EUDR and ONIX: A supply chain lunch & learn - Tech Forum 2024

In this event, Graham Bell (EDItEUR) will discuss the impact of the upcoming EU Deforestation Regulations, the responsibilities it places on publishers, distributors, and retailers both within the European Union and outside it, and the need for data collection and record-keeping about the sources of raw materials used in the book industry. He’ll also describe how ONIX can be used to communicate some of the key metadata required for compliance with the regulations.

Link to video and transcript: https://bnctechforum.ca/sessions/eudr-and-onix-a-supply-chain-lunch-learn/

Presented by BookNet Canada and the Book Industry Study Group on September 3, 2024 with support from the Department of Canadian Heritage.

1. EU Deforestation Regulations
Graham Bell
EDItEUR
3rd Sept 2024, BISG / BNC Lunch ’n’ Learn

2. EU Regulation on deforestation-free products
•aims to limit deforestation, forest degradation and loss of biodiversity
anywhere in the world, by mandating ‘deforestation-free’ products
•main driver of deforestation and biodiversity loss is change of land use to
produce cattle, wood, cocoa, soy beans, palm oil, coffee, rubber
•as a big consumer of these commodities and of products derived from
them, the EU accepts it’s partly responsible, and aims to limit Europeans’
future contribution to the problem

3. EU Regulation on deforestation-free products
•passed into EU law at end of June 2023 – with 18 months to prepare
for implementation
•deadline – 30 December 2024
•places great emphasis on traceability and record-keeping by everyone in the
supply chain
•builds upon earlier EU Timber Regulations, in force for more than a decade
•products must be ‘deforestation-free’, or be excluded from the EEA
market

4. •EUDR requires that any ‘operator’ or ‘trader’ who places these
commodities or derived products on the EU market must be able to
show they do not originate from recently-deforested or degraded land
•operators must collect and retain data that allows the provenance of a
product’s raw materials to be traced to a specific plot of land
•for plots in ‘high risk’ countries, operators must do a more extensive
risk assessment and take steps to mitigate the risk of deforestation
having occurred
•operators must upload provenance and other data to an online
registry to create a Due Diligence Statement
•for a product to be compliant with the regulations, all its raw
materials must be compliant

5. •surely this doesn’t apply to me? Yes it does, unless you are based
outside the European Union* and your books are neither sourced
from nor for sale in the EU via any sales channel
•OK. When? Any product put on the market from 30th December 2024
will have to comply
•is there leeway for SMEs? Yes, until 30th June 2025 – if any two of
< !4m on the balance sheet, < !8m turnover, < 50 staff applies
•do I have to do the Due Diligence Statement? Depends on whether
you are an operator or a trader. Traders can refer back to previous
DDSs, although all parties share responsibility for the product’s
compliance
* in fact, the EEA plus Northern Ireland

6. •and I just do this once, right? The regulations apply at product level,
so each ISBN is separate, but the portal enables reuse of previously-
defined provenances if another ISBN uses the same raw materials
•what about recycled paper? The regulations exclude recycled material,
but if your paper is partly pre- or post-consumer waste, you must still
account for the other part
•so am I an operator or a trader? Tricky… In most cases, a publisher
will be an operator, but an importer (into the EU) could also be an
operator. The publisher will have to pass on data necessary for the
DDS to the operator, even if it is not itself an operator
•all parties in the supply chain should seek legal advice on their
responsibilities under the regulations

7. The metadata aspect
•the provenance of timber and paper pulp is or should be known by
paper mills
•data about that provenance must be passed along the supply chain, so
each party knows, for each product, ‘where the tree grew’
•ONIX is not generally used by paper mills or printers, so these
organisations will have to find ways of delivering paper details to
publishers to enable traceability
•publishers may use ONIX to pass details of raw materials to
operators and traders downstream in the supply chain

8. <ProductFormFeature>
<ProductFormFeatureType>50</ProductFormFeatureType>
<ProductFormFeatureValue>24FRXVV3VOS991</ProductFormFeatureValue>
</ProductFormFeature>
Due Diligence Statement reference (from List 79)
identifies a DDS record in the EU registry

9. <ProductFormFeature>
<ProductFormFeatureType>48</ProductFormFeatureType>
<ProductFormFeatureValue>GB 202401</ProductFormFeatureValue>
<ProductFormFeatureDescription>51.544708 0.061076</ProductFormFeatureDescription>
</ProductFormFeature>
provenance of raw material for cover (from List 79)
single GPS coordinate (latitude and longitude)
denotes the centre of a
4Ha plot of land where
the trees grew

10. <ProductFormFeature>
<ProductFormFeatureType>47</ProductFormFeatureType>
<ProductFormFeatureValue>GB 202311</ProductFormFeatureValue>
<ProductFormFeatureDescription>51.549040 -0.120975, 51.556838 -0.127326,
51.555092 -0.108261, 51.549040 -0.120975</ProductFormFeatureDescription>
</ProductFormFeature>
provenance of raw material for body (from List 79)
three or more GPS coordinates

11. <ProductFormFeature>
<ProductFormFeatureType>47</ProductFormFeatureType>
<ProductFormFeatureValue>GB 202311</ProductFormFeatureValue>
<ProductFormFeatureDescription>51.549040 -0.120975, 51.556838 -0.127326,
51.555092 -0.108261, 51.549040 -0.120975</ProductFormFeatureDescription>
</ProductFormFeature>
provenance of raw material for body (from List 79)
three or more GPS coordinates
denotes a polygon
outlining the forest
where the trees grew
51.549040 -0.12097551.556838 -0.127326
51.555092 -0.10826151.549040 -0.120975

12. Potential future additions
<ProductFormFeatureValue>GB 202401</ProductFormFeatureValue>Picea glauca
<ProductFormFeatureDescription>51.549040 -0.120975, 51.556838 -0.127326,
51.555092 -0.108261, 51.549040 -0.120975  ; 51.515333 -0.117380, 51.516582 -0.118347,
51.517177 -0.115544, 51.516026 -0.114760, 51.515333 -0.117380 </ProductFormFeatureDescription>
more than one polygon
contributed wood pulp
(same species and date)
to the paper stock
country polygon is in date of harvestspecies

13. •each paper, card, board type used…
•may be made from pulp from multiple forests, multiple species
•needs one or more of its own repeats of <ProductFormFeature> – there will
inevitably be many repeats
•List 79 – code 47 for body of book (or whole product), 48 specifically
for cover and binding, 49 specifically for ‘other’ (eg boards and
covering of slipcase, or other supplementary components)
•hardcovers need information about fibreboard and any cellulose-based
covering (eg faux linen), plus endpaper and jacket stock
•need for data about source of raw material for some leather bindings
uncertain, but likely unless leather is a species such as goat, sheep, eelskin
or is reformed from waste (bonded leather)
• potentially, use same method with bovid species name (Bos taurus for example)

14. Special issue in the book supply chain
•sources of raw materials may change between impressions – same
product but different paper
•could treat each impression as a distinct product, but this is onerous (and not
supported by existing near-universal product identifier scheme, the ISBN)
•most distributors and wholesalers do not offer lot control (separation
between copies of each impression, strict first in-first out fulfilment)
•and in any case, returns are often used to fulfil new orders
•thus data cannot exactly match raw materials to what a retailer will receive
•potential solution – build a cumulative list of provenances (ie specify
raw materials provenances for latest and all previous impressions)
•each addition will require a post-publication update of the ONIX data

15. <ProductFormFeature>
<ProductFormFeatureType>47</ProductFormFeatureType> <!-- interior -->
<ProductFormFeatureValue>GB Picea glauca 202311</ProductFormFeatureValue>
<!-- four points define a triangular source plot -->
<ProductFormFeatureDescription>51.549040 -0.120975, 51.556838 -0.127326,
51.555092 -0.108261, 51.549040 -0.120975</ProductFormFeatureDescription>
</ProductFormFeature>
<ProductFormFeature>
<ProductFormFeatureType>48</ProductFormFeatureType> <!-- cover -->
<ProductFormFeatureValue>GB 202401</ProductFormFeatureValue>
<!-- single point defines the centre of a 4 hectare source plot -->
<ProductFormFeatureDescription>51.542570 0.061570</ProductFormFeatureDescription>
</ProductFormFeature>
<ProductFormFeature>
<ProductFormFeatureType>50</ProductFormFeatureType> <!-- DDS ref -->
<ProductFormFeatureValue>24FRXVV3VOS991</ProductFormFeatureValue>
</ProductFormFeature>

16. <ProductFormFeature>
<ProductFormFeatureType>47</ProductFormFeatureType> <!-- interior -->
<ProductFormFeatureValue>GB Picea glauca 202311</ProductFormFeatureValue>
<!-- four points define a triangular source plot -->
<ProductFormFeatureDescription>51.549040 -0.120975, 51.556838 -0.127326,
51.555092 -0.108261, 51.549040 -0.120975</ProductFormFeatureDescription>
</ProductFormFeature>
<ProductFormFeature>
<ProductFormFeatureType>48</ProductFormFeatureType> <!-- cover -->
<ProductFormFeatureValue>GB 202401</ProductFormFeatureValue>
<!-- single point defines the centre of a 4 hectare source plot -->
<ProductFormFeatureDescription>51.542570 0.061570</ProductFormFeatureDescription>
<ProductFormFeature>
<ProductFormFeatureType>47</ProductFormFeatureType> <!-- interior -->
<ProductFormFeatureValue>GB Picea abies 202406</ProductFormFeatureValue>
<!-- five points define a quadrilateral source plot -->
<ProductFormFeatureDescription>51.515333 -0.117380, 51.516582 -0.118347, 51.517177
-0.115544, 51.516026 -0.114760, 51.515333 -0.117380</ProductFormFeatureDescription>
</ProductFormFeature>

17. Other considerations
•use FSC accredited paper?
•July – Forest Stewardship Council launched a voluntary regulatory module
to bring FSC accreditations into alignment with EUDR requirements
•new risk assessment framework also re-aligned with EUDR
•use POD?
•paper type may not be known until customer order is placed
•manufacturer will have to pass details to publisher and retailer?
•timeline for the DDS registry?
•September – user instructions. October – first training sessions. November
– user registration. Mid-December – go live

18. Further details
•EU
•https://green-business.ec.europa.eu/deforestation-regulation-implementation_en
•https://green-business.ec.europa.eu/deforestation-regulation-implementation/
deforestation-due-diligence-registry_en
•https://ec.europa.eu/transparency/expert-groups-register/core/api/front/document/
104730/download
•CPI
•https://www.cpi-print.co.uk – a printer’s eye view
•FSC
•https://fsc.org/en/newscentre/eudr/fsc-aligned-certification-for-eudr-and-system-
wide-changes-now-live

19. •EDItEUR
•www.editeur.org/93/Release-3.0-and-3.1-Downloads/ – ONIX documentation
•ns.editeur.org/onix – controlled vocabularies (‘codelists’)
•[email protected] – mailing list
•[email protected] – mailing list
While we’re talking about EU regulations, look out for GPSR and EAA too
…and if you’re completely unfamiliar with ONIX
•https://tinyurl.com/3eyy3a9f – 15-minute briefing video

20. Frequently asked questions
•will these regulations apply to reprints, or only to books published
after 30th December?
•I don't sell my books in the EU or European Economic Area, but I do
sell them in the UK. Do the regulations apply?
•is there some 'master list' of forests all over the world, with
information about when a particular plot was deforested or degraded?
•can this EUDR data be included if I'm still using ONIX 2.1?

21. •what is the exact difference between an operator and a trader?
•from the Directive – Article 2 – Definitions: see https://eur-lex.europa.eu/
legal-content/EN/TXT/?uri=CELEX:32023R1115#d1e933-206-1
•(15) ‘operator’ means any natural or legal person who, in the course of a
commercial activity, places relevant products on the market or exports them
•(16) ‘placing on the market’ means the first making available of a relevant
commodity or relevant product on the Union market
•(17) ‘trader’ means any person in the supply chain other than the operator who, in
the course of a commercial activity, makes relevant products available on the
market
•(18) ‘making available on the market’ means any supply of a relevant product for
distribution, consumption or use on the Union market in the course of a
commercial activity, whether in return for payment or free of charge

22. •there’s also https://green-business.ec.europa.eu/deforestation-regulation-
implementation/definitions-and-obligations_en#operator which makes it
clear that large retailers (who would otherwise merely be traders) have the
same obligations as operators, including the need to file DDSs, and joint
responsibility for non-compliance
•…and this is why you must seek legal opinion
•since soy is the raw material for some printing inks, do soy-based
inks need to comply?
•https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX: 32023R1115#
d1e32-243-1
•OK. Where should I start?

23. Nothing here may be construed as legal advice from EDItEUR
[email protected]
https://www.editeur.org