UPM Adhesive Materials
 

Imagine a land area the size of the European Union. More than that much forest has been lost globally due to deforestation during the past three decades. The area equates to around 10% of the world’s forests. Deforestation is also reportedly responsible for around 12% of global greenhouse gas emissions.

As a major development in its efforts to combat deforestation and forest degradation globally, the European Union is introducing EUDR, short for the EU Regulation on Deforestation-free Products (Regulation (EU) 2023/1115). The regulation entered into force on 29 June 2023 and is currently in a transition period that ends on 30 December 2025. The original application date 30 December 2024 was postponed by twelve months as per Regulation (EU) 2024/3234.

 

Update: European Commission, Parliament, and Council reached an agreement on amending the EU deforestation regulation (EUDR), as announced by the EU on December 4. The agreement reached introduces the following changes:

  • Implementation of EUDR has been postponed to December 30, 2026, for large and medium operators, and small and micro operators (where in EUTR scope).
  • Due diligence is limited to the first operator placing the commodity or product on the market. Operators and traders will no longer need to submit due diligence statements, nor pass on the reference numbers further in the supply chain. Only the first actor downstream will collect a due diligence reference number.
  • Books, newspapers and printed material are removed from the EUDR product scope.
  • EU to conduct a simplification review by April 30, 2026.
  • Both Parliament and Council must formally ratify the provisional agreement before it replaces the current EUDR. It is expected to happen before December 30, 2025.

We are committed to working with our customers to ensure compliance on the updated regulation by the application deadline.

 

What is EUDR?

EUDR replaces the EU Timber Regulation (EUTR, Regulation (EU) 995/2010) and extends mandatory due diligence requirements to new commodities. Under EUDR relevant commodities, such as wood, or products that contain or have been made using such relevant commodities, will be prohibited to be placed on the EU market or exported from the EU unless they meet the following criteria:

Deforestation and Forest Degradation-Free

Compliance with Country Legislation

Due Diligence Statement

An 18-month transition period began when the EUDR entered into force on 29 June 2023. This transition period was extended by 12 months in late 2024 and it will end with the new date of application on 30 December 2025.

Please note that, for small and micro undertakings, the transition period is six months longer – i.e., to 30 June 2026 – if relevant products are not yet subject to EUTR. Find more information on the timelines of EUDR implementation here.

 
 

UPM Adhesive Materials on EUDR

Responsible sourcing is a top priority for UPM and UPM Adhesive Materials. We are aware of and committed to the obligations set in the EUDR. During the transition period, a dedicated project team is assessing the requirements and taking necessary measures to be compliant with the regulation by 30 December 2025. 

We are working on processes from sourcing to the customer end to meet all regulatory requirements and to ensure necessary data will be available to customers within the required timeline, subject to the delivery of the final instructions by the EU Commission.

 

Frequently asked questions on EUDR implementation for UPM Adhesive Materials

Please be aware that our comments refer to EUDR compliance related to the supply of labelstock and other self-adhesive products to our direct customers based on UPM Adhesive Materials interpretation of publicly available information on EUDR in EU sources. We recommend customers consider their own EUDR obligations when selling products to their own customers. UPM Adhesive Materials does not offer legal advice or consult on EUDR compliance. We recommend requesting guidance from the EU or a third party when determining the impact of the regulation to your own business activities.

This section answers to frequently asked questions from UPM Adhesive Materials customers (last update October 10, 2025). In addition, please see our UPM Group statement on EUDR. 

Please find here the EUDR legislative text (including Annex I and II) as well as the amendments by the EU from December 2024. The EU has furthermore released updated guidance and Frequently Asked Questions on April 15, 2025.