I am not only an independent publisher but also a small publisher.
So, I was basically ignoring the discussions about the EU’s Deforestation Regulation – but, every time anything about this did cross my ken, I patted myself on the back because I have used FSC-certified paper from the very start of my publishing effort, just over 4 years ago.
But shock! Horror!
Using FSC-certified paper isn’t adequate for compliance at all!
Why?
Because using FSC-Certified paper “merely” proves that it doesn’t contribute to deforestation – and, yes, it also does provide traceability right through the supply chain. But what it doesn’t do is to provide the additional stuff needed by EUDR.
Why does the world need more information than that? Dear fellow-dimwits, that may not be at all clear to you and me, but it is startlingly clear to the superior minds in certain bureaucracies.
What is the additional information that is thought necessary or at least useful?
Just two things: geolocation data and risk assessment.
Whatever is “geolocation data”? Ah that is the small matter of the specific physical location of *each* of the actual plots of land where the wood used in that *specific* consignment of paper was harvested. Which means not only the exact map co-ordinates of the plot of land, but also the *time of harvest* and the *date-range* when the relevant trees grew!
Further, each shipment of books must carry a “due diligence” statement confirming that the products comply with the legislation of the country of production. Does that seem self-evidently assinine to you? I am based in the UK, so it will now be part of my job as a small publisher to fly to the USA, Canada, China, Sweden, Finland, Brazil and Indonesia, to ensure that the paper being used by my sub-contracted printer complies with the environmental, social, and labor laws of these countries – which just happen to be written, of course, in Mandarin, Swedish, Finnish, Portuguese and Bahasa!!
But no, that clearly isn’t assinine enough.
I must also provide “risk assessments” that identify and mitigate any “potential risks” of deforestation in my supply chain.
How am I to do that? By conducting or commissioning *independent* surveys and audits!
In addition, I must provide evidence that I am supporting my suppliers in meeting these requirements by providing training and other resources that will help them comply with EUDR.
And, to top it all, I must prove that I have systems for regular monitoring and reporting to ensure compliance is “ongoing”, which means not only *my* keeping detailed records but also being prepared for inspections by EU authorities, who will want to fly in to the UK for the purpose – at my expense, no doubt?
*_*_*
Just in case you haven’t been keeping up with current trends in regulation, you may not be aware of the EU’s Deforestation Regulation (EUDR – officially, “Regulation (EU) 2023/1115”), so here is a cheat sheet about it.
The EUDR aims to ensure that products entering or leaving the EU market are not linked to deforestation or forest degradation. Sounds entirely a good thing to have someday, right?
But, ha!, you didn’t notice it because it slunk by – voila! It already come into force (on June the 29th LAST year (2023).
There is a saving grace, though. It has come into force, but it has not yet come into force! Yes, you read that right, and I repeat: It has come into force, but it has not yet come into force.
Whatever could that possibly mean? Well, what that means is that it does already exist on paper, but there is a “transitional period” before it actually starts being applied to you and me.
If you are large and medium-size company, then it will, as currently framed, start being applied to you in a few weeks – from December the 30th THIS year; but if you are, like me, a small or even micro enterprise, it will start hitting us on the incredibly distant date of June the 30th next year (i.e., 2025).
However, just to add to the fun, there is lack of clarity about whether the regulation will actually be applied then, as proposals have just been announced (see https://ec.europa.eu/commission/presscorner/detail/en/ip_24_5009) which *may* result in application being delayed by 12 months – in which case, the regulations could actually start being applied, in the case of large and medium-sized publishers, from December the 30th, 2025 – but, in the case of small and micro publishers, from June the 30th, 2026
Whenever EUDR kicks in, operational costs will certainly increase.
So what happens if you and I don’t comply with the EUDR? Easy: you and I will lose access to the EU market. Doesn’t sound too bad you may think.
But what about this: will we face fines if any of our products, through no action or inaction on our part, end up in the EU?!
Exasperated, you may wonder: Is there no way of escaping this dragnet?
Well, there may be a passably convenient way of getting alignment with the EUDR which is apparently being created, and could possibly be created in time – the FSC’s “EUDR Aligned Solution”, which will include some tools and frameworks that could help – and will, presumably, cost something on top of what FSC-certified paper is already costing.
So what happens if you return, reinforced, to your instinct to dodge all that or at least survive in spite of it?
Simple:
- Avoid the EU market entirely; and,
- In order to create as much of a war-chest as possible, use NON-FSC certified paper in the majority-world, adding to efforts to lobby these nations (as India and other countries are already doing) to relax and preferably lower environmental standards.
Though that route is open only to those with no conscience or at least a seared conscience, it is another illustration of the fact that it costs money to have a conscience.
Of course, lack of conscience is why regulations are necessary in the first place.
But it is only one illustration among numerous ones which demonstrate that higher regulatory standards in one part of the world can actually incentivise lower adherence to sustainable and other ethical standards in other parts of the world.
Which is why we need global regulation, nor merely national or regional regulation.
Or, to put it differently, what we don’t need is unnecessarily heavy-handed attempts in one part of the world which only raise costs in that part of the world while incentivising behaviour with opposite consequences in the majority world.
So here is my concluding gentle message to the EU:
If you wish to avoid worsening the sustainability situation for the world as a whole, please desist from the EUDR beyond requiring the use of FSC-certified paper. Beyond that, work instead for regulation and legislation which takes, along the desirable path, the whole of the globe.