EU Deforestation Regulation 2026: Paper, Notebooks and Wooden Goods from Japan

Short answer: As of October 2026, the EU Deforestation Regulation (EUDR) applies from 30 December 2026 for large and medium operators and from 30 June 2027 for most micro and small ones. Paper and paperboard articles, wood pulp and many wooden articles are in scope. Printed books and other printed matter were taken out in December 2025. For goods made in Japan, the due diligence statement is normally filed by the EU business that brings them onto the EU market, not by the Japanese maker.

What changed, and the dates now in force

The regulation dates from 2023. Its start was postponed in December 2024, then Regulation (EU) 2025/2650 (December 2025) moved the dates back 12 months and simplified the rules for downstream businesses. In September 2026, Delegated Regulation (EU) 2026/2102 rewrote parts of the product list. The dates now in force:

Who	Applies from
Large and medium operators	30 December 2026
Micro and small operators (established as such by 31 December 2024)	30 June 2027
Micro and small operators, for products already covered by the EU Timber Regulation	30 December 2026
Products newly added by Delegated Regulation 2026/2102 (soluble coffee, certain palm oil derivatives and others)	30 December 2027

The third row matters for paper. The old EU Timber Regulation already covered pulp and paper of Chapters 47 and 48, so a small EU importer of paper goods has the December 2026 date, not the June 2027 one. That old list did not include wooden tableware and kitchenware (heading 4419) or “other articles of wood” (4421). For those products, a small operator gets the later date.

Which products from Japan are in scope

Product	Status under Annex I, as amended
Paper, paperboard and articles of paper (ex Chapter 48), such as notebooks and diaries (4820), cartons and boxes (4819), sheets of paper	In scope, with the exclusions below
Wood pulp (ex Chapter 47)	In scope
Wooden articles: frames (4414), tool and brush handles (4417), tableware and kitchenware (4419), boxes, cases and ornaments (4420), other articles of wood (4421)	In scope, except used and second-hand goods
Printed books, newspapers, pictures and other printed products of Chapter 49	Removed by Regulation 2025/2650
Products made of bamboo, rattan and “other materials of a woody nature”	Not covered (note added by 2026/2102)

The Chapter 48 entry now excludes:

• used and second-hand products, and waste
• recovered (waste and scrap) paper and products derived from it
• single-use packing used only to support, protect or carry another product and presented with it
• marketing and information material that only accompanies another product or is supplied free
• samples of negligible value used only to get orders

Some practical consequences:

• A paper gift box sold as a product is in scope. The same box is out of scope when it only packs a cup you sell.
• Notebooks stay in scope. They are listed under heading 4820 in Chapter 48, so the removal of printed matter (Chapter 49) does not cover them. Confirm the exact code with your customs broker.
• Recycled paper: products derived from recovered paper are excluded. The text does not say how paper with only part recycled content is treated.
• Washi made from non-wood fibres such as kozo: I have not found an official statement on whether these fibres count as wood or as “other materials of a woody nature”. Don’t assume either way. Ask the competent authority in your country.

Who files the due diligence statement

The “operator” is whoever first places the product on the EU market. If someone established outside the EU places goods on the market, the first person established in the EU who makes them available counts as the operator. In practice, that means the EU importer.

Before placing the goods on the market, the operator must submit a due diligence statement through the EU information system. The statement’s reference number has to be given to customs before the goods are released for free circulation. Since the 2025 amendment, downstream operators and traders no longer submit their own statements. The first one in the chain must collect and keep the reference numbers, and those that are not SMEs must register in the system.

The operator must collect, and keep for five years:

• a description of the product, including the common and scientific names of the wood species
• quantity, and country of production
• the geolocation of every plot of land where the wood was harvested, with the date or time range of harvest. Plots over four hectares need polygons, not single points
• supplier and customer details
• verifiable information that the wood is deforestation-free (no deforestation after 31 December 2020) and was produced legally in the country of production

Japan is on the low-risk list in Implementing Regulation (EU) 2025/1093. Where every commodity comes from low-risk countries, the operator can use simplified due diligence. It can skip the risk assessment and mitigation steps, but it still has to collect the information above and submit the statement. The country of production is where the trees were grown and harvested, not where the paper was made. Paper made in Japan can contain pulp from other countries, and that decides the risk class.

The 2025 amendment also created a “micro or small primary operator” regime: a one-time simplified declaration, with a postal address allowed instead of geolocation. It applies only to small operators in low-risk countries who place on the market products they grew or harvested themselves. It does not cover an importer of finished notebooks or boxes.

What to ask a Japanese maker

Ask early, because the answers may sit one or two steps up the supply chain. The maker who cuts, prints and binds your notebook may not have made the paper itself.

1. Fibre content of each paper and board: wood pulp, recycled, bamboo, or non-wood fibre, with percentages.
2. Tree species, with scientific names.
3. Country of harvest, and whether the mill can provide plot geolocation and harvest dates.
4. What evidence the mill can give on legal harvest and on no deforestation since 31 December 2020.
5. Whether the paper supplier already provides EUDR information to EU customers.

What this means if you order through me

I am not the operator for goods you import; you or your importer are. Before I quote paper or wooden goods for an EU destination, I ask the maker in writing, in Japanese, for the information listed above. I pass on exactly what they provide. If they cannot provide it, I tell you before you order, not after production. This article explains the rules; it is not legal advice. Check the Commission’s EUDR page and FAQ, and the competent authority in your country, before you rely on any of it.

More on paper products: custom notebooks and paper goods, custom paper boxes and the stationery and paper page. To start a project, send me a brief.