The EU Deforestation Regulation at THIMM
Statement by THIMM, October 2025
What is the EUDR?
With the new EU Deforestation Regulation, the EU is establishing clear due diligence requirements for companies. Companies are obliged to ensure that their products are deforestation-free – in other words that no forest areas were cleared or damaged during the manufacturing of their products.
The focus is on transparency and traceability within supply chains. Companies must be able to prove that a product’s entire journey is fully documented. For this purpose, the EUDR requires comprehensive data and information from the companies concerned.
Who does the EUDR apply to?
The EUDR is product-based and therefore applies without exception to all companies that trade EUDR-relevant raw materials and goods within the EU, import them into the EU or export them from the EU. The Regulation concerns raw materials and products manufactured using the following raw materials:
wood | rubber | cocoa | coffee | soya | palm oil | cattle.
Entry into force: The EU Deforestation Regulation is scheduled to enter into force on 30 December 2025 for non-SMEs such as THIMM. We are closely monitoring the current situation regarding the European Commission’s proposed amendments and will promptly implement any required changes once a legally binding basis is established. Until then, we will continue to operate in accordance with the current applicable legal framework.
THIMM commitment to the EUDR
The THIMM Group is covered by the scope of Regulation (EU) 2023/1115 on Deforestation-free Products (EUDR) and must implement all legal requirements regulated herein within the specified deadlines.
We ensure that all due diligence obligations required by the EUDR are fulfilled properly and on time. These include, in particular, the submission of the legally required Due Diligence Statement in the required form and within the legally defined deadlines.
Each THIMM Group company (“Legal Entity”) is independently responsible for implementing the requirements of the EUDR and ensures that the relevant national interpretations of the European requirements are taken into account.
As THIMM does not act as the “first operator” within the meaning of the EUDR at any point in the supply chain, we do not generate our own geolocation data. Nevertheless, as part of our due diligence obligations, we are required to work exclusively with business partners who, in turn, meet the requirements of the EUDR and provide the required information.
Scope of the EUDR for THIMM products
Our products are covered by the EUDR if they are listed in Annex I of the EUDR and no other exemption provided by the law applies.
The EUDR therefore covers, for example, paper containing a proportion of fresh fibres as well as corrugated cardboard, packaging and displays from THIMM.
The Harmonised System code (customs code) required by the EUDR is disclosed in the Due Diligence Statement.
If a product contains a proportion of fresh fibres, does not serve to protect, support or carry at the time of being placed on the market, and is not a sample, it falls under the EUDR, regardless of the proportion of fresh fibres. Only products made from 100% recycled paper are not covered by the EUDR.
Collection and disclosure of EUDR data
The Due Diligence Statements received from our suppliers are checked for validity. THIMM then creates a new Due Diligence Statement for the products concerned via the EU portal TRACES.
From the date the law enters into force for non-SMEs, Due Diligence Statements with reference and verification numbers will be generated for EUDR-relevant products that are not covered by the EU Timber Regulation (EUTR).
The reference and verification numbers are assigned per batch.
The corresponding reference and verification numbers are added to the delivery notes and invoices. When this information is provided on the forms, it is deemed to have been submitted. This ensures that all EUDR-relevant information is received by the customer on time and in accordance with the law.
Do you have any questions about the implementation of the EUDR at THIMM?
THIMM Group
+49 5551 703 0
mail@thimm.de