Paper and cardboard come from wood, and wood is one of seven commodities covered by the European Deforestation Regulation. This does not mean that every paper or cardboard product automatically falls within the scope of the obligations. The regulation works with a list of product categories linked to commodity codes (the codes you also encounter on customs documents). Some paper and cardboard products are on that list, others are not, and the precise code of your product determines whether this applies to you.
For you as an importer or trader, this means you cannot rely on the question "is it made of wood", but on the question "under which commodity code does my specific product fall". That is a small but important distinction, as it explains why two companies that both trade in paper products can reach different conclusions.
Why the commodity code is decisive
The regulation links its scope to the annex with product categories and the associated commodity codes. This is a deliberate choice: customs codes are unambiguous and already part of the administration you carry out anyway when importing. For wood and wood products, a significant part of the processed products on that list, but not everything. The exact list of codes can be found in the official text of the regulation on EUR-Lex; that location is also precisely where you should look if you want to check for yourself whether your product is on it.
Paper, cardboard and printed matter: where it becomes less straightforward
With raw materials such as wood pulp or unprocessed cardboard, the link to the raw material wood is obvious. With further processed products, such as printed paper, books, packaging material or office supplies, it becomes less straightforward. Some of these products fall under their own commodity code that is not on the regulation's list, others do. This is precisely the kind of question where you should not rely on a rule of thumb, but on the code that applies to your product.
The same applies to packaging that you would not yourself describe as a "wood product", such as cardboard boxes or protective layers in transport. Here too, the commodity code is decisive, not the intuition that cardboard is after all made of wood.
Packaging versus the product itself
Another distinction that often causes confusion: packaging material that you use to transport another product is generally approached differently than the traded product itself. If, for example, you import coffee that is transported in cardboard boxes, attention initially focuses on the coffee and the associated obligations, not on the box around it. Once you yourself import or export cardboard or paper as a commodity, that question shifts to the paper product itself and the code that applies to it.
How to verify this for your own assortment
The most practical starting point is your own administration: the commodity code you already use for imports or customs declarations. You can compare that code with the annex of the regulation to see if your product is included in it. For businesses with a broad or changing assortment, this quickly becomes more than a one-time check, especially if you work with multiple suppliers and product variants. A role check provides a first indication in that case, based on the role you fulfil and the type of product you trade; in a few questions see how your situation looks in broad terms is a logical first step before you delve deeper into the details.
If you have multiple product streams alongside each other—paper alongside, for example, coffee or timber—it is advisable to review each stream separately rather than all at once for your entire range. This way you avoid a product that falls outside the regulation ending up in a file, or conversely, a product that does fall under it falling out of sight. search the knowledge base for your own product group provides an overview per commodity of what is and is not covered.
What if only part of your range is covered
It often happens that a company must comply with the obligations for one product but not for another. This is not an exceptional situation and does not require a separate approach for the entire business, but rather careful categorisation per product line. The legal assessment of which code applies to your product and what follows from it remains your responsibility or that of a lawyer; in case of doubt, the official text of the regulation or the competent supervisory authority is the appropriate place to have this confirmed.
If you want to see what such a categorisation looks like in practice before you collect data yourself, an overview of how a file is structured a clear picture of the steps involved.
Are you unsure whether your own paper, cardboard or printing products fall within the scope of the regulation? Take the free role check or browse the knowledge base; both give you an initial picture of where you stand without obligation.