EUDR Compliance

EU Deforestation Regulation (EUDR) Compliance Declaration of texorello UG

EUDR Compliance Declaration

1. About the EU Deforestation Regulation (EUDR)

The EU Deforestation Regulation (EUDR) - Regulation (EU) 2023/1115 - came into force on June 29, 2023 and will be fully applicable from December 30, 2025 for large companies and from June 30, 2026 for small and medium enterprises.

The regulation aims to minimize deforestation by ensuring that certain goods and products placed on the EU market do not originate from areas that were deforested after December 31, 2020.

2. Affected Raw Materials and Products

The EUDR regulates seven main raw materials and their processed products:

  1. Wood (including paper and books)
  2. Soy
  3. Palm oil
  4. Cattle
  5. Cocoa
  6. Coffee
  7. Rubber

Particularly relevant for texorello as a publisher: Wood and wood-based products such as paper, as these are used for book production.

3. texorello UG - Business Model and EUDR Relevance

3.1 Our Business Model

texorello UG (haftungsbeschränkt) is a publisher that publishes exclusively through Amazon Kindle Direct Publishing (KDP):

  • No own production: We do not produce, print or store physical books
  • No direct sales: We do not sell and ship books directly to end customers
  • Amazon KDP Print-on-Demand: All physical books are printed by Amazon using print-on-demand processes
  • Amazon as operator: Amazon acts as the operator in the sense of the EUDR

3.2 Our Role in the Supply Chain

As a content provider, we only provide Amazon with digital files (manuscripts, cover designs). The entire physical supply chain - from paper procurement to sales - is Amazon’s responsibility.

4. EUDR Compliance Status

4.1 Applicability of EUDR to texorello

Direct applicability: Limited

Since texorello does not place, store or sell physical products itself, we do not fall under the direct obligations as an “operator” within the meaning of the EUDR.

4.2 Indirect Responsibility

Due diligence obligations: As a responsible publisher, we nevertheless commit to:

  1. Transparency towards our readers and partners
  2. Cooperation with Amazon on EUDR compliance inquiries
  3. Monitoring developments in the publishing industry

4.3 Amazon KDP and EUDR Compliance

Amazon’s responsibility:

  • Amazon as operator is responsible for EUDR compliance
  • Amazon must ensure that the paper used is deforestation-free
  • Amazon must submit Due Diligence Statements (DDS)
  • Amazon must document geolocation data of raw material sources

5. Our EUDR Compliance Measures

5.1 Monitoring and Documentation

We continuously monitor:

  • Amazon KDP policies: Changes in Amazon’s EUDR compliance
  • Legal developments: Updates on EUDR interpretation and enforcement
  • Industry standards: Best practices in the publishing industry

5.2 Willingness to Cooperate

We commit to:

  • Full cooperation with Amazon on EUDR compliance inquiries
  • Transparent communication with authorities upon request
  • Provision of all relevant information about our publications

5.3 Sustainability Commitment

Even though not directly subject to EUDR, we promote:

  • Sustainable publishing practices
  • Digital publications as an environmentally friendly alternative
  • Awareness of environmental issues in our publications

6. EUDR Contact Point

6.1 Competent Authority in Germany

Federal Office for Agriculture and Food (BLE)
Department 513 - Sustainable Forest Management
Deichmanns Aue 29
53179 Bonn

Website: https://www.ble.de
Email: EUDR (at) ble.de

6.2 EU Information System

The central EU EUDR Information System was launched on December 4, 2024:

7. Transparency and Reporting

7.1 Annual Review

We review annually:

  • EUDR relevance of our business activities
  • Amazon KDP compliance and its implications
  • Regulatory developments in Germany and the EU

7.2 Stakeholder Information

We inform our stakeholders about:

  • Changes in our EUDR compliance status
  • New requirements for publishers
  • Best practices in the sustainable publishing industry

8. Contact for EUDR Matters

8.1 EUDR Contact Person

texorello UG (haftungsbeschränkt)
Attn: EUDR Compliance
Dr. Matthias Boldt
Birkenallee 103
15745 Wildau, Germany

Email: eudr (at) texorello.org
Phone: +49 1575 1124477

8.2 Inquiries and Cooperation

For inquiries regarding EUDR compliance, we are available:

  • Official inquiries: Full cooperation assured
  • Partner questions: Transparent information about our business model
  • Industry exchange: Participation in compliance initiatives
  • Regulation (EU) 2023/1115 (EUDR)
  • Implementing Regulation (EU) 2023/2407
  • German Supply Chain Due Diligence Act (LkSG)
  • Federal Nature Conservation Act (BNatSchG)

9.2 Compliance Principles

Our EUDR compliance is based on:

  • Legal compliance: Adherence to all applicable laws
  • Transparency: Open communication about our business model
  • Cooperation: Collaboration with partners and authorities
  • Sustainability: Promotion of environmentally friendly publishing practices

10. Updates and Changes

10.1 Regular Review

This EUDR compliance declaration is regularly reviewed and updated as needed:

  • At least annually or in case of significant changes
  • Upon new legal requirements
  • Upon changes to our business model

10.2 Notification Procedure

Significant changes are communicated via:

  • Website update: Update of this page
  • Email notification: To registered stakeholders
  • Official notification: If required

Important Disclaimer

This EUDR compliance declaration represents our current assessment of EUDR applicability to our business model. It does not replace individual legal advice and may change with new legal developments or authority interpretations.

For specific legal questions regarding EUDR, we recommend consulting a specialized lawyer or direct contact with the competent authority (BLE).

Last update: September 2025 Next review: September 2026