The German Printing and Media Association (BVDM) has criticised the European Commission’s proposals for revising the EU Deforestation Regulation (EUDR) as inadequate. It argues that the proposed relief measures for companies in the downstream supply chain are not being implemented consistently and fail to address key challenges in practical implementation.
The BVDM welcomes the EU’s efforts to further simplify the EUDR, but in the BVDM’s view, the proposals presented on 4 May 2026 do not go far enough to reduce the bureaucratic burden in the long term. The exclusion of printed matter confirms that printed products manufactured in the EU are not drivers of deforestation or forest degradation. “If paper does not contribute significantly to forest damage, then, by extension, the regulations for printed products still covered by the EUDR, such as packaging and labels, must also be further simplified,” demands Kirsten Hommelhoff, Chief Executive of the BVDM.
The BVDM supports the European Commission’s approach of focusing due diligence obligations on the start of supply chains. However, the aim of relieving the downstream supply chain of liability risks is partly undermined if a suspicion raised by a third party can trigger a cascade of retrospective due diligence checks. “If companies in the downstream supply chain continue to face extensive investigation, documentation and liability risks, the planned relief will fail to achieve its objective,” explains Kirsten Hommelhoff. She adds: “Small and medium-sized enterprises, in particular, must not be indirectly burdened once again with bureaucratic requirements simply because larger market players wish to protect themselves comprehensively.”
In a statement, the BVDM reminds the European Commission of its own commitment that companies in the downstream supply chain should not be held responsible for potential breaches of the EUDR in the country of origin. To achieve this, registration, documentation and ex post due diligence obligations for downstream companies would need to be removed. Otherwise, there is a risk that larger companies in the downstream supply chain, as part of an excessive ‘risk management’ approach, would request detailed information via questionnaires and supplier portals even from small and medium-sized suppliers, in order to protect themselves against ex post due diligence checks – and possible bans on placing products on the market. This would effectively nullify almost all the simplifications achieved for downstream companies and lead to additional bureaucratic burdens.
BVDM
The Federal Association of Printing and Media (BVDM) is the umbrella organisation for the German printing industry. As an employers’ association, a political trade association and a technical trade association, it represents the positions and objectives of the printing industry vis-à-vis politicians, government bodies, trade unions and the supplier industry.
