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On October 21, 2025, the European Commission presented a reform of Regulation 2023/1115 on deforestation (RDUE). This text was supposed to correct the excessive complexity criticized by manufacturers over the past two years. For Copacel, which represents the French paper industry, these adjustments remain largely insufficient.
Adjustments too limited for paper companies
The amended text introduces two notable changes.
On the one hand, an easing of obligations for micro and small businesses upstream of the value chain in low-risk âeuros countries, in particular forestry operators.
On the other hand, downstream players such as printers or publishers would no longer have to repeat checks if they had been carried out upstream.
Traceability obligations deemed excessive at the end of the chain
But these advances, described by Copacel as common sense, are largely weakened by the retention of provisions deemed unworkable. The emblematic example remains the obligation to collect the identifiers of forest operators, which at the end of the chain leads the publisher of a book to potentially collect several hundred pieces of data, a constraint qualified as "unworkable" by Copacel "illegal" by the union, because "contrary to business secrecy" .
What's more, in practice this would, according to Copacel, mean asking a publisher to compile several hundred pieces of data without being able to use them.
A reform that maintains legal uncertainty for manufacturers
Another point of criticism is the persistent discrepancy between the regulation and the interpretation documents (FAQ in particular) issued by the Commission. Although these documents have provided some clarity in recent months, they have no legal force. Their absence from the amended regulation leaves companies in a state of uncertainty.
Christian Ribeyrolle, President of Copacel, points out that companies have already mobilized "a lot of time and money "to prepare for a regulatory environment "we knew it couldn't be implemented" . Frustration is heightened by the fact that this mobilization could be repeated.
Hasty implementation in 2026
The Commission wants to conclude the revision of the text by December 30, 2025, with the date of entry into force postponed by one year to the end of 2024. Copacel considers this timetable unrealistic. The reform affects the very structure of the original regulation, which requires, in the union's view, an in-depth legislative debate. Failing this, the risk is of another failure.
Copacel therefore calls for a further postponement of the application of the RDUE. "It's time for the co-legislators to realize the extent to which this chaotic management of the EUDR discredits Community policies. After a phase of debate which we hope will result in a sensible text, we will need time to prepare for the new obligations. For this reason, it would be incomprehensible if, for companies like ours, the European Commission persisted in retaining December 30, 2025 as the date for application of the RDUE" says Christian Ribeyrolle.
