#343 - EUDR For Print: What Changes Now, with Anna Roberts, Head of Market Development

A regulation that can fine you for a single weak link in your supply chain forces a different kind of thinking. We sit down with Anna Roberts, Head of Market Development at IOV42, to unpack the EU Deforestation Regulation (EUDR) and why it is creating real urgency for timber, paper, packaging, and print businesses trying to trade with the EU.

We get practical about what EUDR compliance actually involves: due diligence, traceability back to the plot of land, and the uncomfortable reality that “we’ve always done it this way” no longer holds up. Anna explains where the biggest concerns come from, including the scale of penalties, the difference between upstream and downstream obligations, and why print can be uniquely complex when products are composite and raw materials come from fragmented, global networks. We also clarify a point many people miss: scope is driven by the product and its HS code, so some finished printed materials may be out of scope while printed packaging, labels, and stationery can still trigger obligations.

From there, we look at how to cut through the noise. We talk myth busting, mapping your supply chain, and why collaboration with suppliers beats transactional purchasing if you want reliable data. Anna also shares how IOV42’s Interu platform uses automation and AI to reduce the endless back-and-forth of chasing information, while keeping humans in control and decisions explainable. Finally, we zoom out to place EUDR inside the wider EU Green Deal direction of travel, alongside other sustainability and reporting rules that make good data foundations a long-term advantage.

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Transcript

Welcome And Guest Introduction

SPEAKER_01 0:01

Welcome to the Future Print Podcast, celebrating print technology and the people behind it.

SPEAKER_00 0:10

Hello and welcome back to the Future Print Podcast. My name's Ed, and I'm really happy to be joined today by Anna Roberts, who is head of market development at IOV42. Anna, hi, how are you doing?

SPEAKER_02 0:20

I'm fantastic. Thank you for having me.

SPEAKER_00 0:23

Brilliant. Okay,

What EUDR Is And Why

SPEAKER_00 0:24

so we wanted to get you on the podcast today to kind of talk about the EU DR, so the European Union deforestation regulations. For people hearing that that word or that phrase for the first time, what is it? And why is it causing a little bit of concern among supply chains?

SPEAKER_02 0:44

Yeah, it's a good question. For the first part, the clue is in the name. It is an EU piece of regulation that relates to deforestation in particular. And I think importantly, whilst it is an EU piece of policy, due to the nature of global supply chains, it is impacting people as far away as Uruguay and China and Scandinavia. It's impacting everyone. And the reason for it, I think, is very important to always have front of mind when you're bogged down in the ins and outs and the difficulties of it. The main purpose of it is to try and decouple EU consumption from deforestation. So preventing goods that may be linked to deforestation from entering or being processed or leaving the EU and why. So I'm going to share it with you in case it blows your mind too. But illegal logging, so not just deforestation, but logging is the world's third largest crime by value. So it's behind drug trafficking and it's behind counterfeited goods, but there is more value lost from illegal deforestation than there is from human trafficking and weapons trafficking. And when you hear that, you understand the scale of this and then the economic impact and the criminality of it. So that's really the why. The why now, I think previous efforts, previous voluntary schemes, previous regulations like the EU timber regulation have done something, but they've not moved the needle enough. Otherwise, we wouldn't need something like the EUDR. So that's the why.

Why Businesses Are Worried

SPEAKER_02 3:10

In terms of the concerns, I think it's important to separate into two camps. The first camp is if I'm a company who is being naughty and doing the wrong thing, and I suspect, or maybe I know that my goods are coming from places where they shouldn't do, or they've been illegally harvested, or there's fraud in the in the supply chains. For companies who are doing the wrong thing, their concern with the UDR is it makes it much harder for them to trade into the EU. So that's kind of a good, that's good. We want to make it harder. For companies who are doing the right thing, though, this is where we pay a little bit more attention to the concerns. So I think partly they're worried about the size of fines. So the potential impact of one non-compliant item could be as much as 4% of revenue. So for a company the size of IKEA, nearly 50 billion euros in revenue, that's 50 billion euros annual turnover, that's a really big 4% is a really big potential hit. There's also potential criminal proceedings, depending upon the country, for directors. So we've got IKEA at one end. Think about a small family-run business. Well, this is dad or this is mum who might potentially be going to jail for this. Um I think for those who've been following EU timber regulation, so that's how it applies to wood products, and obviously EDR applies to other commodities as well. It's sort of more of the same. So EU timber businesses who fall under EU timber regulations have got some concerns because it's more work, but it's more of the same. It's for those companies for whom traceability is brand new. They've gone from zero to 100 very quickly. It feels like a lot of work to trace each product all the way back to the plot of land. And thinking about print and print industry in particular, that's particularly relevant and particularly tricky when you have composite products. You know, printed materials can be made of not just a cover and an inlay and paper, but the paper can come from huge numbers of different forest sources, different pulps, etc. You've also got the challenge around stock. Again, it impacts printers a lot. You do really big print runs, that stock, if it's placed in the market from 2027, will need to comply. Then you've also got the challenges if you've got very long, fragmented supply chains, thousands of suppliers, et cetera, it just becomes pretty complicated for everyone. So yeah, a bit of a long answer, but that that's why people are concerned.

SPEAKER_00 5:52

No, it's really good. And I think actually it's it's really pertinent not to date the podcast too much, but you know, last week we saw 40 degrees, 42 degrees heat in Europe. And there is a real issue with global warming, as we all know, and we need to be more sustainable. And I suppose that this regulation will kind of move us towards towards that. Uh in terms of kind of you mentioned that it's global, you know, it's it's China, it's South America.

Who Is In Scope For Print

SPEAKER_00 6:21

More specifically, for people who listen to this podcast, who is and isn't in scope for it?

SPEAKER_02 6:28

Very good question. And it's not an obvious answer. It's not a silly question. There are still lots of nuances and slightly grey areas around this. I think the critical step before saying who is in scope is to just clarify what is in scope. Because it's really the product that determines if you as a company are in scope. So seven commodities and their derived products in scope. Um, from pulp, uh, sorry, from palm oil, coffee, soy, rubber, timber, leather used to be, so cattle is still in, um, that's very important. Paper, packaging, pallets, that's all in scope. Specifically for the print industry, there are probably three scenarios. If you are in the EU and you are purchasing printed material, maps, books, magazines, whatnot, that is not in scope. You have no obligations. You don't need to collect information, you don't need to do due diligence, you don't need to pass any information on. So you're purchasing a finished print product off the hook. If you are producing printed material, so if you are a printer and you are buying your paperboard or your wooden display materials or your paper, you're buying that from an EU supplier, those products will have already had to comply with EUDR. The supplier will have had to do due diligence. And therefore, your obligations are really limited. So you're producing printed materials from EU raw material inputs, you maybe need to collect some information about the products and store that from your suppliers, but you don't need to do due diligence and you don't need to submit anything to the EU's information system. The bit where it's tricky is if you are a supplier to the print industry, or you might be a printer who is buying raw materials from outside of the EU that have never been in the EU. So you might be buying from a big paper mill in Indonesia or in India or elsewhere. You're importing that as paper or pulp into the EU for the first time, and then you're printing on it because you're importing an in-scope product that is in scope at that point. You don't need to worry about passing information downstream. But when you're buying and bringing into the EU an in-scope product for the first time, you would have full obligations there. Um so yeah, that's where it becomes interesting because for UK printers, there's a slight advantage potentially, because if they are supplying a finished print product into the EU, that's got no obligations versus buying from an EU printer potentially. Well, we had we heard that um about some kind of unintended benefits for UK printers um earlier this year. So yeah, I thought it might just be worth sharing. Now, last end of last year and confirmed in April is the fact that printed materials that come with an HS code starting 49 are now not in scope. So things like maps, magazines, books, marketing materials, none of those are in scope of the UDR anymore. Gets complicated because some printed materials are still in scope. So if it's a printed material, but it might be packaging or it might be um stationary or a label or something, if it has a 4.8 HS code, that is still going to be in scope. So first things first with people, check your products. Then write my products in scope. Who needs to worry about this? There's no minimum threshold. So some regulations, and in fact, the UK's proposed equivalent of EUDR says we're going to make a decision about whether you're in scope or not, depending upon the size of your company and the volume of goods that you're trading. EUDR, you could be importing one sheet of paper. It could be a tiny company, and if you're selling it on, that would be in scope. Um EU, any EU registered company importing these in-scope products is legally liable. So it's EU regulation. There must always be an EU company that can be held accountable. Um, and they're called the the upstream operator. They're typically the first importer. So the burden is on that first company putting goods in the EU market. It's much easier now than it was a year ago for their customers, the downstream operators, they've much more limited obligations. But if you think about it, and this is where it gets a little bit complicated, I'm um a UK or a Swiss or I might be an Indonesian or an Indian supplier to the print industry. I'm not in the EU. However, if my goods are to be able to be sold into the EU, they have to comply. So I effectively have the burden of all of the evidence, um, but I'm not legally on the hook for it if I'm not importing it. And sometimes we get companies coming to us saying, but my EU customers are telling me I have to do X, Y, and Z. And you're thinking, well, you legally you don't, but from a commercial standpoint, yeah, you're not going to be able to trade unless you can provide evidence that the goods aren't def um haven't been linked to deforestation.

SPEAKER_00 11:58

It's fascinating. And I suppose, you know, it is also quite complex. It sounds complex, you know, HS code. Yeah. 491101, you know. Oh, yeah. You know what I mean? It does evoke slightly of scary bureaucracy.

Myth Busting And Reducing Complexity

SPEAKER_00 12:17

It is complex. And I know that IOV, you guys have spoken about the trying to uh myth bust a little bit. How do you how would you go about that? You know, what would you do to kind of uh avoid having too much complexity within this system?

SPEAKER_02 12:32

There is there are a lot of misunderstandings, and I think nobody should feel silly for not understanding things because this is a piece of regulation that's changed an awful lot. And it hasn't been personal opinion, it hasn't been particularly well communicated or much awareness practically being created in capacity building, whether you're in the EU or not in the EU, that's been limited. So never feel silly about those. I think um there are two levels of complexity. The first is, well, yeah, the first in terms of complexity is understanding the regulation. And this is where a lot of the myths surface from. My colleague Holly said she was, oh, I was she was going around a little bit in circles trying to understand certain parts. And she said, you know what I did? I printed out the documents and I went through them and I read them, and every scenario I thought, how does that apply to my business? And I drew a diagram of my business of my supply chains, and then I got it. And I think that is really, really important. Um, so I that would be a recommendation for that. Um I think other recomm other myths and misconceptions we hear for the print industry are things like, but my my goods are FSC certified, so that's okay, right? Or, oh, but we're a small company. We're a small company in the UK, we don't need to worry about this. Or, oh, there's a grace period for for stock. Um, and those are all those are all myths, actually. Um the biggest misconception that we see, once people understand the regulation and they're part of it, is that for a business, whether you're big or whether you're smaller, the compliance preparation for this, ongoing operational management for EUDR compliance can be managed by or done by one department. It it really can't. This impacts um if you're in the print industry, this is going to impact um your purchasing department, your probably your sales department as well, because customers might be asking for it, maybe a bit less relevant to print, but paper industry, for instance, supplying the print industry, sales department, um, IT, often it requires systems to talk to each other, legal compliance, sustainability are often um tasked to doing this. So it really is a cross-departmental thing. And then the second thing is it can't happen only overnight. You can only move as quickly as your suppliers move. You're only as well prepared as your least prepared supplier. So that's where we really feel um if you treat your suppliers and your supply chains transactionally, this is gonna be painful. But if you collaborate, if you support them, if you kind of understand and empathize the pain points that they have and help them with that, um that's gonna be that's gonna be really, really helpful.

SPEAKER_00 15:39

It's it's always good to hear about collaboration because you know, FuturePrint, we're we're really huge on bringing businesses together, collaborating together, you know, our industry is only as strong as as as we can make it. So it's it's really nice to hear that perhaps there will be some positives that come out of something that can sound actually quite scary.

What IOV42 And Interru Do

SPEAKER_00 15:58

Let's let's move on to exactly what IOV42 do now. So you have a software. What is it and what what problems can it solve?

SPEAKER_02 16:09

I think first of all, we are a platform with software. Uh we're a technology company at the heart of it. But our and the team is very experienced delivering and designing um industry solutions at scale. So we've got we've got kind of a experience with that. But we've we've pride ourselves in being very grounded in reality. So we've been working on EU TR for the best part of a decade. And a number of my colleagues come from the print industry. They ran printed businesses or the packaging industry or the lumber industry. So they keep us real, they tell us exactly how it is on the ground. We love nothing more than a trip to a sawmill where we wear our hard hats and we see how things actually work. Because yeah, having a platform for this type of thing is one part of it. It's not a silver bullet, but it can make life easier. But it's any platform that guarantees that you can comply with something, I'd run a mile from. So our whole aim is to make due diligence and your ability to trust claims made about products. So the product is from this particular area, or my product is a UDR compliant. We're trying to make your decision making around whether you can trust something like that as seamless as possible. So that compliance and purchasing folks can focus on compliance and purchasing and not have to worry about um checking if data is missing from suppliers or is data incomplete or chasing suppliers. We hear about this endless back and forth, back and forth chasing down information from suppliers. That is what we are trying to eliminate to help people focus on more value adding work. Um, yeah, that's our that's our main part of it. And then it it wouldn't be it wouldn't be a podcast or a discussion in today's world if we didn't mention AI. So AI and automation have really important and interesting roles to play in this. So we are very excited by that. We're using it extensively within our business, within Interru, but we are super clear. You as a user, you stay in control of decisions made about your business. This is not a black box. It's going to be play a really great assistant role, pointing out, hey, there's a gap there, or oh, you might want to double check on that risk. What we will never, well, what we're not doing at the moment is saying, yes, we've looked at all of the information, green tick, you're good to go. Like we know that that will not stack up from enforcement investigations. If a compliance manager cannot explain how they came to a decision, it's it's non-compliant.

SPEAKER_00 19:03

It feels like, you know, when we talk about AI, it is often hand in hand with with the human capacity to to maybe, you know, do these things. It's never, it's never just, oh, we'll just put AI there and it'll do what we want it to do. You know, it's I assume it's exactly the same with interrupt, you know. You can't just get a piece of software and think, there we go, we're done. You know, we're happy. You know, that's it. No worries.

SPEAKER_02 19:30

We do come across, we do come across a lot of people who are searching for that and would love that.

SPEAKER_00 19:36

Well, I'm sure, yeah, I'm sure.

SPEAKER_02 19:38

Unfortunately, um I think they, yeah, we're not the best company for them to work with because we we we don't want to replace your relationships with suppliers. We don't want to replace kind of human cognitive thinking behind some of these really important checks and balances.

SPEAKER_00 19:55

I suppose, you know, you're you're kind of allowing uh allowing people who are using Interru to stay in control, you know, they're they're in control of exactly what data they're inputting, they're in control of how they read the situation in terms of compliance. So, you know, instead of it replacing, replacing your compliance officer, for example, you know, that it goes hand in hand. Definitely.

Getting Reliable Supplier Data

SPEAKER_00 20:19

One thing we hear a lot about is that supply chain data is fragmented, inconsistent. And I suppose actually this kind of relates to staying in control. From your experiences, what where do you think companies struggle most when trying to gather that reliable data from suppliers from whether they're in, you know, across the world, global. Yes. How do they keep that in in check?

SPEAKER_02 20:44

Have you ever come across Simon Sinek? He wrote about start with why.

SPEAKER_00 20:48

I have not. Like why?

SPEAKER_02 20:50

Anyway, it's this, I think this is the way that I would propose thinking about this. It's rather than like where are the parts that are most difficult? It's why is it difficult? Like, why is this a challenge for suppliers? And so it's like coming back to your point you made about future print and collaboration, those who view buying and selling goods with suppliers as very transactional, purely price-based, are more likely to struggle. Whereas those who help their suppliers to help them, more collaborative, more enabling, more supportive, will find it much, much easier. Um. So I think it gets more challenging. What what we don't want to do, and what we see a slight risk, and we really try and avoid this is hey, I can't buy from Ed, this supplier Ed, because he doesn't, he doesn't like it, he can't give me the information. Ed's got a family to feed. Ed's might be a small holder there, and we don't want to cut you off because you you don't even know why you need to. Give me this information or in what format. That's also bad for EU customers. So not only is it bad for Ed and the source or the suppliers, it's bad for the EU because fewer goods that meet a particular standard, there's more scarcity. You're going to see price inflation increasing on those types of goods. So I think for us, it's always important to help your suppliers understand why they need this to give us this information. What is in it for them? And we hear that a lot with suppliers who we work with, like, oh, this is delivering good, this is helping us. We're saving time when we do it this way. We're spotting risks. There are benefits for us. And they see, yeah, benefits like um better market access and things like that. Um I think the biggest, yeah, and to summarize, I think the biggest challenge with data is people not, it's not not being able to get the data, it's understanding really what is the data I need to get. Because it's there, it it does exist.

SPEAKER_00 22:59

Yeah, and I suppose that's kind of partly what you guys will help with, right? You know, being able to understand exactly exactly what data you need. In terms of uh you you kind of mentioned it there, and I'm just picking up on that, and I'm slightly interested. Do you think this this regulation will potentially drive up prices at all? Do you see foresee anything, any any change within that that kind of area of business?

SPEAKER_02 23:25

We there was a report, and I I can send it to you afterwards. I can't remember who published it, but it was published sometime last year, and they looked at several different commodities, different sizes of businesses, and what the impact was on price for the end consumer. And it came out as something like 0.05% for the for the end consumer. Um I think we are hearing things like we're hearing from EU operators if I would be willing to pay a premium if I can, if I know that that supplier will provide me with this information, well structured, well organized. It hits all the points it needs to hit because it saves me. It's like a value-adding service that the supply provides, and people may be willing to pay a premium for that. So we are seeing a little bit, a little bit of that. I think there was also reports last year of some cocoa products from South America being traded in at an EUDR standard that had that had uh resulted in a slight price premium.

SPEAKER_00 24:26

So it's interesting, you know. I mean, it's it's also a question of ethics, I suppose, you know, at the heart of it is, you know, is is it right for someone to take advantage of of the situation and things like that?

SPEAKER_02 24:42

Yeah, it's hugely problematic. And that's a lot of the criticism is that um is it is it a protectionist policy for the EU where buying EU timber becomes much easier than buying non-EU timber? So yeah, there are all sorts of questions. Again, it comes back to enablement and support. Like you have to support. If this is going to impact global supply chains, you need on-the-ground capacity building all the way back to source.

SPEAKER_00 25:07

It's it's uh it's it's gonna be interesting, yeah. It's macroeconomics. Yeah. Um writ large. Um, I suppose bringing it back to interrupt, obviously, you talk about traceability, we're just talking about traceability as well.

Traceability As Market Entry

SPEAKER_00 25:23

I suppose how can we better understand the supply chain visibility and and will it be a competitive advantage to understanding your supply chain over people who previously might not have known where they were getting their timber from or getting their, you know, cocoa from or whatever? It will there be an advantage to that?

SPEAKER_02 25:49

Um I it might be the other way, Ed. It might be that it becomes basic hygiene. It's the price of market entry, is knowing your products. It's been like that in the food industry and the farmer industry for quite a few years now. Um lots of EUDR commodities are also food and beverage commodities. Uh Easter eggs, for instance. Like so traceability, we we really see a lot of regulations indicating that it will become commonplace. I think it is there already in a lot of sectors, just not necessarily in these commodity sectors that we're working on. I think if you look at some of them, um you think of what I often drive past Grenfell Tower and you look at that and you think of the roles, we're not just talking about printed materials, we're also talking about construction materials and building materials or rubber in tyres for cars. Now, if you don't know where it comes from and you don't have that trust in your suppliers and your supply chain, do you really want to trust that that building material is gonna stand up or that the tires aren't gonna blow out? So for me, yeah, I think it it is competitive advantage, but I think it is also market access and the the price of good it will just become good business to have traceability.

SPEAKER_00 27:10

Yeah. I suppose, you know, uh in in the 21st century, sometimes you have to think maybe good business is the right way of going about our daily lives. You know, we we'll we're we're almost at the end of the tether of just taking advantage and of the world of of people and things like that.

Sustainability And The EU Green Deal

SPEAKER_00 27:31

In terms of you know, sustainability, if we bring it back to that, w how much of an effect do you think this will have on that? How much of an effect do you foresee? Um do you think this this piece of uh legislation will be a step towards you know reducing global warming? Or do you think that it's just a drop in the ocean?

SPEAKER_02 27:58

I think so far the regulations that preceded this didn't do enough. So we're having to do something different and it will take time. I think there is a legal requirement for the impact on deforestation to be assessed at a regular level by the European Commission as a result of this. Um I don't really see EUDR as a standalone piece of legislation. It's part of an EU overall Green Deal package. So you've got other things like CBAM, the carbon border adjustment mechanism, PPWR packaging, waste regulation, CSRD, et cetera. And so it all ties into that. And sitting behind being able to achieve and realize the positive outcomes of such regulations, we see data sitting there. And so what organizations have been asked to do in terms of traceability and data for EUDR is part of what they will need to do. Like if you're building those foundations now, you're saving yourself a job in the future because you will need that for lots of other regulations. And there's already commitment from the commission that the reporting, you don't you wouldn't need to report the same data twice if you fall on in scope of CSR CS triple D and EUDR. You can have one reporting mechanism for that, for instance. Um yeah, so I see it as becoming, like you say, part just part of good business overall.

Final Takeaways And Where To Go

SPEAKER_00 29:26

That's great. I I think hopefully we've been able to establish what EUDR is gonna do and and how it might impact businesses, especially in the print industry. And it's also been great to kind of hear and understand exactly what you guys at IOV42 are doing with with the interru system. So Anna, thank you very much for joining us. Um did you have anything else you wanted to say, mention?

SPEAKER_02 29:52

No, I've enjoyed the conversation. Thank you. Thank you for asking great questions. Um we get we get loads of questions about this, but you ask questions we've not been asked before, so that's always very nice. That's very good.

SPEAKER_00 30:03

I'm very glad. Well, thank you very much for joining us, and um, we'll see you again soon.

unknown 30:08

Cool.

SPEAKER_01 30:08

Thanks, Ed. Thank you for listening. If you enjoyed this episode, you can subscribe now for more great audio content coming up. And visit futureprint.tech for the latest news, partner interviews, in-depth industry research, and to catch up on content from future print events. We'll see you next time on the Futureprint podcast.