Quick summary: Understand EUDR wood species requirements for paper manufacturers. Learn how pulp blending, supplier data and species traceability affect compliance.
When businesses discuss EUDR compliance for paper and packaging, the conversation usually focuses on country of origin, supplier information, geolocation and deforestation risk. EUDR Wood Species is another important data requirement that paper manufacturers should not overlook.
Under Article 9 of the EU Deforestation Regulation (EUDR), operators must collect information about the common name and full scientific name of the wood species contained in, or used to make, relevant wood products.
The European Commission’s updated guidance also addresses highly processed products such as paper, particleboard and fibreboard. Where the wood species used may vary, businesses must provide a list of the species that may have been used.
For paper manufacturers sourcing pulp from multiple suppliers, this requirement can create a significant information-management challenge.
EUDR traceability goes beyond identifying the country from which a wood-based product originates.
For relevant products listed under the wood category in Annex I, Article 9 requires operators to collect the common name and full scientific name of the wood species.
This information forms part of the product description and must be supported by the relevant due diligence information.
For example, a paper manufacturer may need to identify whether the wood fibre used in its products comes from species such as eucalyptus, pine, spruce or birch, using the appropriate scientific names.
The challenge is that paper production often involves multiple wood species, suppliers and processing stages. By the time the fibre becomes finished paper, identifying its original species composition may not be straightforward.
Unlike a sawmill processing identifiable logs, a pulp and paper mill often works with wood that has already been chipped, pulped, processed and blended.
Several factors make species identification difficult:
These challenges make species data difficult to maintain through conventional purchasing and production records alone.
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The European Commission’s updated EUDR guidance recognises that identifying every species in highly processed products such as paper and particleboard can be complex.
Where the species used to produce a relevant wood product varies, the operator must provide a list of the species that may have been used.
The species should be identified using internationally accepted timber nomenclature.
This is an important clarification for paper manufacturers.
It means businesses should not rely only on a generic description such as ‘hardwood pulp’, ‘softwood pulp’ or ‘mixed wood fibre’ where the applicable requirements call for species names.
Instead, they need a structured way to collect and maintain species information from pulp suppliers and other upstream partners.
For example, a paper manufacturer producing printing paper may use eucalyptus and acacia pulp in one production run and a combination of pine and spruce pulp in another. If the exact blend varies, simply recording the input as “mixed hardwood and softwood pulp” may not provide the species-level information required under EUDR. The manufacturer needs to obtain and maintain the common and scientific names of the species that may have been used, supported by information from its pulp suppliers. This makes supplier data collection and material traceability essential parts of EUDR readiness.
Consider a paper manufacturer sourcing hardwood and softwood pulp from multiple suppliers.

The supply chain may involve:
At each stage, product and material information needs to be transferred in a structured way.
For example, a paper mill should be able to connect its incoming pulp batches with supplier information, species declarations and relevant sourcing records. Where materials are blended, the mill needs a reliable record of which inputs contributed to the resulting production batch.
The finished product should not become disconnected from the information associated with its relevant wood inputs.
Paper converters and packaging manufacturers often operate further downstream than pulp producers.
They may purchase paper rolls or paperboard from multiple mills, each with different sourcing practices, fibre compositions and documentation formats.
A converter may know the mill, product grade, quantity and delivery date but have limited visibility into:
This creates a dependency on upstream suppliers.
Without a structured process for exchanging species and sourcing information, downstream businesses may struggle to assemble the information required for their own due diligence.
Discover the key requirements, common compliance gaps and practical steps to strengthen your pulp and paper supply chain.
Paper manufacturers can strengthen their EUDR data management by incorporating species information into their existing supplier and material traceability workflows.
A practical approach includes:
The objective is to ensure that species information remains connected to the material as it moves through the supply chain.

Managing species information across suppliers, pulp batches, production orders and finished products can become difficult when records are maintained in disconnected spreadsheets and systems.
Discover how a large paper manufacturer integrated its existing application with TraceX to connect farm-level sourcing locations, GeoJSON data, automated deforestation risk assessment, manufacturing batches and finished-goods shipments.
Digital traceability platforms can help businesses:
TraceX EUDR Solutions helps businesses connect supplier onboarding, sourcing, procurement, inventory, manufacturing and batch-level traceability through digital workflows.
For paper and packaging manufacturers, this can support better visibility into wood-based material inputs and help organise the information needed for EUDR due diligence.
For the paper industry, one of the less visible EUDR challenges may be identifying the wood species used in highly processed products.
A finished paper roll can contain fibre from multiple species, suppliers and sourcing regions. Its appearance or product specification alone cannot provide the complete information needed to establish material origin.
The responsibility therefore extends across the supply chain—from forestry and pulp production to paper manufacturing and converting.
Businesses need to ensure that species information, sourcing records and production data remain connected as materials move between organisations.
EUDR readiness for the paper industry is not just about knowing where the wood came from. It is also about knowing which wood species were used and being able to connect that information to the products being placed on the EU market.
Yes, where the paper product falls within EUDR Annex I and your business has an applicable operator or trader obligation. The fact that wood has been converted into pulp or paper does not automatically remove the species information requirement. Businesses need to assess the exact product classification and applicable obligations.
The information required depends on the product and applicable guidance. For highly processed products such as paper, particleboard and fibreboard, the European Commission’s guidance recognises that species may vary and indicates that operators should provide a list of species that may have been used, using accepted nomenclature. This makes structured upstream species data particularly important.
Generic descriptions such as hardwood and softwood do not replace the required common and full scientific names. Businesses should work with suppliers to establish a standardised species data collection process, supported by appropriate documentation and consistent nomenclature.
Not automatically. FSC and PEFC certification can support responsible sourcing and supply-chain documentation, but certification alone does not replace the information, geolocation, risk assessment and due diligence requirements applicable under EUDR. Businesses must assess whether their existing records provide the specific information required by the Regulation.
No. Low-risk country classification does not exempt an in-scope product from EUDR. Eligible operators may benefit from simplified due diligence under Article 13, provided the applicable conditions are met. However, the relevant Article 9 information requirements, including wood species information, still apply.