Pulp and paper · Checklist

Deforestation Regulation EUDR Regulation (EU) 2023/1115 In force Key date:2026-12-30

• Due diligence statement (DDS) and geolocation Relevant commodities must be shown to be deforestation-free; geographic coordinates and a DDS must be submitted. Trigger:Import/export of soy, beef, palm oil, wood, cocoa, coffee, rubber and derived products · Evidence:DDS, plot geolocation, supply chain information · Timing:From 2026-12-30 for medium and large operators (two deferrals via 2024/3234 and 2025/2650)

Packaging and Packaging Waste PPWR Regulation (EU) 2025/40 In force Key date:2025

• Packaging recyclability and recycled content Packaging must meet recyclability-by-design, recycled content and reduction requirements. Trigger:Placing packaging or packaged goods on the EU market · Evidence:Declaration of conformity, EPR registration, recyclability assessment · Timing:Phased from 2030

EU ETS Directive Directive 2003/87/EC In force Key date:2003

• Obtain a greenhouse gas emissions permit Before operating an installation covered by the ETS, obtain a GHG emissions permit from the competent authority of the Member State and draw up a monitoring plan. Trigger:Operating an activity listed in Annex I to the ETS Directive (power generation, energy-intensive industry, aviation, etc.) · Evidence:GHG emissions permit, monitoring plan · Timing:Obtained before operation; valid on a continuing basis
• Monitor and report annual emissions Calculate in accordance with the MRR and submit an annual emissions report after verification by an accredited verifier. Trigger:Each operating year in which an emissions permit is held · Evidence:Monitoring methodology document, verified annual emissions report (AVR) · Timing:Submitted by 31 March of the following year
• Surrender a sufficient number of allowances Surrender EUAs equal to annual emissions; in case of a shortfall, a penalty of €100/t applies and the allowances must still be surrendered. Trigger:Annual emissions verified and confirmed · Evidence:Allowance account surrender records, cancellation certificate · Timing:By 30 September of the following year

Industrial Emissions Directive IED 2.0 Directive (EU) 2024/1785 In force Key date:2026-07-01 transposition

• Obtain an IED integrated permit and comply with BAT Operate in accordance with best available techniques (BAT/BREF) and apply an environmental management system. Trigger:Industrial activities listed in Annex I to the IED · Evidence:IED permit, BAT compliance assessment, environmental management system · Timing:After transposition of 2024/1785
• Submit a transformation plan The new IED requires high-emission installations to provide a decarbonisation transformation plan. Trigger:Energy-intensive installations subject to the IED · Evidence:Decarbonisation transformation plan · Timing:After transposition of 2024/1785

State Aid Guidelines on Indirect Cost Compensation (EEI) Guidelines on EEI compensation In force Key date:continuous

• Design indirect cost compensation in line with the EEI Guidelines Member State compensation for indirect electricity costs must comply with the State aid guidelines. Trigger:A Member State establishes an electricity indirect cost compensation scheme · Evidence:Member State aid notification, European Commission approval · Timing:2025–2030

Renewable Energy Directive RED III Directive (EU) 2023/2413 In force Key date:2023

• Increase the renewable energy share and retain proof of origin Renewable energy targets rise across sectors and must be evidenced by guarantees of origin (GOs). Trigger:Energy producers/consumers · Evidence:GO certificates, renewable share calculation · Timing:2021–2030

Landfill Directive Directive 1999/31/EC In force Key date:1999 (as amended by 2018/850)

• Only treated waste may be landfilled Except for inert waste that cannot technically be treated, waste must be treated before landfilling. Trigger:Operating a landfill · Evidence:Pre-treatment records, acceptance inspections and ledger · Timing:Ongoing
• Reduce landfilling of biodegradable municipal waste Reduce in stages to 75%, 50% and 35% against the 1995 baseline. Trigger:Landfilling biodegradable municipal waste · Evidence:Landfill volume statistics, compliance evidence · Timing:Phased (1995 baseline)
• Obtain a landfill permit and control leachate and landfill gas Meet technical operating requirements for siting, lining, leachate and landfill gas collection. Trigger:Constructing or operating a landfill · Evidence:Operating permit, leachate and landfill gas management records · Timing:Before operation and on a continuing basis

Waste Framework Directive Directive 2008/98/EC In force Key date:2008 (as amended by 2018/851)

• Apply the waste hierarchy, prioritising prevention, reuse and recycling Waste prevention and management legislation must follow the priority order of prevention, preparing for reuse, recycling, other recovery and disposal. Trigger:Generating or managing waste · Evidence:Waste management plans, disposal and recovery records · Timing:Ongoing
• Meet reuse and recycling targets Household waste and construction and demolition waste must meet the prescribed reuse and recycling rates. Trigger:Management of household waste and construction and demolition waste · Evidence:Recycling rate statistics and reports · Timing:Phased from 2020
• Meet producer responsibility (EPR) Within the scope of extended producer responsibility, organisational and cost obligations for take-back and disposal apply. Trigger:Product falls within the scope of extended producer responsibility · Evidence:EPR registration, records of fulfilment of take-back obligations · Timing:According to Member State transposition rules

Packaging and Packaging Waste Directive Directive 94/62/EC In force Key date:1994

• Packaging must meet essential requirements and join a recovery system Packaging placed on the market must meet the essential requirements on prevention, reuse and recovery and participate in recovery organised by Member States. Trigger:Placing packaging or packaged products on the EU market · Evidence:Compliance technical documentation; Member State producer responsibility registration and fee payment evidence · Timing:Continuing application; PPWR 2025/40 replaces it in stages
• Meet Member State recovery targets The Directive sets minimum recovery rates; specific fees, marking and deposit rules are set by Member States and may be stricter. Trigger:Parties responsible for producer responsibility for packaging waste · Evidence:Declared quantities, recovery evidence and registration with the Member State competent authority · Timing:According to Member State statutory deadlines

Single-Use Plastics Directive Directive (EU) 2019/904 In force Key date:2019

• Restrict certain single-use plastic products The Directive bans certain single-use plastic products from the market and requires reduction, marking or producer responsibility for others. Trigger:Producing or importing single-use plastic products covered by the Annex to the Directive · Evidence:Whether the product falls within the Annex; marking and producer responsibility registration · Timing:Phased from 2019
• Member States may levy separate single-use plastic charges The Directive only requires Member States to take measures and does not set a uniform tax. The German single-use plastic fund, the Spanish plastic packaging tax and the Portuguese plastic bag contribution are national measures on top of it. Trigger:Selling single-use plastic or lightweight plastic bags in the relevant Member State · Evidence:Member State registration, declaration and payment · Timing:According to the Member State entry-into-force date

Urban Wastewater Treatment Directive Directive (EU) 2024/3019 In force Key date:2024 (applies from 2027-01-01)

• Ensure urban wastewater collection and secondary treatment Build and operate collection and treatment facilities according to population equivalent size and the timetable. Trigger:Generating urban wastewater · Evidence:Collection and treatment permit, effluent monitoring reports · Timing:Phased according to the timetable
• Apply quaternary treatment at treatment plants of ≥ 150 000 p.e. Treatment plants with a load of 150 000 population equivalent or more must remove micropollutants. Trigger:Treatment load ≥ 150 000 p.e. · Evidence:Quaternary treatment operation and monitoring data · Timing:2033 / 2039 / 2045
• Advance energy neutrality and GHG emission reductions Improve the energy balance of collection and treatment activities and progressively reduce GHG emissions to sustainable levels. Trigger:Urban wastewater collection and treatment activities · Evidence:Energy consumption and energy balance reports · Timing:By 2045