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An update from Bookvault on EUDR (due 23/09/2026)
As you may have heard, on Tuesday 23rd September the EU Environment Commissioner Jessika Roswall proposed a one-year delay to the implementation of the EU Deforestation Regulations (EUDR). As this delay is proposed and not yet ratified, this delay is not a foregone conclusion but for authors keen to understand what this means for their titles, the following is a brief summary of what the EU Deforestation Regulations are, what they mean for books, and what impacts a delay in their implementation may have.
What is EUDR?
- The EU Deforestation Regulations were drafted to combat global deforestation and forest degradation by reshaping how commodities are sourced, traded and consumed within the EU. Critically, it does so by creating a requirement that all applicable products, including cattle, cocoa, soy, palm oil, coffee, rubber and timber (and all products created from them, including books) be proven to be deforestation free in order to either be “placed on the market” in the EU, or be exported from it
- For books, that means comprehensive forestry information (tree species information, location within the forest that the trees were harvested from, and more) relating to the components of the books (text paper, printed end-papers, covers, jackets etc) would need to be passed down the supply chain from forest to paper mill to merchant to printer to publisher to wholesaler to retailer. The entity finally “placing the product on the market” in the EU would then have to create an entry in the EU Traces system (known as a Due Diligence Statement, or DDS) using all that information, alongside confirmation that due diligence has been done on that information to confirm it demonstrates that the materials were harvested in a way that avoided deforestation or forest degradation. In other words, it’s not just that data needs to be supplied; there needs to be confirmation that checks were done to confirm the products are actually deforestation-free
- Without DDS information (in the form of a DDS Reference Number and Verification Number, generated when the DDS is registered on EU Traces) on the customs documentation, books would not be able to cross the border into the EU. And EU competent authorities in each jurisdiction (i.e. country) would monitor and audit for compliance, with fines equivalent to 4% of an entity’s turnover in the EU able to be levied
In other words, EUDR places onerous requirements on importers into the EU to get the data they need and to be sure that their products are deforestation free, backed up by hefty fines for non-compliance.
Unsurprisingly, a large amount of work has been done over the course of 2025 by businesses across the book supply chain (including Bookvault) to be able to ensure their supply chains are indeed deforestation-free and to provide the required data downstream. This includes most suppliers seeking to providing DDS reference and verification numbers up front, so that rather than hefty amounts of forestry data passing down the supply chain, just those two numbers do. Creating DDS numbers up front also means the burden of proving products are deforestation-free doesn’t fall to the person at the end of the chain who is worst placed to try and prove that. As well as reducing the amount of data travelling alongside the products, this also should serve to smooth customs clearance across borders, and increases trust between parties so customers feel safe to order.
Even so, the amount of data and interactions with EU Traces are so numerous (not just within books, but across all EUDR affected products) that it is not a total surprise that the EU have had to delay implementation for fear that EU Traces would not be able to cope. In short, to launch EUDR successfully the EU needs to both boost the ability of EU Traces to be able to handle the level of interactions and data involved, but also likely trim the requirements to something that EU Traces can aspire to handle.
What does that mean for authors who self-publish through Bookvault?
- The first thing to be confident of is that Bookvault has been doing everything it can to be compliant with EUDR. All papers used in our books are from European mills that are already compliant with EU Timber Regulations (EUTR), and those mills were already confident of being able to supply the required forestry information (in the form of DDS reference and verification numbers) in advance of the end of 2025. Bookvault plan to then create a DDS using that input data for the books they produce, and would therefore be able to provide the DDS reference and verification numbers to allow customs clearance for books entering the EU, or for receiving businesses in the EU to be able to file their own DDS successfully as required, or for wholesale customers like Gardners or Baker & Taylor who would then be able to supply their own EU customers in due course
- It’s also worth noting that B2C sales (i.e. sales to individual consumers within the EU, as opposed to retailers, wholesalers and distributors ) are exempt from the legislation, which means that apart from having DDS data to enable customs clearance, our self-published authors would not need to provide that data to such customers in any other way. However, this information can be provided to authors if required (for example as they are supplying a corporate entity in the EU) – and this is something that we are looking at making available within the Bookvault portal
- The delay is likely to lead to some simplifications in requirements, but it is not yet clear what those may be and it remains likely that core tenets of EUDR will remain in place – for example, the need for Due Diligence Statements in all or most cases, and a need to demonstrate in some way that book are deforestation-free. One area where a change may come is in the treatment of books sourced from markets like the US – currently, books from the US are often not compliant with EUDR as US mills struggle to provide the level of forestry information required, and therefore authors and publishers in possession of US-sourced stock could struggle to supply it to customers in the EU. One possibility arising from this delay is a change so that it would be easier to demonstrate that US products are deforestation free, potentially by identifying the US as a “very low risk” country. That may help authors who hold existing stocks of books that they have sourced from US suppliers in the past
What should authors do next?
It's likely that the future shape of EUDR will become clear over the coming weeks, and as it does, Bookvault will post regular updates so authors are made aware of any pertinent changes. Any authors who supply customers in the EU should keep an eye out for updates, and where they source books from multiple suppliers, it’s important they check what all their suppliers’ plans are for ensuring that their books will be EUDR compliant, especially if those books are sourced from outside the UK or EU. If a supplier is not clear that they can supply the data that is currently anticipated as being required for EUDR, it is not safe to assume that such books can be supplied to EU customers, whether B2B or B2C, once the legislation finally comes into force. Whilst we may have another year to become compliant, and the legislation may change in some ways, it’s still important that everyone prepare and changes made if current arrangements look like they may not be compliant.
What if I have questions?
Please reach out to the Bookvault team at customers@bookvault.app; also, here are some useful links: