Printers, mills, merchants and publishers are not being left to cope with the requirements of the regulation without help. This ranges from software companies like Osapiens which specialise in meeting transparency and traceability regulations on behalf of customers, to protocols developed from within the industry and those from third party consultants.
Osapiens has been selected by UK paper mill James Cropper to ensure that its activities fall within the EUDR. The requirements on paper mills include full traceability of fibre, down to the precise location of the trees used to make the pulp which in turn makes the paper. As this is shipped to customers, the paper mill has to provide digital certificates to identify how and when the batch of paper has been made.
The Osapiens technology enables the mill to meet its obligations without having to employ additional staff. The software provider hosts the data in a cloud to be able to automate the collection of geospatial data, the legal and risks assessments, batch and product tracking and submission of the Due Diligence statements which are needed at the next step in the supply chain.
This can be a paper merchant which has the same obligations, though instead of needing the geolocation data, it starts with the DDS from the mill. It is only when there is an investigation does it become necessary to follow the Due Diligence Statements up to the beginning of the supply chain.
Osapiens will take of this for the merchant with inflows from mills across Europe and beyond, each comprising multiple brands, differing production windows and potentially using different pulps. On shipping, the merchant has to supply the DDS for each product delivered so that the printer has the DDS to prove to their customers that the supply chain is fully transparent.
While Osapiens is unsurprisingly not disclosing its methods, an initiative from the Initiative Online Print has developed a data exchange protocol that has received the endorsement of Intergraf. The proposed standard came about from the realisation that online printers can have a presence in multiple countries, Cimpress for example owns Tradeprint in the UK and Pixart in Italy, Onlineprinters is the parent of Solopress as well as having operations in Germany, Scandinavia and Poland, and there are others. All have also been used to shipping product across borders within the EU, hence need to produce DDS validation as well as receiving it from paper suppliers.
EUDR-X has been developed by the IPO. It is used to working with exchange formats for specifying and tracking the production of print, which provides the framework for the automated, standardised and secure exchange of data. It can be incorporated into an ERP and production workflow being based on JSON and XML.
Having a standard way of doing this will enable the print supply chain to continue to operate smoothly. Using a digital exchange format ensures the consistency of approach and helps avoid errors being introduced through miskeying. “Anyone who cannot offer a functioning interface for EUDR compliant data transfer will be excluded from many supply chains in the medium term,” the developer warns. The risk is that if data has to be submitted in an adhoc way, there will be delivery delays and these business will be unable to work with internal brands looking to manage their own compliance issues, major retail chains, for example.
Another initiative comes from the Book Chain Project, which has previously helped publishers identify the most sustainable paper mills and which is starting to include printers.
This work has given it close contacts within the mills and which is not enabling it to handle data associated with 4,000 paper brands that book publishers can use.
It has been tested by 12 of the 26 publishers that are members of the book Chain Project. These are the publishers that have supported the initiative, aware that they have to comply with EUDR. As a book can be made with different papers, each made in a different production window, and as each publisher can be working on multiple titles at any one time, the amount of data that needs to be processed is huge.
The team has collaborated with the Zoological Society of London Advisory Services and Global Forestry Service to validate the geolocation data. The ZSL work concentrates on creating templates for data collection in what EUDR deems as High Risk Countries, that legal forestry licences exist and to harmonise the data.
One of the issues is that while EUDR specifies what is needed, it does not say how. Each mill can decide what constitutes a production window, a few hours, a day or longer, as the data of production and which machine is used, is necessary.
The Book Chain team has delivered a risk assessment to each of the mills so they can make adjustments to ensure compliance as necessary. Essentially this can mean that mills from outside the EU can match those that are from EU member countries. Currently business from outside the EU cannot create the DDS because there is no provision for access to the TRACES database. The Book Chain team will visit the mill and ensure that its production is deemed low risk so that if it cannot create the DDS, as soon as the delivery crosses in th EU all the data is on hand.
There is an API into the Book Chain database for the project’s members to access all the documentation needed. The data can be associated with the book’s ISBN or accessed by consumers from another code printed on the book, much like the Chain of Custody number for FSC, to check that is legally entitled to be in the EU. If for example, the book uses different papers for the body text section and another for the cover, this amounts to change that needs a new DDS to trace which paper came from where and all the way to the forest.
It will not be perfect at the start date, now like to be the end of 2026 rather than the beginning of the year, and there will be friction to start with. This is understood. The plan must ben to make compliance as automated and as invisible as possible.
