EUDR Wood Species: An Underrated Traceability Challenge for the Paper Industry

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.

Key Takeaways

• Wood species identification is a core EUDR information requirement. Article 9 requires operators to collect the common name and full scientific name of the wood species relevant to products in scope.
• Paper products present a unique traceability challenge. Highly processed products such as paper, particleboard and fibreboard may contain wood from multiple species, making species-level information difficult to obtain and maintain.
• Supplier declarations alone may not be enough. Paper manufacturers and importers need reliable upstream information, supporting records and processes to validate species data across their supply chains.
• Mixed wood inputs increase data complexity. Changes in sourcing, pulp composition and production batches can make it difficult to maintain consistent species information throughout the supply chain.
• Product scope and species data must work together. Businesses should first identify which products fall under EUDR Annex I and then establish the applicable species information requirements.
• Digital traceability helps close information gaps. Structured supplier data, material mapping, batch-level traceability and centralised evidence management can help businesses maintain reliable records and respond to due diligence requirements.

Why Wood species data matters under EUDR

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.

Why species identification becomes complicated in pulp and paper manufacturing

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:

• Mixed-species pulp: Market pulp may contain fibre from multiple wood species. The mill may receive species information at the supplier or product level rather than for every individual fibre input.
• Changing fibre recipes: Manufacturers may change the proportion of hardwood and softwood depending on paper grade, quality requirements, availability and production conditions.
• Multiple sourcing regions: Different suppliers may source wood from different forests, countries and production regions.
• Blending during production: Pulp from multiple suppliers or batches may be combined before entering the paper-making process. This makes it important to preserve the relationship between incoming material records and production batches.
• Limited downstream visibility: A converter purchasing paper from several mills may receive product specifications and supplier documentation without having direct access to the original forestry and species information.

These challenges make species data difficult to maintain through conventional purchasing and production records alone.

Explore our EUDR Wood Solutions

What if the exact species used in a paper product can vary?

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.

How species information travels through the paper supply chain

Consider a paper manufacturer sourcing hardwood and softwood pulp from multiple suppliers.

The supply chain may involve:

• Stage 1 – Forestry and harvesting: Wood is sourced from forest plots, where the relevant production location and species information originate.
• Stage 2 – Wood processing: Logs are converted into chips and supplied to pulp mills. Species information needs to remain associated with the relevant source materials.
• Stage 3 – Pulp manufacturing: Different wood species may be processed into pulp and supplied in separate or mixed batches.
• Stage 4 – Paper manufacturing: Pulp from multiple suppliers may be blended to achieve the required paper properties.
• Stage 5 – Converting and packaging: Finished paper is converted into paperboard, packaging or other downstream products.

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.

Why this creates a challenge for paper converters

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:

• The wood species used in the pulp.
• Whether the product contains multiple species.
• The upstream sourcing locations associated with relevant wood inputs.
• Whether the species information changes between suppliers or batches.
• How the information connects to the finished paper or packaging product.

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.

Read our blog to understand EUDR requirements for the paper industry and prepare for compliance with confidence.

Building a species-level traceability process

Paper manufacturers can strengthen their EUDR data management by incorporating species information into their existing supplier and material traceability workflows.

A practical approach includes:

• 1. Supplier onboarding
  Collect supplier details, pulp product specifications, sourcing information and supporting documentation.
• 2. Species master data
  Maintain a standardised list of common and scientific wood species, aligned with recognised timber nomenclature.
• 3. Incoming material identification
  Record species information against relevant pulp, wood-chip and fibre input batches.
• 4. Production and blending records
  Connect incoming material batches to production orders and record which inputs contribute to each paper batch.
• 5. Origin and geolocation linkage
  Maintain the relevant sourcing locations and supporting information associated with wood inputs subject to EUDR requirements.
• 6. Finished-product traceability
  Connect finished paper rolls, paperboard and packaging batches to their production inputs and supporting compliance records.
• 7. Supplier data exchange
  Establish a consistent process for receiving updated species, sourcing and product information whenever suppliers or material compositions change.

The objective is to ensure that species information remains connected to the material as it moves through the supply chain.

How digital traceability can help paper manufacturers

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.

Read the case study to see how TraceX helps strengthen wood and pulp traceability and streamline EUDR due diligence across the supply chain.

Digital traceability platforms can help businesses:

• Maintain structured supplier and wood-species information.
• Standardise common and scientific species names.
• Connect incoming pulp batches with production records.
• Track material blending and consumption.
• Link relevant sourcing locations with material records.
• Maintain supporting documents and compliance evidence.
• Share structured traceability information with downstream partners.

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.

Conclusion: EUDR traceability must go beyond the finished product

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.

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