too

The EUDR stipulates a comprehensive documentation and reporting obligation, whereby proof of origin and care must be provided along the entire supply chain. This concerns both the product composition (including all paper or pulp qualities used) and, where applicable, information on the geographical origin of the wood and the sustainable management of the forest areas.

For paper products and disposable aprons, this may include certificates for FSC or PEFC-certified raw materials, supplier confirmations, log data on imports or customs documents. In the event of a dispute, companies must plausibly demonstrate that each processing step has been documented. Forward-looking and efficient management of obligations, for example through powerful software solutions, is therefore not a luxury but a necessity in order to avoid the threat of penalties and reputational risks.

Conclusion and outlook

In summary, it can be said that companies must ensure end-to-end EUDR compliance along the entire supply chain when manufacturing, trading and importing paper products. The reporting obligation does not cease to apply as a result of further technical processing, but remains relevant until the final "declassification" according to CN heading. For paper-based end products in particular, a look at the customs classification of goods and the individual product composition is crucial for the obligation situation.

Companies are well advised to make their product databases, product descriptions and distribution channels EUDR-compliant. A secure classification system not only avoids fines and controversies, but also helps to pragmatically implement dynamic requirements from legislation and customs practice. The importance of the EUDR reporting obligation will continue to increase in the coming years.

In addition to specialist resources, companies should regularly make use of aids such as official guidelines, industry standards (e.g. DEHSt leaflets), Chamber of Industry and Commerce training events or advice from experienced customs and sustainability consultants. The dynamic development of the EUDR - particularly on detailed issues relating to paper products and their CN headings - underlines the importance of proactive knowledge and process maintenance.