Webinar: EUDR – Getting ready to comply with the new EU Deforestation Regulation

00:58:48
https://www.youtube.com/watch?v=bR6_o_h9CpA

Résumé

TLDRThe webinar discusses the European Union Deforestation Regulation (UDR) and its significant impact on companies. It introduces the roles of Sonia Murin and Ani Takala, who are responsible for managing responsible sourcing and the IT implementation of UDR compliance at UPM Raflatac. The UDR was introduced to curb the EU’s contribution to global deforestation, and companies are required to comply by setting up due diligence systems, conducting risk assessments, and creating due diligence statements through the EU's Tracer system. Compliance is mandatory for certain commodities like wood used in paper products, and includes regulations for all products placed on the EU market, whether imported or exported. The regulation requires extensive product traceability and due diligence, although existing stocks and specific exceptions, such as recycled goods, may be exempt. The UDR is not limited to products traded outside the EU. Despite questions regarding the readiness of the Tracer system and clarity on implementation guidelines, the deadline for compliance is set for December 30th. Participants in the webinar were encouraged to engage with their supply chains and review information published by the EU and other knowledgeable third parties for further guidance.

A retenir

  • 🌍 UDR is crucial to combat EU's contribution to global deforestation.
  • 📅 Compliance deadline is December 30th, urging urgent readiness.
  • 🛠️ Establishing a due diligence system is mandatory under UDR.
  • 🔍 Risk assessments and due diligence statements are key processes.
  • 🌲 Wood, especially used in paper, is a major focus of the UDR.
  • 📜 Certifications help but are not sufficient for compliance.
  • 🔄 Recycled materials could be exempt from UDR.
  • 🗂️ Companies need robust data collection systems for traceability.
  • 🔗 UDR affects both imports to and exports from the EU.
  • 🚫 Products already on the market might be exempt from the regulation.

Chronologie

  • 00:00:00 - 00:05:00

    The webinar begins with an introduction and explains the focus on the new European Union Deforestation Regulation (EUDR), aiming to help companies understand its impact. Colleagues Sonia, a responsible sourcing manager, and Anie, a development manager, will discuss different aspects of EUDR compliance, due diligence, and its implementation. A disclaimer mentions that the information shared is based on the current understanding of EUDR, and it's advised to seek additional guidance for legal compliance.

  • 00:05:00 - 00:10:00

    Sonia elaborates on the reasons behind the EU deforestation regulation, highlighting the EU's role as a contributor to global deforestation despite its own increasing forest area. The regulation targets minimizing the EU's impact on worldwide deforestation and forest degradation. It's stated that the regulation aims to mitigate climate change and biodiversity loss, highlighting the need for due diligence in sourcing commodities like wood, to ensure they're deforestation-free and compliant with production legislation.

  • 00:10:00 - 00:15:00

    The speaker highlights that all papers sourced by UPM Raak are now certified under a credible third-party forest certification scheme, a target achieved six years ahead of schedule. They explain that while certifications help comply with EODR requirements, they are not enough on their own. The regulation requires due diligence and compliance with criteria like being deforestation-free, legal production according to country laws, and having a due diligence statement. Operators must conduct due diligence before placing products on the market.

  • 00:15:00 - 00:20:00

    Discussion continues on roles under EUDR such as operators, who must conduct due diligence before selling in the EU market. UPM Raak's focus as explained includes establishing a due diligence system, risk assessment, and implementing risk mitigation measures if needed. Information gathering is crucial in steps like assessing product trade names, scientific names, and quantities. Creating due diligence statements in the EU's TRACES system is emphasized for compliance.

  • 00:20:00 - 00:25:00

    It's further explained that traceability is essential for due diligence statements, needing information about the product, operator, and origin of materials. The interconnected nature of due diligence statements along the supply chain is crucial, referring to prior statements when creating new ones. Emphasis is on confirming that due diligence showed no significant risk, ensuring compliance with EUDR. Questions from participants will be addressed later in the discussion.

  • 00:25:00 - 00:30:00

    The speaker gives a practical view of the supply chain, explaining obligations under EUDR for UPM Raak and their customers, highlighting that obligations differ between upstream and downstream players. Exemptions to compliance include products not in Annex 1 of the regulation or when used as packaging. They advise considering compliance needs based on specific tariff codes and product uses concerning EUDR.

  • 00:30:00 - 00:35:00

    Focusing on practical steps, the speaker advises customers on evaluating their CN codes to determine EUDR obligations. They differentiate between products that require compliance and others exempt under specific conditions, such as when used for packaging or containing recycled fibers. Details on UPM Raak's plan to facilitate compliance for its customers, indicating the importance of due diligence systems and collaboration with suppliers, are shared.

  • 00:35:00 - 00:40:00

    The presentation on technical implementations discusses the development of the UPM system to comply with EUDR, emphasizing the integration of due diligence across the supply chain. The use of EU's TRACES for maintaining a complete path of due diligence reference numbers is detailed, aligning with EU integration. Developments are running parallel to ensure the readiness by year-end. They discuss specific roles and details for the production and dispatch processes related to compliance.

  • 00:40:00 - 00:45:00

    An overview of system development outlines key milestones and areas being addressed for EUDR compliance, highlighting the roles of various UPM business layers. Detailed descriptions of dispatch processes include reference number generation, emphasizing the critical role of UPM's internal systems in aligning with EU TRACES. The focus is on ensuring seamless integration throughout the dispatch stage, validating DDS references through UPM's system layers.

  • 00:45:00 - 00:50:00

    Anie explains UPM Raak's approach to implementing EUDR compliance within their IT infrastructure, detailing the necessary technical developments at each process step. The plan involves readying systems by the end of the year to ensure DDS references flow correctly to customers. Focus is on recording vendor DDS references, integrating them during production, and ensuring correct dispatch processes, facilitated by API connections with EU TRACES.

  • 00:50:00 - 00:58:48

    The questions and answers session covers numerous inquiries about EUDR compliance, clarifying topics like the role of certifications, how due diligence statements will be issued, and the impact of EUDR on supply and trade activities. It emphasizes the importance of understanding specific CN codes, cooperation with manufacturers, and the need for verification through EU-traces. Listeners are advised to stay updated and seek guidance on complexities that may arise.

Afficher plus

Carte mentale

Vidéo Q&R

  • What is the purpose of the European Union Deforestation Regulation (UDR)?

    The UDR aims to minimize the EU's contribution to global deforestation and forest degradation, which are major drivers of climate change and biodiversity loss.

  • When did the European Union Deforestation Regulation come into effect?

    The regulation came into force in June last year, with the transition period concluding on December 30th this year.

  • Which commodities are covered by the UDR?

    Commodities such as wood are covered by the UDR, particularly those used in manufacturing products like paper.

  • How must companies comply with the UDR?

    Companies must establish a due diligence system, gather specific product information, conduct a risk assessment, and create a due diligence statement in the EU's Tracer system.

  • Are certifications like FSC and PEFC enough for complying with UDR?

    No, while certifications help, they are not enough. Companies still need to follow all due diligence processes required by UDR.

  • What exceptions exist under the UDR?

    Recycled materials and products used explicitly for packaging may be exempt from UDR, along with materials not listed in the regulation's annex.

  • Can due diligence statements for existing stock be provided?

    No, due diligence statements cannot be issued for products already on the market before the regulation's enactment.

  • How are due diligence statements verified?

    Verification is done through the EU's Tracer system, using a reference number and verification code.

  • What role do companies play in the UDR's compliance process?

    Companies may act as operators, traders, or authorized representatives, each having their own compliance responsibilities.

  • Is the UDR applicable to non-EU transactions?

    No, the UDR applies to products placed on the EU market, whether imported, exported, or traded within the EU.

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  • 00:00:00
    good day to you all good morning good
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    afternoon and good evening welcome from
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    wherever you are located um I'm very
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    delighted to welcome you to our upm ra
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    rafl webinar on eud the new European
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    Union deforestation
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    regulation if you are here you have
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    either already started to prepare your
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    company for compliance or you're
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    wondering what is all what it is all
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    about and how it may affect you with our
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    webinar today we hope to share
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    information that will support you in
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    your own
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    understanding let's have a short look at
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    our agenda for today I'm here as you can
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    see with my dear colleagues Sonia murin
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    and Ani takala Sonia is our responsible
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    sourcing manager at upm raflatac and she
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    will introduce euda and our approach to
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    to due diligence next I will have a
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    practical look at eodr based on the last
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    months of customer discussion we've had
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    on this topic already Anie who's our
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    development manager for operations
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    solution also heads the upm rafu project
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    on eodr he's leading the it
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    implementation and will share how upm
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    raak approaches eodr for the
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    EU before we close all three of us will
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    be available to answer all of your
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    questions please write your questions in
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    the chat you will find the chat in teams
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    on the top of the window that you're
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    looking at and it should open up on the
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    right side side feel free to share
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    questions already during the
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    presentation as they come
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    up before I hand over to Sonia we have a
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    disclaimer on eodr as it is a legal
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    requirement for the EU the information
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    we share today are based on our current
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    understanding and interpretation of the
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    eodr the EU has not finally answered all
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    open questions and things may change in
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    the coming weeks and months Please be
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    aware that our comments refer to supply
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    of label stock and other selfadhesive
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    products to our direct customers when it
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    comes to our customers and the value
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    chain further Downstream we recommend
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    that you consider your own eodi
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    obligations when selling materials to
  • 00:02:12
    your own customers as it says here we do
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    not offer legal advice or consult on
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    eodr and we recommend that you seek
  • 00:02:19
    guidance also from the EU and
  • 00:02:21
    knowledgeable third parties when it
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    comes to your own
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    compliance but with that let's get right
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    in the thick of it so may I hand over to
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    you yes and thank you Vera and welcome
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    all on my behalf to this webinar about
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    UDR I will tell you a little bit about
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    the EU deforestation regulation and our
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    approach to due
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    diligence the reason why this regulation
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    was created is that EU as a region is a
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    major contributor to
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    deforestation even though its own forest
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    area has been
  • 00:03:07
    increasing from the chart you can see
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    that the forest area in Europe has grown
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    by 9% over the past 30
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    years however EU consumption remains a
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    major Global driver of deforestation and
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    Forest
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    degradation Global deforestation means
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    deforestation taking place
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    worldwide due to the conversion of
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    forest to land of agricultural use
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    whether human included or
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    not Forest degradation under the
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    regulation means the conversion of
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    certain types of forest into other kinds
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    of forest other than wooded
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    land it has been estimated that without
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    this regulation the Union's consumption
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    and production of just six Commodities
  • 00:04:01
    alone would result in the deforestation
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    of
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    248,000 hectares per year which is
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    equivalent to the size of Sara Island in
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    Estonia or two times the size of the
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    city of
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    Rome this regulation aims to minimize
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    the eu's contribution to Global
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    deforestation and Forest degradation
  • 00:04:27
    which are among the main drivers of
  • 00:04:30
    climate change and biodiversity
  • 00:04:33
    loss the goal behind eud is important
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    and we fully support its aim to create a
  • 00:04:39
    positive
  • 00:04:47
    impact we can move to next
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    slide okay so here I'm happy to
  • 00:04:54
    highlight the achievement that we made
  • 00:04:57
    in the beginning of this year
  • 00:05:00
    all papers sourced by upm raak are now
  • 00:05:03
    certified under a credible thirdparty
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    Forest certification
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    scheme having all papers certified was
  • 00:05:11
    one of upm raf's 2030 responsible
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    sourcing and climate targets which has
  • 00:05:18
    now been achieved six years ahead of
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    time while certified papers help us
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    comply with eodr requirements having
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    certifications and certified products
  • 00:05:31
    alone is not enough to comply with eodr
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    requirements therefore certifications
  • 00:05:38
    are not a Green Lane or a free pass when
  • 00:05:42
    it comes to UDR
  • 00:05:50
    compliance so the goal of this
  • 00:05:53
    regulation is to hold and reverse EU
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    driven Global
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    deforestation based on mandatory due
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    diligence the reg regulation came into
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    force in June last year and we are now
  • 00:06:08
    nearing the end of the transition period
  • 00:06:12
    which concludes on December 30th this
  • 00:06:15
    year after December 13th it will be
  • 00:06:20
    prohibited to place relevant products on
  • 00:06:23
    the EU Market or export them unless they
  • 00:06:26
    meet the following criteria
  • 00:06:30
    they are deforestation
  • 00:06:32
    free they have been produced in
  • 00:06:35
    accordance with the relevant legislation
  • 00:06:37
    of the country of
  • 00:06:39
    production and they are covered by a due
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    diligence
  • 00:06:43
    statement anex one of the regulation
  • 00:06:47
    lists all the Commodities covered by the
  • 00:06:50
    regulation and for us wood is the
  • 00:06:54
    relevant commodity
  • 00:07:01
    I would like to briefly show you the
  • 00:07:03
    different roles companies can have under
  • 00:07:05
    the
  • 00:07:06
    UDR for us the most relevant role is the
  • 00:07:11
    operator operators are responsible for
  • 00:07:14
    conducting due diligence before placing
  • 00:07:17
    products on the EU Market or exporting
  • 00:07:21
    them additionally operators must create
  • 00:07:24
    a due diligence statement in the eu's
  • 00:07:27
    Tracy system
  • 00:07:29
    and this due digent statement has a
  • 00:07:32
    reference number that is then provided
  • 00:07:34
    to our
  • 00:07:35
    customers but an will explain more about
  • 00:07:39
    this process
  • 00:07:41
    shortly besides the operator role there
  • 00:07:45
    are also Trader and authorized
  • 00:07:47
    representative roles but the
  • 00:07:50
    responsibilities in most roles are quite
  • 00:07:52
    similar
  • 00:08:01
    in order to comply with eodr
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    requirements we need to establish a due
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    diligence system as outlined in article
  • 00:08:10
    8 of the
  • 00:08:13
    regulation we must exercise due
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    diligence before placing relevant
  • 00:08:17
    products on the EU Market or exporting
  • 00:08:20
    them from the
  • 00:08:23
    EU so how to carry out due
  • 00:08:27
    diligence firstly we need need to gather
  • 00:08:30
    information as specified in the
  • 00:08:33
    regulation for example trade name full
  • 00:08:36
    scientific name of the wood and quantity
  • 00:08:39
    of the product in
  • 00:08:40
    kilograms just to mention
  • 00:08:43
    few secondly we need to conduct a risk
  • 00:08:48
    assessment and if the result indicates
  • 00:08:51
    no risk or only negligible risk we can
  • 00:08:54
    proceed to place the relevant uh
  • 00:08:57
    products on the market or export it
  • 00:09:01
    however
  • 00:09:06
    if and higher than
  • 00:09:09
    NE we need to implement risk mitigation
  • 00:09:12
    measures if after implementing these
  • 00:09:15
    measures we achieve no risk or only
  • 00:09:18
    negligible risk we can proceed to place
  • 00:09:21
    the product on the market or export it
  • 00:09:31
    as I mentioned previously we need to
  • 00:09:33
    create due diligence statements in the
  • 00:09:36
    Tracy system when selling Goods in the
  • 00:09:39
    EU or exporting them from the
  • 00:09:42
    EU Annex two of the regulation outlines
  • 00:09:46
    the information required in these
  • 00:09:50
    statements there need to be information
  • 00:09:52
    about the
  • 00:09:55
    operator also product information
  • 00:09:58
    including the CM code trade name full
  • 00:10:01
    scientific name of the wood and quantity
  • 00:10:03
    of the product in
  • 00:10:05
    kilograms also there need to be
  • 00:10:08
    traceability info including the country
  • 00:10:10
    of production and geolocations of the
  • 00:10:13
    harvested
  • 00:10:14
    wood this information is included in the
  • 00:10:17
    first due d statement created by the
  • 00:10:21
    first player in the value chain within
  • 00:10:23
    the
  • 00:10:24
    EU after that the traceability
  • 00:10:27
    information flows through the value
  • 00:10:29
    chain VI are linked du diligent
  • 00:10:32
    statements so in cases where our
  • 00:10:36
    suppliers have already created due
  • 00:10:38
    diligence statements we need to refer to
  • 00:10:40
    these statements when creating our own
  • 00:10:44
    statement lastly we need to confirm that
  • 00:10:48
    due diligence has been carried out and
  • 00:10:51
    no or only eligible risk was
  • 00:10:56
    found that was all from my side and
  • 00:11:00
    thank you for
  • 00:11:04
    listening thank you Sonia so now you've
  • 00:11:08
    heard what Udi is all about and I've
  • 00:11:09
    seen that questions have already come in
  • 00:11:11
    we'll address them in the end as said um
  • 00:11:14
    that's what it's all about and how we
  • 00:11:15
    approach the regulation I will now have
  • 00:11:18
    a bit more practical look when it comes
  • 00:11:20
    to label stock and other selfes of
  • 00:11:22
    products so what are things that you may
  • 00:11:24
    want to consider yourselves um when you
  • 00:11:26
    plan the next steps regarding eodr
  • 00:11:28
    compliance
  • 00:11:32
    so here you see an example of what a
  • 00:11:35
    value chain where upm ra attack is in
  • 00:11:36
    the middle kind of looks like with both
  • 00:11:38
    up and downstream companies Upstream
  • 00:11:41
    this is probably the shortest value
  • 00:11:43
    chain possible with only three steps the
  • 00:11:46
    forest where the wood is grow where the
  • 00:11:47
    wood grows uh that is then being used to
  • 00:11:50
    produce pulp which in turn is used for
  • 00:11:51
    paper production and the papers can then
  • 00:11:54
    become part of a uper ra product that
  • 00:11:57
    will resell to you
  • 00:12:01
    we are a manufacturer of label stock and
  • 00:12:02
    Other Self adesive products and while
  • 00:12:05
    Upstream value chain players have their
  • 00:12:07
    own obligations under eodr it's not
  • 00:12:09
    sufficient for us to refer to their to
  • 00:12:12
    those players being compliant we have
  • 00:12:14
    our own compliance obligations like
  • 00:12:16
    Sonia explained before and that's the
  • 00:12:19
    same for the downstream value chain as a
  • 00:12:21
    customer of ours you may convert and or
  • 00:12:24
    print a product subject to eodr and your
  • 00:12:27
    own sales transactions are likely on Al
  • 00:12:29
    subject to UDR
  • 00:12:30
    compliance it is very likely not
  • 00:12:32
    sufficient for you to rely on our
  • 00:12:35
    compliance and our reference number but
  • 00:12:38
    there are cases where the compliance
  • 00:12:40
    requirement ends at rafl and it may also
  • 00:12:42
    end at you at our customers
  • 00:12:45
    straightforward example before we go
  • 00:12:47
    into more details um examples exempt
  • 00:12:50
    from compliance are products not covered
  • 00:12:52
    in nx1 of the regulation that um Sonia
  • 00:12:56
    just mentioned so those CN codes and
  • 00:12:57
    we'll get to more details and then
  • 00:12:59
    secondly products that are used as
  • 00:13:01
    packaging not packaging products or
  • 00:13:04
    products intended to be used for
  • 00:13:05
    packaging later but when they are used
  • 00:13:06
    as packaging but let's have a more
  • 00:13:08
    detailed look at exactly
  • 00:13:10
    that so what are practical things to
  • 00:13:14
    consider related to euda Let's address a
  • 00:13:16
    couple of topics on this
  • 00:13:18
    slide first as a customer if you for
  • 00:13:22
    example print and convert label stock
  • 00:13:24
    into labels you may use the same or
  • 00:13:26
    similar tariff codes CN codes tariff of
  • 00:13:29
    codes and um that we do then when you
  • 00:13:32
    sell printed labels and this indicates
  • 00:13:35
    that you may have a compliance
  • 00:13:36
    requirement to fulfill under
  • 00:13:38
    eodr however if a label is used on a
  • 00:13:41
    package and the filled package is sold
  • 00:13:43
    the packaging itself may be exempt from
  • 00:13:46
    UDR compliance at that stage as an
  • 00:13:48
    example think of a raack shipment the
  • 00:13:51
    products you receive may be subject to
  • 00:13:53
    eodr but the pellets which the products
  • 00:13:56
    are delivered on are not at least they
  • 00:13:59
    are not when we use them as packaging
  • 00:14:01
    they are subject to UDR further up in
  • 00:14:03
    the value
  • 00:14:04
    chain when it comes to you our customers
  • 00:14:07
    and also your own customers for example
  • 00:14:09
    brands or retailers we receive a lot of
  • 00:14:11
    questionnaires that you forward for eodr
  • 00:14:15
    the EU system the so-called traces
  • 00:14:17
    system as Sonia said that is the vehicle
  • 00:14:19
    where compliance is shown and this is
  • 00:14:21
    where the due diligence statements need
  • 00:14:23
    to be issued that's where they live and
  • 00:14:25
    that's where they connect to each other
  • 00:14:27
    we can share reference numb to due
  • 00:14:29
    diligence statements with you and you
  • 00:14:32
    may share those with you may share those
  • 00:14:34
    further if there's no uh requirement for
  • 00:14:37
    you to be compliant um but basically if
  • 00:14:41
    you need to be compliant you need to
  • 00:14:42
    create your own due diligence as well
  • 00:14:44
    because we don't have a direct Supply
  • 00:14:46
    relationship with your customers and we
  • 00:14:48
    seek to provide the desired information
  • 00:14:50
    under
  • 00:14:51
    UDR um but we would like to avoid
  • 00:14:54
    building a duplicate information stream
  • 00:14:56
    separate of UDR requirements
  • 00:14:59
    with that let come to the second topic
  • 00:15:01
    getting even more practical in the
  • 00:15:03
    middle of it which projects which
  • 00:15:06
    products are subject to
  • 00:15:07
    UDR Sonia mentioned anex one of the
  • 00:15:10
    regulation anx one gives so-called CN
  • 00:15:14
    codes CN codes for Combined nen n
  • 00:15:17
    nomenclature these are called also
  • 00:15:19
    tariff codes or HS codes and nx1 States
  • 00:15:23
    those codes which are subject to eodr
  • 00:15:26
    these are related to the seven
  • 00:15:27
    Commodities Sonia mentioned and the main
  • 00:15:29
    one for rafl is Wood related to wood for
  • 00:15:33
    European raflatac all products falling
  • 00:15:35
    into the category starting with 48 are
  • 00:15:38
    subject to eodr 48 is the category for
  • 00:15:41
    paper and paper board and in that case
  • 00:15:43
    for example selfes of labels of paper
  • 00:15:46
    have a subcategory in that
  • 00:15:48
    area this also means that only products
  • 00:15:51
    with a CN code of 48 will receive due
  • 00:15:54
    diligence
  • 00:15:55
    statements these are typically materials
  • 00:15:58
    made from wood fibers so in label stock
  • 00:16:00
    it means materials with a paper face in
  • 00:16:02
    the
  • 00:16:04
    lemonade what that means in turn is that
  • 00:16:07
    label stock with a film face material is
  • 00:16:10
    not in this 48
  • 00:16:12
    category the category for film label
  • 00:16:14
    stock is usually
  • 00:16:15
    39 and thus not subject to
  • 00:16:18
    UDR this is even true when the film
  • 00:16:21
    lemonade has a glass scene or craft
  • 00:16:24
    paper liner the paper liners are subject
  • 00:16:27
    to eodr but further Upstream in the
  • 00:16:29
    value chain so as as we buy those papers
  • 00:16:32
    for example but not at the point of
  • 00:16:34
    sales when we deliver film label stock
  • 00:16:36
    to our customers to
  • 00:16:38
    you so what you see here also are two
  • 00:16:41
    exceptions related to eodr the first one
  • 00:16:45
    if material is used as packaging in our
  • 00:16:48
    understanding e does not apply there was
  • 00:16:50
    the pellet example I gave earlier
  • 00:16:53
    another example is when print when a
  • 00:16:55
    printed paper label is applied to an
  • 00:16:57
    e-commerce package being sent or a Home
  • 00:16:59
    Care bottle of laundry detergent to be
  • 00:17:01
    sold in that case there is an exception
  • 00:17:04
    under
  • 00:17:05
    eodr the second exception if the paper
  • 00:17:08
    is subject to eud and it contains
  • 00:17:10
    recycled fibers the UDR does not apply
  • 00:17:14
    recycled fibers are considered kind of
  • 00:17:16
    born in the recycling stage and they are
  • 00:17:19
    not traced back to the forest origin
  • 00:17:21
    that would also be practically pretty
  • 00:17:22
    impossible if a paper contains both
  • 00:17:25
    recycled and virgin fibers the UDR
  • 00:17:28
    requirement does apply to the Virgin
  • 00:17:30
    fibers
  • 00:17:33
    only and with that our third Topic in
  • 00:17:36
    this practical
  • 00:17:38
    look as rafl Tu we are building a system
  • 00:17:42
    to share needed information for
  • 00:17:44
    compliance with our customers with you
  • 00:17:46
    when it comes to deliveries within the
  • 00:17:48
    European Union when we deliver into the
  • 00:17:51
    EU or we deliver out of the EU Andy will
  • 00:17:54
    share more details on how we plan to do
  • 00:17:56
    this for our scar UK site this means
  • 00:18:01
    that we will create due diligence
  • 00:18:02
    statements when delivering from there to
  • 00:18:04
    EU customers we also plan to do the same
  • 00:18:08
    for deliveries from scabo to non-eu
  • 00:18:11
    countries like UK or
  • 00:18:13
    Switzerland however the EU has not yet
  • 00:18:16
    clarified whether this will be
  • 00:18:17
    sufficient then for you as our customer
  • 00:18:21
    not in the EU to import to the EU in the
  • 00:18:24
    next step of the value
  • 00:18:26
    chain deliveries from other RAF sites
  • 00:18:29
    outside of the EU to customers outside
  • 00:18:32
    of the EU are not subject to
  • 00:18:35
    eodr and it's not possible to create due
  • 00:18:37
    diligence statements in the EU Tracer
  • 00:18:40
    system if you are a customer for example
  • 00:18:42
    in North America or in Asia Pacific you
  • 00:18:45
    receive products from upm Raff tuch
  • 00:18:47
    there might be EU involvement further
  • 00:18:50
    down the value chain please remember the
  • 00:18:52
    exceptions from earlier 48 CN code and
  • 00:18:56
    the packaging exception if you see that
  • 00:18:59
    despite this there will be an UDR
  • 00:19:01
    compliance requirement please contact
  • 00:19:03
    your sales representative and share
  • 00:19:05
    product details and case information as
  • 00:19:08
    this is the regulation from the European
  • 00:19:10
    Union not all of our Global suppliers
  • 00:19:13
    are ready to share necessary information
  • 00:19:15
    if it's outside of the EU so please get
  • 00:19:17
    in touch with your main contact at
  • 00:19:19
    raflatac and we look at those
  • 00:19:22
    cases few I already I'm sure it fused
  • 00:19:25
    like a lot already with all this
  • 00:19:26
    information so finally
  • 00:19:29
    what are the next steps that you can now
  • 00:19:31
    take especially if you haven't
  • 00:19:32
    considered eudi yet and you know that
  • 00:19:34
    you have deliveries related to the
  • 00:19:38
    EU if you have EU related transactions
  • 00:19:41
    we recommend that you consider
  • 00:19:44
    identifying the CN codes of the products
  • 00:19:46
    that you sell do they even fall under
  • 00:19:48
    the regulation
  • 00:19:50
    nx1 secondly you may also want to
  • 00:19:53
    clarify your role as Sonia explained
  • 00:19:55
    them earlier if you determine that you
  • 00:19:57
    have an EU Diablo
  • 00:19:59
    obligation then thirdly you may want to
  • 00:20:02
    consider how you can establish a due
  • 00:20:04
    diligence system especially involving
  • 00:20:05
    your it Department to work with the EU
  • 00:20:08
    Tracer system much like what an an is
  • 00:20:10
    going to explain later for
  • 00:20:12
    raak and finally you may want to create
  • 00:20:15
    awareness among all of your suppliers
  • 00:20:17
    because there are still companies
  • 00:20:18
    unaware of eodr and they haven't set
  • 00:20:21
    anything into action yet so it's always
  • 00:20:23
    good to then inform the Upstream value
  • 00:20:25
    chain of those topics
  • 00:20:31
    and now I have the pleasure to hand over
  • 00:20:32
    to Anie who will take a look with you at
  • 00:20:35
    the it implementation of UDR related to
  • 00:20:37
    the
  • 00:20:38
    EU thank you Vera and hello
  • 00:20:42
    everyone I'll insights of the eud
  • 00:20:46
    related developments ubm rafl is is
  • 00:20:49
    currently running in parallel with ubm
  • 00:20:51
    and and European
  • 00:20:54
    Union um let's take a look of this U
  • 00:20:58
    complic ated looking slide um on the
  • 00:21:00
    left is the starting point of a
  • 00:21:03
    multi-step supply chain where
  • 00:21:05
    geolocations of harvested wood are are
  • 00:21:08
    recorded upm Brock is is part of this
  • 00:21:11
    chain where every step needs to do their
  • 00:21:13
    own share in fulfilling the EU
  • 00:21:16
    regulation this means development in in
  • 00:21:18
    multiple
  • 00:21:20
    places technical key for f fulfilling
  • 00:21:24
    the EU regulation is the uh due
  • 00:21:26
    diligence statement and DDS for short
  • 00:21:29
    and more precisely DDS reference numbers
  • 00:21:32
    delivered through the supply chain every
  • 00:21:35
    Link in the chain receives DDS
  • 00:21:38
    references from their vendor and then
  • 00:21:40
    uses receed products with the respective
  • 00:21:44
    references in production
  • 00:21:46
    process rafl will do exactly this we
  • 00:21:49
    receive the reference numbers from our
  • 00:21:51
    vendors with raw material deliveries and
  • 00:21:54
    then when we ship onwards to you we will
  • 00:21:56
    again generate new reference number
  • 00:21:59
    the reference numbers are created in in
  • 00:22:02
    European Union tool called traces which
  • 00:22:05
    is under development at the moment we
  • 00:22:07
    will call EU traces from rafl internal
  • 00:22:11
    Mill execution system and request DDS
  • 00:22:14
    references at the time of of shipment to
  • 00:22:17
    you the call to traces will go through a
  • 00:22:20
    common upm integration
  • 00:22:22
    layer as a result EU traces will have a
  • 00:22:26
    complete link path from Goods you
  • 00:22:28
    receive from us to geolocations of
  • 00:22:31
    harvested wood in the example
  • 00:22:34
    illustration shown here rafl has
  • 00:22:36
    delivered Goods to a customer and
  • 00:22:39
    created reference number 15 for the
  • 00:22:41
    shipment this reference number 15 has
  • 00:22:44
    linked reference numbers 11 12 and 13
  • 00:22:48
    those Raff has received from
  • 00:22:51
    vendors and so path continues all the
  • 00:22:54
    way to geolocations of harvested
  • 00:22:57
    wood next
  • 00:22:59
    let's take a look of a high level
  • 00:23:01
    development plan we
  • 00:23:05
    have uh turning the previous picture
  • 00:23:07
    upside down we have European Union at
  • 00:23:10
    top uh EU is developing Tracy system as
  • 00:23:13
    we speak at the moment we have access to
  • 00:23:16
    a test system and the final production
  • 00:23:19
    system is said to be available in
  • 00:23:21
    December one step down is um upm eodr
  • 00:23:25
    project which is developing common
  • 00:23:28
    function alties for all all UPN
  • 00:23:30
    businesses including rafl for today's
  • 00:23:33
    topic most important is the API to
  • 00:23:36
    traces which will enable us to get the
  • 00:23:39
    DS
  • 00:23:40
    references and last but not least of
  • 00:23:43
    course is the ubm rafl project itself
  • 00:23:46
    covering the rafl specific
  • 00:23:49
    functionalities as with the with with
  • 00:23:52
    the two up
  • 00:23:53
    layers our build work is ongoing first
  • 00:23:57
    building blocks have been tested Ted and
  • 00:23:59
    we are moving onwards in development
  • 00:24:01
    work all developments share the same
  • 00:24:04
    ultimate Target and be ready by the end
  • 00:24:07
    of this
  • 00:24:08
    year moving on from this high level
  • 00:24:12
    timeline to a more details on raak
  • 00:24:15
    system development itself here you can
  • 00:24:17
    see a rafl production site you our
  • 00:24:22
    customers are on the right you have
  • 00:24:24
    placed an order and we will produce the
  • 00:24:27
    goods and send them to you
  • 00:24:29
    during the dispatching process executed
  • 00:24:31
    in our Mees system we will call EU
  • 00:24:35
    traces through a upm integration layer
  • 00:24:38
    and generate DDS reference
  • 00:24:40
    numbers the reference numbers will be
  • 00:24:43
    included into shipping list and shipment
  • 00:24:46
    EDI messages EDI messages are using
  • 00:24:49
    papet standard and papet has already
  • 00:24:53
    implemented necessary schema changes for
  • 00:24:55
    eodr purpose
  • 00:24:58
    I have all the time spoken about
  • 00:25:00
    reference numbers and indeed there will
  • 00:25:03
    be two numbers we deliver to you the
  • 00:25:06
    actual DDS reference number and a
  • 00:25:08
    verification number you can see examples
  • 00:25:12
    of those numbers in the Box on the right
  • 00:25:14
    hand side of the
  • 00:25:16
    slide these examples are created in EU
  • 00:25:20
    traces test system and do not refer to
  • 00:25:23
    any live case but you get the idea how
  • 00:25:25
    the reference numbers will look like
  • 00:25:28
    the shipment with two mentioned
  • 00:25:31
    reference numbers is the visible part
  • 00:25:33
    for you before that can happen we have
  • 00:25:36
    run through a normal material receiving
  • 00:25:39
    and production
  • 00:25:40
    processes during material receiving we
  • 00:25:43
    will record and validate DDS references
  • 00:25:47
    we get from our vendors validation
  • 00:25:50
    happens through that upm integration
  • 00:25:53
    layer production process is the final
  • 00:25:56
    block connecting both ends of together
  • 00:26:00
    needless to say this is a very critical
  • 00:26:02
    step you can think it as a engine of the
  • 00:26:05
    whole thing we will continue using our
  • 00:26:09
    existing in-house production data
  • 00:26:11
    tracing the tracing functionality itself
  • 00:26:14
    does not require any changes we will
  • 00:26:16
    simply use what we already
  • 00:26:19
    have and as summary we are working in
  • 00:26:22
    multiple process touch points at the
  • 00:26:25
    moment firstly in receiving to be a able
  • 00:26:28
    to record vendor provided DDS references
  • 00:26:31
    for later use and in in addition to
  • 00:26:33
    recording validate them
  • 00:26:36
    also secondly in integration to EU
  • 00:26:40
    traces via upm integration layer to get
  • 00:26:43
    the due diligence statements created and
  • 00:26:46
    DDS reference numbers available and
  • 00:26:49
    lastly in dispatching to be able to send
  • 00:26:51
    you DDS references with every shipment
  • 00:26:55
    hope this gives you an idea what eodr
  • 00:26:57
    means to raak from system development
  • 00:27:00
    perspective Target is the end of the
  • 00:27:03
    year thank
  • 00:27:08
    you thank you
  • 00:27:11
    Anie I hope we could already provide
  • 00:27:13
    useful insights and information to all
  • 00:27:16
    of you we can now use remaining time to
  • 00:27:18
    answer your questions I see they're
  • 00:27:20
    coming in plenty so we're going to pick
  • 00:27:22
    all of those up as one reminder if you
  • 00:27:24
    haven't done sh if you haven't shared
  • 00:27:26
    any questions yet you can share the
  • 00:27:27
    question in the chat you should use the
  • 00:27:29
    option on the top of the webinar window
  • 00:27:31
    with a uh where you can open the chat
  • 00:27:32
    and then on the right side you can type
  • 00:27:34
    those questions before I kick off the
  • 00:27:36
    Q&A like to remind you of uh of kind of
  • 00:27:40
    the legal disclaimer from the beginning
  • 00:27:41
    so information we share today and we
  • 00:27:43
    comment on your questions of course is
  • 00:27:45
    based on our current understanding and
  • 00:27:46
    interpretation of eodr we cannot offer
  • 00:27:49
    legal advice or consult on eodr and we
  • 00:27:51
    recommend you seek guidance also from
  • 00:27:53
    the EU and knowledgeable third parties
  • 00:27:55
    and I can see that some of you asking
  • 00:27:56
    the questions have already started doing
  • 00:27:58
    that as well so finally let's have a
  • 00:28:01
    look at the questions I'm going to move
  • 00:28:03
    the questions now in my view so I can
  • 00:28:05
    see them and then let me start I will go
  • 00:28:09
    actually I will go top down now um and
  • 00:28:12
    then of course feel free to add on I
  • 00:28:13
    think some questions we may have
  • 00:28:14
    answered already through the webinar as
  • 00:28:16
    well but I think it's still good to
  • 00:28:17
    repeat as this is such a complex topic
  • 00:28:21
    um Sonia the first question to you um
  • 00:28:24
    could you reiterate again is UDR kind of
  • 00:28:27
    uh how is it it related to FSC and PFC
  • 00:28:29
    and do they still need UDR compliance if
  • 00:28:32
    certification is in
  • 00:28:34
    place yes so the certifications help us
  • 00:28:38
    to comply with eodr but it's not enough
  • 00:28:42
    so if you have a certification it
  • 00:28:44
    doesn't help much with eodr so basically
  • 00:28:47
    you also need to implement all the
  • 00:28:50
    details we have described here but uh
  • 00:28:53
    when you need to create these risk M
  • 00:28:56
    mitigation procedures um the
  • 00:28:58
    certifications will help you with
  • 00:29:01
    those great thank you and then building
  • 00:29:05
    on that Sonia also for you um there's uh
  • 00:29:08
    one listener that asks what sort of risk
  • 00:29:11
    and then another one that asks what is a
  • 00:29:13
    risk and what risk mitigation procedures
  • 00:29:15
    can be implemented could you have a a
  • 00:29:17
    take at that yeah um if we want to go
  • 00:29:22
    back to the slide
  • 00:29:24
    eight yes if it's possible yes
  • 00:29:29
    I'm going to do a quick jump
  • 00:29:34
    through okay so here in the middle you
  • 00:29:38
    see that all the products that we place
  • 00:29:40
    into the EU Market they need to be um
  • 00:29:43
    deforestation free they need to have
  • 00:29:47
    been produced in accordance with the
  • 00:29:49
    relevant legislation of the country of
  • 00:29:52
    production and they need to be covered
  • 00:29:55
    with this due diligence statement so the
  • 00:29:57
    risk is really related to these three
  • 00:29:59
    pillars over here so basically we need
  • 00:30:02
    to make sure that um the products that
  • 00:30:06
    we are purchasing from our suppliers and
  • 00:30:09
    what we are placing in the
  • 00:30:11
    market um these three pillars are
  • 00:30:13
    covered and there are no risk related to
  • 00:30:19
    these and about the uh measures how you
  • 00:30:22
    can mitigate the risk um UDR the
  • 00:30:26
    regulation States
  • 00:30:28
    um that you need to gather information
  • 00:30:32
    about your supplier and about the
  • 00:30:34
    products and so forth but otherwise it's
  • 00:30:37
    up to companies to decide what to do and
  • 00:30:40
    how to check your own suppliers and
  • 00:30:43
    mitigate the
  • 00:30:48
    risks thank you
  • 00:30:50
    Sonia let me find my chat window again
  • 00:30:53
    one second now okay good then the next
  • 00:30:57
    question an like to share to you
  • 00:31:00
    um will we will you issue this uh this
  • 00:31:03
    statement for each supplied batch if you
  • 00:31:05
    could go just kind of reiterate what you
  • 00:31:07
    said on that yes simple answer is yes um
  • 00:31:10
    when we ship out a batch of goods we
  • 00:31:13
    call it shipment and you get the uh
  • 00:31:16
    shipment paperwork then that will
  • 00:31:17
    include one DDS reference or well two
  • 00:31:21
    numbers so one set of these
  • 00:31:23
    numbers thank you and that means per
  • 00:31:25
    shipment it can be multiple products if
  • 00:31:27
    you order multiple products that
  • 00:31:29
    shipment will that DDS reference number
  • 00:31:30
    will cover multiple products as well yes
  • 00:31:33
    correct good and then the next one is
  • 00:31:37
    now back to um the this is more
  • 00:31:40
    verification of the DDS so either Anya
  • 00:31:42
    an or Sonia how does your customer do
  • 00:31:45
    verification of the DDS by upm so I'm
  • 00:31:48
    not quite sure if it now means that how
  • 00:31:50
    do we verify as rafl attack or how do
  • 00:31:51
    our customers verify the DDS so
  • 00:31:54
    something I can try to answer I'm
  • 00:31:57
    understand in the question so that when
  • 00:31:59
    we send a DDS references to our customer
  • 00:32:03
    then how do they verify them that they
  • 00:32:05
    are good and I I know two means either
  • 00:32:08
    you you Lo on directly into the uh EU
  • 00:32:12
    provided traces system and check the
  • 00:32:15
    numbers from there or then you use a API
  • 00:32:20
    call from your own system to the um EU
  • 00:32:24
    traces and uh use the functionality in
  • 00:32:26
    there but the verification is anyway it
  • 00:32:30
    has to happen in the EU Tracy
  • 00:32:33
    system good thank you an so then the
  • 00:32:36
    next question is what if product is
  • 00:32:38
    based on recycled raw material is it in
  • 00:32:40
    scope of UDR or not so when it comes to
  • 00:32:42
    recycled content recycled fibers are
  • 00:32:45
    considered born in the recycling stream
  • 00:32:48
    and they're not traced back to the
  • 00:32:49
    origin of the wood remember that
  • 00:32:51
    recycled fibers could also be multiple
  • 00:32:53
    times recycled and it's clearly
  • 00:32:55
    impossible to actually Trace that back
  • 00:32:57
    so recycled content is an exception from
  • 00:33:00
    eodr obligation but if there's a paper
  • 00:33:03
    that includes both virgin and recycled
  • 00:33:06
    content um the Virgin content underlies
  • 00:33:08
    requirements of the eudi as
  • 00:33:11
    well and then that's I think the
  • 00:33:13
    question we probably most anticipated
  • 00:33:15
    would be coming there's information
  • 00:33:17
    about possible postponed of of EU drr
  • 00:33:19
    and do you have more information on this
  • 00:33:21
    and then I saw another one we've heard
  • 00:33:23
    that South American authorities and also
  • 00:33:25
    German ministers have sent a letter to
  • 00:33:27
    EU Commission to ask to postpone the
  • 00:33:28
    introduction date for 6 months and
  • 00:33:30
    there's still no instructions published
  • 00:33:32
    and most companies are not ready and
  • 00:33:34
    that's a very fair question it's a
  • 00:33:36
    question that we kind of ask the same
  • 00:33:38
    way um we've heard probably the same
  • 00:33:40
    rumors as you have we have the same
  • 00:33:42
    access to EU websites as you have um we
  • 00:33:47
    still operate under the assumption that
  • 00:33:48
    it's going to go live from from the 30th
  • 00:33:51
    of December and we plan accordingly but
  • 00:33:54
    it may be that there is a postponement
  • 00:33:56
    coming but we just don't no so we are
  • 00:33:58
    preparing accordingly and we also feel
  • 00:34:01
    that while even if there's a postponed
  • 00:34:03
    it will only come later as a requirement
  • 00:34:05
    so the only chance that there is for us
  • 00:34:07
    and also you is take more time to get
  • 00:34:09
    all the ducks in a row basically to
  • 00:34:11
    prepare for
  • 00:34:14
    this then uh question for um Anie we've
  • 00:34:18
    covered that but let's take it again
  • 00:34:19
    just to make sure how will we receive
  • 00:34:21
    the reference codes on the invoice line
  • 00:34:24
    by line by EDI by
  • 00:34:26
    mail yeah repeat the previous answer
  • 00:34:29
    then uh the uh reference numbers will
  • 00:34:33
    come with the shipment paperwork and
  • 00:34:35
    with the EDI uh for for those customers
  • 00:34:38
    where we have the EDI connection running
  • 00:34:40
    so both cases and there will be one
  • 00:34:43
    number per shipment so as ver you were
  • 00:34:45
    commenting already if there are multiple
  • 00:34:47
    products then that one number will cover
  • 00:34:50
    all of those products sounds good then
  • 00:34:53
    the next question forgive me I will skip
  • 00:34:55
    because that I think goes in the ex the
  • 00:34:56
    same direction um I will later on also
  • 00:34:59
    share the link to the um FAQ that goes
  • 00:35:01
    on our website that will also go again
  • 00:35:03
    in the reference number and show also an
  • 00:35:05
    example again of the reference number
  • 00:35:06
    that was on the slides so you will see
  • 00:35:08
    that the the reference number and then
  • 00:35:10
    the verification number um and in terms
  • 00:35:13
    of the for the postponement earlier so
  • 00:35:16
    yes the EU has actually promised to
  • 00:35:19
    adjust the uh Q&A that they did earlier
  • 00:35:22
    this year but they've never updated that
  • 00:35:24
    and we are still waiting for those
  • 00:35:25
    practical instructions from EU side as
  • 00:35:27
    well and I think there's now more
  • 00:35:29
    pressure building from various
  • 00:35:31
    governments and various associations to
  • 00:35:33
    the EU to actually publish those rules
  • 00:35:35
    as
  • 00:35:37
    well so um what's the next here what are
  • 00:35:40
    obligations as a brand owner that is
  • 00:35:43
    buying in an eodr relevant material but
  • 00:35:45
    then sells a product that is not in
  • 00:35:47
    scope of
  • 00:35:50
    eodr so if you're if you sell a product
  • 00:35:52
    that's not in scope of eodr you won't
  • 00:35:55
    have to do any due diligence because
  • 00:35:57
    then the D diligence if that used to be
  • 00:35:59
    earlier in the value chain the due
  • 00:36:00
    diligence stops before you then actually
  • 00:36:02
    sell that product onwards depending on
  • 00:36:05
    what the details are you may consider a
  • 00:36:07
    difference between EU or non-e location
  • 00:36:09
    of where you're selling from um is there
  • 00:36:11
    a need to provide anything but if
  • 00:36:13
    something's not subject to eud you don't
  • 00:36:15
    need to provide any details under UDR
  • 00:36:18
    either further down the value chain you
  • 00:36:20
    might get inquiries but that depends a
  • 00:36:22
    little bit on how the value chain then
  • 00:36:26
    looks then um in terms of Trader so now
  • 00:36:29
    maybe an and or Sonia does a Trader have
  • 00:36:32
    to send data to traces if the HS code
  • 00:36:34
    doesn't change when sending Goods
  • 00:36:36
    Downstream or can a Trader just copy the
  • 00:36:39
    reference codes the reference numbers
  • 00:36:41
    that they get I don't know if you can
  • 00:36:43
    comment on that if there's a some
  • 00:36:45
    insight well um based on the information
  • 00:36:48
    we have at the moment then the trader
  • 00:36:51
    has to create a new DDS statement with a
  • 00:36:54
    new number and then link back to the the
  • 00:36:57
    number they received so they they cannot
  • 00:37:00
    simply copy the number they got but they
  • 00:37:02
    have to create a new one with the link
  • 00:37:04
    to the previous one yeah so even as a
  • 00:37:07
    Trader yeah yeah good okay so then a
  • 00:37:10
    very specific question related to chain
  • 00:37:12
    of custody I think will the DDS and
  • 00:37:15
    reference number be mentioned on the
  • 00:37:16
    chain of custody um Sonia do you want to
  • 00:37:21
    take yeah I can reply that the answer is
  • 00:37:24
    no chain of custody and the
  • 00:37:26
    certifications are a totally different
  • 00:37:28
    thing than
  • 00:37:30
    eodr so those are handled handled
  • 00:37:34
    separately good then um Anie the next
  • 00:37:38
    one I'll give to you how do you deal
  • 00:37:40
    with the uncertainties for example if
  • 00:37:42
    geolocation and other information will
  • 00:37:44
    need to be stored by Downstream
  • 00:37:46
    operators and um the person that's
  • 00:37:48
    asking this said they received oral
  • 00:37:50
    confirmation that will not be needed but
  • 00:37:52
    they are waiting for confirmation FAQ or
  • 00:37:54
    guidelines what do we build our system
  • 00:37:57
    on what type of information do we build
  • 00:37:58
    our system on I think that question
  • 00:38:01
    contains so many answer that is that I
  • 00:38:04
    can't even answer so we probably have to
  • 00:38:05
    come back to that um in in a later stage
  • 00:38:10
    yeah um good and then we will I'll share
  • 00:38:13
    the link soon for the um FAQ on our
  • 00:38:16
    website and that will be kind of
  • 00:38:18
    continuously adjusted as well also based
  • 00:38:20
    on the the questions
  • 00:38:22
    today um do we have a tool in place to
  • 00:38:25
    generate fine DDS for manual dispat es
  • 00:38:28
    material returns material samples
  • 00:38:30
    dispatches outside of the system rough
  • 00:38:32
    cycle
  • 00:38:34
    dispatches and see I would also look at
  • 00:38:36
    you for that well yeah the um rough
  • 00:38:39
    cycle of course is uh recycled material
  • 00:38:41
    so it's not in the scope itself um the
  • 00:38:45
    tools we are generating are for the
  • 00:38:47
    dispatches and we we are intending to
  • 00:38:50
    include the uh reference numbers into
  • 00:38:53
    the documents we mentioned so shipment
  • 00:38:55
    uh documents and then the EDI messages
  • 00:38:57
    including but uh nowhere else
  • 00:39:00
    there's we we don't have any other tools
  • 00:39:03
    in the plan plans at the moment yeah and
  • 00:39:05
    then of course for sample deliveries
  • 00:39:06
    they are also just regular deliveries so
  • 00:39:08
    there will be a reference number for
  • 00:39:10
    samples under eodr and the material
  • 00:39:12
    returns of course have always a
  • 00:39:14
    connection from the ordering number to
  • 00:39:16
    the shipping list so we know which
  • 00:39:18
    reference number material return
  • 00:39:20
    actually belongs to so that's AB due to
  • 00:39:22
    the traceability that an mentioned
  • 00:39:25
    earlier um and then is a kind of very
  • 00:39:28
    broad question what is the verification
  • 00:39:29
    number do you want to give an answer on
  • 00:39:32
    that Anie um it's it's a second part of
  • 00:39:35
    the uh reference number that EU traces
  • 00:39:38
    or EU legislation has the background and
  • 00:39:42
    the meaning is not clear for us at the
  • 00:39:44
    moment and where it will be used but uh
  • 00:39:46
    that we'll have to we'll probably find
  • 00:39:48
    out and at the same time as as everybody
  • 00:39:52
    else and then uh the next two ones I can
  • 00:39:55
    comment on even though that's the D
  • 00:39:57
    system but with a reference number and
  • 00:39:58
    verification number change for each
  • 00:40:00
    delivery for the same item so let's make
  • 00:40:02
    it concrete when I look at labeled stock
  • 00:40:04
    you buy rafla code R51 honey glassan 65
  • 00:40:08
    if you buy that product this week and
  • 00:40:09
    then you get it delivered again in a
  • 00:40:11
    month then yes you will receive two
  • 00:40:12
    different reference numbers because the
  • 00:40:14
    reference numbers are issued shipment
  • 00:40:17
    specific um and then the question after
  • 00:40:20
    that is whether the reference number is
  • 00:40:21
    the same for all reals in one shipment
  • 00:40:23
    and yes that is so if you buy three
  • 00:40:25
    different products they all shipped at
  • 00:40:27
    at the same time you get one reference
  • 00:40:29
    number for that whole shipment and that
  • 00:40:31
    basically then connects to the whole
  • 00:40:33
    Upstream value
  • 00:40:36
    chain um then the next question what is
  • 00:40:38
    the use of the verification number from
  • 00:40:41
    traces is that what will be matched with
  • 00:40:43
    another DDS uh I think we've probably
  • 00:40:45
    covered that now with what you said
  • 00:40:47
    anything to add on yeah that's well it's
  • 00:40:50
    it's a the the verification number and
  • 00:40:52
    the reference number they they together
  • 00:40:55
    make the uh
  • 00:40:57
    uh ID for the DDS statement so that's
  • 00:41:01
    all we know at the moment um and don't
  • 00:41:04
    know exact meaning of the verification
  • 00:41:06
    number itself okay I can just add here
  • 00:41:09
    that most probably we have the
  • 00:41:11
    verification number just to make sure
  • 00:41:13
    that the due diligence statement number
  • 00:41:15
    is valid and companies are not making
  • 00:41:18
    those numbers up themselves so you can
  • 00:41:21
    actually check that the number that they
  • 00:41:24
    have created so the due diligence
  • 00:41:26
    statement number is valid by using this
  • 00:41:29
    verification number but
  • 00:41:33
    yeah we'll see how it works in practice
  • 00:41:36
    sounds good and then the next question
  • 00:41:38
    is will due diligence statements be
  • 00:41:40
    available for materials already held in
  • 00:41:42
    our stock I think we can all answer that
  • 00:41:44
    but Sonia do you want to take that
  • 00:41:46
    related to our stock
  • 00:41:49
    material um sorry I was not completely
  • 00:41:52
    following uh whether whether we issue
  • 00:41:54
    due diligence statements also for
  • 00:41:56
    material already held in stock that's
  • 00:41:58
    then for our stock and of course for
  • 00:42:00
    customer stock as
  • 00:42:01
    well well basically uh the materials
  • 00:42:04
    that we have stock at the moment we
  • 00:42:07
    don't have the uh geolocation
  • 00:42:09
    information so we are unable to create
  • 00:42:12
    due diligence statements for those
  • 00:42:14
    products but it's okay the regulation
  • 00:42:16
    says that all the goods that are
  • 00:42:18
    already um in the market are fine to be
  • 00:42:22
    used because of course um um EU also
  • 00:42:26
    understands that it's really hard to
  • 00:42:30
    it's impossible to create the dut
  • 00:42:32
    statement for the products that are
  • 00:42:34
    already flowing in the
  • 00:42:39
    market thank you Sonia and then the next
  • 00:42:42
    two ones I'm going to skip over now just
  • 00:42:44
    because it's also related to the
  • 00:42:46
    verification number and reference uh
  • 00:42:47
    reference numbers um if there's further
  • 00:42:50
    questions that couldn't be clarified
  • 00:42:51
    please later on check our uh Q&A and
  • 00:42:54
    then after that we can check if there's
  • 00:42:56
    kind of additional we can share if
  • 00:42:57
    there's additional inquiries that you
  • 00:42:59
    have based on that um will the today's
  • 00:43:01
    slides be made available to participants
  • 00:43:04
    um we won't share the direct slides but
  • 00:43:06
    we have the link uh later on that we
  • 00:43:09
    will also Post in the chat to our
  • 00:43:10
    frequently asked questions and all of
  • 00:43:12
    the questions and more information is
  • 00:43:14
    available on our website so we're happy
  • 00:43:17
    for you to access that and we will soon
  • 00:43:19
    send out also the link to the recording
  • 00:43:20
    of
  • 00:43:23
    today uh December looks tight for traces
  • 00:43:26
    coming on stream to issue um reference
  • 00:43:28
    numbers so will there be any possibility
  • 00:43:29
    to test the system before it goes live
  • 00:43:31
    Sonia may I ask you to comment on
  • 00:43:35
    that I think that an might have a better
  • 00:43:38
    um understanding of when the traces will
  • 00:43:41
    actually work but I know that it will be
  • 00:43:43
    a tight schedule yeah it it definitely
  • 00:43:46
    is and I agree with the question it it
  • 00:43:49
    definitely is and I assume it's a
  • 00:43:50
    development related system related
  • 00:43:53
    question itself so yes the timetable not
  • 00:43:56
    only December but November December
  • 00:43:58
    looks tight and uh the traces uh is is
  • 00:44:04
    under development like said we have
  • 00:44:06
    access to the test system and uh the
  • 00:44:09
    ubm project is building our integration
  • 00:44:12
    layer towards traces but uh we will see
  • 00:44:16
    how how it goes um some of testing
  • 00:44:19
    activities some mockups are in there
  • 00:44:21
    already but time will
  • 00:44:25
    tell thank you
  • 00:44:27
    um and then uh does anybody know do you
  • 00:44:31
    know if can companies still apply for
  • 00:44:33
    access to the test system to also get
  • 00:44:34
    familiar with it do you know
  • 00:44:36
    that um we have we have a access to the
  • 00:44:41
    um test system or actually the the
  • 00:44:43
    developers who are building the uh uh
  • 00:44:47
    traces API they must have because they
  • 00:44:50
    have been working on it already how that
  • 00:44:52
    happens that I would know we would have
  • 00:44:53
    to come back to that but probably the
  • 00:44:56
    best information comes from the EU Pages
  • 00:44:58
    themselves or traces direct yeah and in
  • 00:45:01
    our website that we we're going to show
  • 00:45:03
    you in a minute um there is the link
  • 00:45:05
    actually to that um to that uh to the
  • 00:45:08
    due diligence system and then you can
  • 00:45:10
    get further information from there and
  • 00:45:11
    inquire whether test access is like
  • 00:45:13
    additional available as well um the next
  • 00:45:16
    question is how are you going to
  • 00:45:17
    validate the DDS from your suppliers is
  • 00:45:20
    there any process in the European Union
  • 00:45:22
    platform for doing it there is or there
  • 00:45:26
    is said to be I mean there it doesn't
  • 00:45:28
    exist yet but uh in the beginning they
  • 00:45:31
    was said that there is a functionality
  • 00:45:33
    for for a validating the um um supplier
  • 00:45:38
    given uh DD statements the the function
  • 00:45:41
    wasn't validate it was retrieve or
  • 00:45:43
    something like that but uh but there
  • 00:45:45
    will be one U which doesn't exist yet
  • 00:45:48
    linking to the previous question that uh
  • 00:45:51
    December looks tight for the testing
  • 00:45:53
    purposes yes absolutely um then the next
  • 00:45:57
    question is will the DDS reference
  • 00:45:58
    number be on reels of label stock so to
  • 00:46:01
    repeat what we said there's going to be
  • 00:46:03
    Ruff attack is going to issue one
  • 00:46:05
    reference number with the verification
  • 00:46:07
    code that belongs to that for one
  • 00:46:09
    shipment so all of the shipment is
  • 00:46:12
    covered by one reference number not
  • 00:46:13
    specific reals of label stock in that
  • 00:46:16
    case yeah and in case this means that
  • 00:46:19
    are we printing the uh references on a
  • 00:46:22
    real label then no that's not the case
  • 00:46:26
    yeah they will be aail ailable on the
  • 00:46:27
    shipping list that also accompanies the
  • 00:46:29
    shipment itself yeah okay um are the DDS
  • 00:46:35
    statements and reference numbers
  • 00:46:36
    available or P paper mill data available
  • 00:46:39
    for papers currently sold or sold in the
  • 00:46:41
    past so I would say what Sonia just said
  • 00:46:44
    before um as UDR comes into effect kind
  • 00:46:48
    of in the value chain we all have to
  • 00:46:50
    wait wait as information becomes
  • 00:46:51
    available and Sonia said um we can show
  • 00:46:54
    that if the material has been on the
  • 00:46:56
    market or already in the EU then they
  • 00:46:58
    are for then exempt from from from that
  • 00:47:00
    info and there's a question covering
  • 00:47:02
    that as well also in our Q&A anything to
  • 00:47:05
    add Sonia
  • 00:47:06
    otherwise uh no that's correct so
  • 00:47:10
    basically the answer to that question is
  • 00:47:12
    no we don't have the information for the
  • 00:47:14
    papers that we are purchasing at the
  • 00:47:16
    moment or that we are are having in our
  • 00:47:19
    stocks yeah so and then um there's uh
  • 00:47:23
    one listener that commented I believe
  • 00:47:25
    FSC are offering an add-on module for
  • 00:47:27
    UDR compliance and that you may all look
  • 00:47:30
    out for I think both FSC and PFC and
  • 00:47:32
    also other organizations are working on
  • 00:47:35
    modules to support customers with
  • 00:47:37
    working with the Tracer system of the EU
  • 00:47:40
    um upm has chosen the way of kind of uh
  • 00:47:43
    building our own API on the on the EU
  • 00:47:46
    level and then using our own in-house
  • 00:47:48
    systems to become UDR compliant but
  • 00:47:51
    there are possible solutions out there
  • 00:47:53
    that are being offered how good they are
  • 00:47:55
    how useful they are we can comment on
  • 00:47:57
    that but um we can see that FSC and PFC
  • 00:47:59
    are both further developing also their
  • 00:48:01
    own certification systems
  • 00:48:04
    now um are label manufacturers fully
  • 00:48:07
    exempt uh no they are not so label
  • 00:48:10
    manufacturer upm raak we are a labeled
  • 00:48:12
    stock manufacturer and our customers you
  • 00:48:15
    are then for example printers of label
  • 00:48:17
    stock um and as long as the product that
  • 00:48:20
    we sell falls under the the CN code so
  • 00:48:23
    this tariff code in nx1 we are not
  • 00:48:26
    exempt from e are of course only for
  • 00:48:28
    deliveries that actually are within the
  • 00:48:30
    EU coming into the EU or going out of
  • 00:48:33
    the
  • 00:48:34
    EU um as a customer what do we need to
  • 00:48:36
    check when the material arrives and
  • 00:48:38
    where do we need to integrate the ID
  • 00:48:40
    codes for each material we receive
  • 00:48:42
    Scrolls and transform
  • 00:48:45
    them um is that something I'm not quite
  • 00:48:48
    sure what that means is there something
  • 00:48:50
    that either of you can comment on that I
  • 00:48:51
    don't know Anie if there's some comment
  • 00:48:53
    or a comment on what we do in receiving
  • 00:48:55
    material yeah yeah yeah maybe elaborate
  • 00:48:58
    exactly that how we do so when we work
  • 00:49:00
    with our windows and we receive the uh
  • 00:49:03
    shipments with multiple roles then
  • 00:49:06
    during the dispatch process we will
  • 00:49:08
    assign the received uh DDS reference
  • 00:49:12
    numbers to the roles we receive and then
  • 00:49:15
    use them further down in the chain when
  • 00:49:17
    we when we create the shipments to our
  • 00:49:19
    customer so you probably need to do the
  • 00:49:24
    same thank you Anie then is there a
  • 00:49:27
    specific form of due diligence statement
  • 00:49:29
    who provides it so in the end it's
  • 00:49:31
    actually so for example the UDR
  • 00:49:33
    compliance obligation we have we have to
  • 00:49:35
    create that due diligence statement in
  • 00:49:37
    this traces database and Sonia was in
  • 00:49:39
    the beginning showing this uh nx2
  • 00:49:42
    information so the eodr regulatory text
  • 00:49:45
    defines the information that need to
  • 00:49:46
    come into that statement and uh then it
  • 00:49:49
    depends on the role and the part of the
  • 00:49:51
    value chain where you are uh what
  • 00:49:53
    specifics you have there but always the
  • 00:49:55
    reference number refers to the um
  • 00:49:57
    Upstream value chain
  • 00:49:59
    details and I can just add here that
  • 00:50:02
    basically the due diligence statement is
  • 00:50:05
    the Tracy system so you don't need to
  • 00:50:08
    create a uh paper of your own and there
  • 00:50:11
    the information you need to log into the
  • 00:50:14
    Tracy system and then just answer to the
  • 00:50:17
    questions that the system has and from
  • 00:50:20
    the system you will get the due
  • 00:50:21
    diligence statement and the reference
  • 00:50:23
    number
  • 00:50:27
    and then Sonia next question also for
  • 00:50:28
    you um there's a listener that says from
  • 00:50:32
    my knowledge FSC will offer risk
  • 00:50:33
    assessments for more than 90 countries
  • 00:50:36
    will those be enough for us to determine
  • 00:50:37
    the level of
  • 00:50:40
    risk
  • 00:50:42
    um I L here that basically EU needs to
  • 00:50:46
    create this uh country risk rating but
  • 00:50:50
    it has not being
  • 00:50:51
    published and uh probably FC has tried
  • 00:50:56
    to also create a list to help us to
  • 00:50:59
    comply but uh before the official list
  • 00:51:03
    from the EU we cannot uh rate the
  • 00:51:06
    countries by
  • 00:51:09
    risk so um that's the current
  • 00:51:13
    status thank you and then the next
  • 00:51:16
    question is UDR concerns all countries
  • 00:51:18
    are only import to EU so the eodr
  • 00:51:21
    applies to all products that are subject
  • 00:51:24
    to eud under NX one that are put on the
  • 00:51:27
    EU market and that means they are either
  • 00:51:29
    leaving the EU so crossing the border to
  • 00:51:31
    outside coming in from outside of the EU
  • 00:51:33
    to the EU and that are sold within the
  • 00:51:36
    EU um within the EU borders UDR cannot
  • 00:51:40
    make mandatory compliance for deliveries
  • 00:51:42
    outside of the EU anywhere so deliveries
  • 00:51:45
    let's say from raflatac in North America
  • 00:51:47
    to a customer in North America there's
  • 00:51:49
    no UDR obligation on
  • 00:51:52
    those and another question now
  • 00:51:54
    specifically when I requested data from
  • 00:51:56
    upm about Pulp and Paper Mills due
  • 00:51:58
    diligence for materials sold to the us
  • 00:52:01
    being shipped in the EU I only received
  • 00:52:03
    three species and country of origin no
  • 00:52:06
    more why so relating to the question
  • 00:52:10
    before this right now if you have a case
  • 00:52:13
    that you deliver that you get material
  • 00:52:15
    from the from the US to the US and then
  • 00:52:19
    subsequently something is shipped to the
  • 00:52:21
    EU um as I said earlier it's possible
  • 00:52:24
    that suppliers are not ready to share in
  • 00:52:26
    information that could then help with
  • 00:52:28
    eodr compliance so we um ask you to
  • 00:52:31
    raise those cases to the sales contact
  • 00:52:33
    that you have so that we can then look
  • 00:52:35
    at those cases specifically and advise
  • 00:52:37
    how to proceed because the suppliers
  • 00:52:39
    outside of the EU don't necessarily have
  • 00:52:42
    share the information that is needed to
  • 00:52:44
    be eud
  • 00:52:46
    compliant and I just want to add here
  • 00:52:48
    that to be UDR compliant it doesn't mean
  • 00:52:51
    that um companies need to share who are
  • 00:52:54
    their suppliers and so forth
  • 00:52:57
    so basically uh the information about
  • 00:53:00
    the paper mills where we are sourcing
  • 00:53:02
    the papers or the pulp Mills that are um
  • 00:53:06
    selling the pulp to the paper mills it's
  • 00:53:08
    not relevant under the
  • 00:53:13
    UDR thank you Sonia um what about rubber
  • 00:53:16
    based adhesives you mentioned in your
  • 00:53:18
    presentation only wood as a relevant raw
  • 00:53:20
    material Sonia can I give that to you as
  • 00:53:24
    well yes um uh this natural latex is
  • 00:53:28
    also part of um
  • 00:53:31
    UDR and uh
  • 00:53:35
    basically the materials that we are
  • 00:53:37
    selling to our customers are these paper
  • 00:53:41
    labels and they are um under this paper
  • 00:53:46
    CN codes and everything comes to the CN
  • 00:53:49
    codes like Vera told you it's good to
  • 00:53:52
    check that what are the CN codes that
  • 00:53:53
    what you are sourcing and what you are
  • 00:53:56
    selling to your customers and all the
  • 00:53:59
    obligations regarding to eodr are linked
  • 00:54:02
    to these CN
  • 00:54:05
    codes thank you and then a follow-up
  • 00:54:07
    question on the verification of the DDS
  • 00:54:10
    the customer needs to do the
  • 00:54:11
    verification of the DDS that the
  • 00:54:13
    information on the DDS is indeed correct
  • 00:54:16
    how does the G Customer get this from
  • 00:54:18
    upm um I think we've kind of covered
  • 00:54:21
    some of this already but do you want to
  • 00:54:22
    reiterate either Anie or Sonia
  • 00:54:27
    well I can I can start the probably two
  • 00:54:30
    things in here the the technical
  • 00:54:32
    verification of the number itself that
  • 00:54:35
    it exists in the system so that the DDS
  • 00:54:38
    statement has been created and that
  • 00:54:41
    number is against a a valid DDS
  • 00:54:44
    statement that's that's the verification
  • 00:54:47
    we are going to do when receiving so at
  • 00:54:50
    the receiving point point of time we
  • 00:54:52
    will not be checking the the details of
  • 00:54:55
    the DD statement or anything in the
  • 00:54:58
    further down in the chain uh just the
  • 00:55:01
    technical existence and that it it is a
  • 00:55:04
    valid statement or valid
  • 00:55:08
    number thank you
  • 00:55:11
    an then as a printer all reals pellets
  • 00:55:14
    packets already have batch making
  • 00:55:16
    numbers will there be an API that allows
  • 00:55:18
    us to work back from that number to get
  • 00:55:20
    the full information required could milz
  • 00:55:23
    considering could milch consider a
  • 00:55:25
    standardized number format we can use a
  • 00:55:27
    common
  • 00:55:29
    system Anie can I ask you to comment on
  • 00:55:31
    that yeah the the when you have a DDS
  • 00:55:35
    reference number you can use that to get
  • 00:55:37
    the information from the traces the link
  • 00:55:40
    uh from your number that you get from us
  • 00:55:44
    uh all the way back to the forest and
  • 00:55:47
    the DDS statements the uh the guys who
  • 00:55:49
    were chopping the wood out from the
  • 00:55:51
    forest made and that is generated in the
  • 00:55:55
    Tracy system so we won't be able to
  • 00:55:57
    provide that to you it's in the Tracy
  • 00:55:59
    system and if Tracy system allows you to
  • 00:56:02
    go and look at the whole chain then yes
  • 00:56:04
    it's available but we don't know exactly
  • 00:56:07
    what will be the final version of the
  • 00:56:09
    system and and what it will uh allow you
  • 00:56:11
    to access yeah the next question shall
  • 00:56:15
    the due diligence be based on bch or
  • 00:56:17
    item or
  • 00:56:18
    supplier um I mean reference number wise
  • 00:56:21
    we're sharing one reference number per
  • 00:56:24
    shipment and then Sonia's anything to
  • 00:56:26
    add about the due diligence uh conducted
  • 00:56:29
    that we do because of course they are
  • 00:56:30
    not specific to a delivery as
  • 00:56:34
    such yeah true um like I said that UDR
  • 00:56:38
    doesn't give uh strict guidelines how to
  • 00:56:41
    perform the due diligence so it's up to
  • 00:56:44
    companies to decide how they will do it
  • 00:56:46
    I guess that most probably companies
  • 00:56:48
    will evaluate their suppliers once a
  • 00:56:51
    year twice a year or something like that
  • 00:56:54
    and based on that uh check that uh the
  • 00:56:56
    materials that they are getting from the
  • 00:56:58
    suppliers are compliant and the
  • 00:57:02
    suppliers are following the due
  • 00:57:06
    diligence processes also
  • 00:57:09
    themselves sounds good thank you Sonia
  • 00:57:11
    so now looking at the time because it's
  • 00:57:13
    3 minutes to three and we're cutting off
  • 00:57:15
    at the hour so um all the other
  • 00:57:18
    questions that are still in the chat
  • 00:57:19
    that I can see that you want answers for
  • 00:57:22
    we'll look at all the questions from
  • 00:57:23
    today and we'll rework and look at our
  • 00:57:26
    Q&A online and then adjust whatever
  • 00:57:28
    question hasn't been answered yet to
  • 00:57:29
    share the information that you're asking
  • 00:57:31
    for here um if your name is in there and
  • 00:57:34
    we can identify you directly to a
  • 00:57:36
    customer we might reach out if something
  • 00:57:37
    is unclear but otherwise uh we wew work
  • 00:57:41
    the the Q&A and with that I want to move
  • 00:57:44
    to the very last slide um because I do
  • 00:57:47
    want to thank all of you for asking
  • 00:57:49
    really great questions for participating
  • 00:57:51
    today and thank you Sonia and Anie for
  • 00:57:54
    taking the questions and also explaining
  • 00:57:55
    so much
  • 00:57:56
    all questions that we didn't have time
  • 00:57:58
    to address are not lost as said we're
  • 00:58:00
    going to review them and what you can
  • 00:58:01
    see here now on this page is that um the
  • 00:58:06
    up.com eodr that's where the eodr U
  • 00:58:10
    hopefully has gone live during this hour
  • 00:58:12
    while we said in the webinar so that's
  • 00:58:13
    where the uh FAQ document not not
  • 00:58:16
    document but the FAQ the questions and
  • 00:58:17
    answers are available and we will adjust
  • 00:58:20
    those as we get more information from
  • 00:58:22
    the EU and we'll adjust those also with
  • 00:58:24
    the questions and answers that we've
  • 00:58:25
    gotten from from you today if you do
  • 00:58:27
    have more questions after the webinar
  • 00:58:29
    check out that website or please also
  • 00:58:31
    contact your sales representative you
  • 00:58:33
    should have a designated contact in
  • 00:58:35
    raflatac please contact that person for
  • 00:58:37
    further questions thank you so much and
  • 00:58:40
    have a wonderful
  • 00:58:43
    day thank you
Tags
  • deforestation
  • European Union Regulation
  • compliance
  • due diligence
  • traceability
  • environmental impact
  • risk management
  • forest degradation
  • sustainable sourcing
  • global supply chain