The European Union Deforestation Regulation, commonly known as the EUDR, introduces new traceability and due diligence requirements for companies importing certain commodities and products into the European Union.
Wood is one of the commodities covered by the regulation, and this includes wood charcoal under CN/HS heading 4402. This means that companies importing lump charcoal and charcoal briquettes made from wood into the EU need to prepare for the new requirements.
For charcoal producers outside the European Union, including CALIPAR SRL in Paraguay, the regulation also means that considerably more information about the origin of the raw material may be requested by European customers.
However, it is important to distinguish between the responsibilities of the EU importer/operator and those of the non-EU producer and supplier.
What does the EUDR require?
The objective of the EUDR is to prevent products associated with deforestation or forest degradation from being placed on the European Union market.
Under the regulation, relevant products may only be placed on the EU market when they meet the applicable requirements, including being deforestation-free, being produced in accordance with relevant legislation in the country of production, and being covered by the required due diligence documentation.
For wood products, “deforestation-free” includes the requirement that the wood must not originate from land subject to deforestation after 31 December 2020, and wood harvested from forests must not have caused forest degradation after that date.
The regulation therefore requires much greater traceability than a conventional commercial invoice or certificate of origin alone.
Who is responsible for EUDR compliance when importing charcoal?
For a normal shipment from Paraguay to an EU-established customer, the European company acting as the importer when the goods are released for free circulation is normally the EUDR operator.
European Commission guidance specifically identifies the person acting as importer on the customs declaration as the operator in this type of transaction.
This distinction is important.
CALIPAR SRL is the producer and exporter in Paraguay. The EU importer is responsible for carrying out its EUDR due diligence, assessing the information supplied, determining compliance and submitting the required Due Diligence Statement (DDS) through the EU EUDR Information System.
CALIPAR does not make the compliance determination on behalf of the importer and does not assume the importer’s regulatory obligations simply by providing supporting documentation.
Instead, our role is to provide our European customers with the documentation and traceability information available from the production chain so that they can perform their own due diligence.
Geolocation becomes an important part of charcoal imports
One of the major changes introduced by the EUDR is the requirement for traceability back to the land where the relevant commodity was produced.
The Due Diligence Statement includes information such as the country of production and the geolocation of the plots of land where the relevant commodity was produced.
For charcoal this means that traceability can extend beyond identifying Paraguay as the country of origin. The importer may need geographical information identifying the land associated with the wood used for the specific charcoal production.
This makes proper batch management particularly important.
A good documentary chain should allow the information to be followed from the land and forestry documentation, through harvesting and storage, into charcoal production and finally to the quantity exported in a particular shipment.
Paraguayan legality remains important
EUDR does not replace Paraguayan forestry legislation.
Instead, one of the requirements of the regulation is that relevant commodities and products must have been produced in accordance with the applicable legislation of the country of production.
For Paraguayan charcoal, this means that forestry permits, INFONA documentation, production records and other evidence of legal origin continue to play an important role.
CALIPAR has always considered traceability and legal production essential to supplying international markets. The EUDR adds another level of documentation because the EU operator must now incorporate this information into a formal due diligence system.
When does EUDR become applicable?
Following amendments to the regulation, the current application dates are:
30 December 2026 for large and medium-sized operators, as well as certain micro and small operators already covered by the previous EU Timber Regulation.
30 June 2027 for most other micro and small operators.
European charcoal importers should therefore establish their procedures before the applicable date rather than waiting until a container is already on its way to Europe.
The necessary documentation, geolocation information and traceability chain should preferably be discussed with the supplier when the purchase and shipment are being arranged.
Working together with our European customers
CALIPAR’s objective is to make the documentation process as transparent as possible.
We can provide the relevant production and origin information from Paraguay, while the European importer remains responsible for determining which documents are required for its particular EUDR due diligence system, conducting the required risk assessment and submitting the appropriate information to the European authorities.
This separation of responsibilities is important: CALIPAR provides the evidence from the origin and production side; the EU importer/operator performs and assumes responsibility for the EUDR due diligence required for placing the product on the European market.
European customers planning future shipments of Paraguayan White Quebracho charcoal are encouraged to communicate their documentation requirements before shipment so that the necessary records can be prepared and linked correctly to the relevant production batch.
For CALIPAR, EUDR preparation is therefore not about replacing the importer’s compliance process. It is about providing our customers with a strong and transparent documentary chain from Paraguay that allows them to carry out that process properly.
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