EU carbon rules / Industry dossiers / Pulp and paper
NACE C17 4 duties 11 related regulations
Pulp and paper
Not on the CBAM list, but EUDR timber traceability and PPWR recycled-content rules determine market access.
Reference only: this dossier is public compliance research, not legal advice, and draws no compliance conclusion. Whether a duty applies depends on product classification (CN code), role (importer, EU producer, downstream purchaser), cumulative volumes and Member State application; rely on the legal text and the competent authority.
01
Duties
CCarbon: pricing, accounting, reporting, targets EEnvironment: pollution, waste, ecosystems, product attributes
| Duty | Trigger | Evidence needed | Timing | Legal source |
|---|---|---|---|---|
| Environment Traceability and EUDR statement for wood pulp/paper products Provide plot geolocation coordinates and forest traceability, and submit a due diligence statement (DDS). | Wood and wood pulp products entering the EU market | Plot geolocation coordinates, forest traceability, due diligence statement (DDS) | Large and medium-sized operators from 2026-12-30 | Reg (EU) 2023/1115 (postponed twice by 2024/3234 and 2025/2650) |
| Carbon Recycled content and recyclability of packaging Meet recycled fibre share and recyclability grading requirements in stages under the PPWR. | Packaging paper/paperboard placed on the EU market | Recycled fibre share and recyclability grading data | In stages under the PPWR | Reg (EU) 2025/40 |
| Carbon Product carbon footprint (customer requirement) Provide PCF data in accordance with EN ISO 14067 / PEF at the customer's request. | Requests from EU paper buyers (driven by ETS costs) | PCF in accordance with EN ISO 14067 / PEF | Ongoing | Market requirement (not a single regulation) |
| CarbonEnvironment ETS and IED compliance for EU installations Installations in the EU must monitor and report under the ETS, meet BAT-AELs under the IED and submit transformation plans. | Pulp and paper machines in the EU (including CHP) | MRV; compliance with the BREF (PP) | Ongoing | Directive 2003/87/EC; Directive (EU) 2024/1785 |
02
Related regulations
| Regulation | Number | Status | Key date | Applies to |
|---|---|---|---|---|
| Deforestation Regulation EUDR | Regulation (EU) 2023/1115 | In force | 2026-12-30 | Beef, cocoa, coffee, palm oil, rubber, soy, wood |
| Packaging and Packaging Waste PPWR | Regulation (EU) 2025/40 | In force | 2025 | Packaging and packaging materials |
| EU ETS Directive | Directive 2003/87/EC | In force | 2003 | Power, energy-intensive industry, aviation (within the EU/EEA) |
| Industrial Emissions Directive IED 2.0 | Directive (EU) 2024/1785 | In force | 2026-07-01 transposition | Large industrial installations |
| State Aid Guidelines on Indirect Cost Compensation (EEI) | Guidelines on EEI compensation | In force | continuous | Electricity-intensive sectors (steel, aluminium, chemicals, paper, etc.) |
| Renewable Energy Directive RED III | Directive (EU) 2023/2413 | In force | 2023 | Energy producers and consumers |
| Landfill Directive | Directive 1999/31/EC | In force | 1999 (as amended by 2018/850) | Landfill operators, waste treatment companies |
| Waste Framework Directive | Directive 2008/98/EC | In force | 2008 (as amended by 2018/851) | Waste generators, processors and producer responsibility entities |
| Packaging and Packaging Waste Directive | Directive 94/62/EC | In force | 1994 | Packaging producers and Member State recycling schemes |
| Single-Use Plastics Directive | Directive (EU) 2019/904 | In force | 2019 | Producers and sellers of single-use plastic products |
| Urban Wastewater Treatment Directive | Directive (EU) 2024/3019 | In force | 2024 (applies from 2027-01-01) | Urban wastewater treatment plants, discharging companies and municipal operators |
03