Raw materials and processing under the EUDR - what needs to be considered?

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 notification under the EUDR.

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 (sanitary articles) are particularly relevant.

The decisive factor is whether the respective intermediate or end product is classified as an Annex I 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.

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. Only those products that are covered by specific CN headings in Annex I and that are placed on the EU market or exported from the EU are relevant to EUDR. 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 (CN 4818 (incl. certain subheadings, depending on product specification)). The delimitation and continued obligation to declare EUDR is particularly relevant for these further processing operations.

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 very likely to fall under the EUDR Regulation. Here, too, the prerequisite applies that the products are covered by an Annex I CN heading, e.g. in the context of ex 4015 for gloves or 4818 for hygiene articles.

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.

Processing steps: When does the EUDR relevance change?

Exemplary processing chain from wood to disposable aprons

The chain begins with wood harvesting 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 decisive factor is whether the respective product falls under a CN/HS heading listed in Annex I.

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 the apron is predominantly made of paper and is classified under an Annex I heading for customs purposes, it remains EUDR-relevant and is subject to the reporting obligation regardless of how many processing steps the raw material has already undergone. In case of uncertainty, the specific CN classification should be verified by means of a customs tariff information.

Even hybrid products made of paper and plastic, for example, can be subject to the EUDR as long as the product labeling indicates this. The decisive factor is not the wood content, but the tariff classification and whether the specific product is included in Annex I.

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

The obligation to declare does not automatically cease to apply 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.

Downstream market participants and traders generally do not submit due diligence declarations, but must fulfill information and retention obligations. Non-SMEs must register in the information system and take action if there are justified concerns.

Obligations from the FAQs

Key findings from the EU FAQs

The European Commission published extensive FAQ documents on the EUDR in 2024 and early 2025. Of particular importance: The decisive factor for the obligation to declare a product is not the technical processing steps or the degree of processing, but whether the product is classified as an Annex I product at the time it is placed on the market, made available or exported.

Many companies previously assumed that, with sufficient processing and value creation, responsibility for the raw material trace would end. It is now clear: as long as the end product corresponds to an "EUDR-KN position", the compliance and reporting obligation remains in place. Conversely, if further processing results in a product that is not listed in Annex I, this new product is not EUDR-relevant, even if it contains a listed raw material.

CN position instead of technical processing as test standard

This clarification puts a stop to a misleading practice in which companies rely on technical arguments such as chemical changes, loss of structure of the wood or offcuts of recycled content. Ultimately, it is always and exclusively the technical CN classification that determines EUDR relevance. In the event of uncertainty, binding tariff information (BTI/BTI) creates legal certainty. It is generally valid throughout the EU.

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? This clarifies the scope of the obligations and reduces misconceptions in practice. 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. The legality and deforestation-free status of the wood must be confirmed when the source material is supplied. 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 action

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. The due diligence obligation does not automatically end with further processing. The decisive factor remains whether the product continues to fall under a CN heading listed in Annex I. If not, it may also fall outside the scope. The relevant question within the meaning of the EUDR is always: Under which CN heading does my product fall at the time of import, placing on the market, making available or export?

Anyone who buys and resells coated disposable aprons, for example, is still obliged to register even if the product has been given a "completely different look". 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.

Organize collaboration internally

Technical, logistics and legal departments must work closely together, as 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.

Observe documentation requirements for end products

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 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, for example, this may include supplier confirmations, import or customs data, batch and quantity references and, where applicable, proof of certification. Certificates (FSC/PEFC) are supportive, but do not replace the EUDR evidence (in particular geo-data/risk assessment depending on the case).

In the event of a dispute, companies must plausibly demonstrate that every 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

Companies must systematically ensure their EUDR compliance along the supply chain when manufacturing, trading and importing paper-based products. The decisive factor is not the technical degree of processing, but whether the respective product is classified as an Annex I product for customs purposes.

With a view to the application from December 30, 2026 (large and medium-sized enterprises) and June 30, 2027 (micro and small enterprises), a robust classification and documentation system is becoming increasingly important.