In this month’s podcast episode, we talk to Simon Crump, Environmental Consultant for BIC, to discuss the European Union Deforestation Regulation (EUDR) and its impact on the book industry. Simon offers insights on how the EUDR affects the book supply chain, practical steps for Canadian publishers to align with the regulation, and resources for non-European publishers aiming to understand compliance requirements.

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Transcript

Nataly Alarcón: Hello, welcome to a new episode of the BookNet Canada podcast. I am your host, Nataly Alarcón, BookNet's marketing and events manager. Today's topic is the European Union Deforestation Regulation or EUDR. To help us dive into this subject, I have invited Simon Crump, environmental consultant for BIC. Simon has been instrumental in several of BIC's sustainability initiatives, including helping with the planning and execution of the Green Supply Chain Committee Work Plan, which is based on 7 of the 17 UN Sustainability Development Goals. He is here to share insights on the EUDR and its implications for the book industry.

But first, for some context, what is BIC? BIC or Book Industry Communication is a UK-based not-for-profit book industry supply chain organization and a founding member of the Green Book Alliance, alongside BookNet Canada and the US-based Book Industry Study Group. With its unique position of trust across the book industry, BIC facilitates UK and global industry-wide collaboration to reach agreement on dependable standards and industry-recognized best practices guidelines in the supply chain. Amongst its many other supply chain initiatives and activities, BIC has been tirelessly advancing sustainability in the industry, and Simon has been a key collaborator in this mission.

Welcome to the BookNet Canada podcast, Simon. Please feel free to introduce yourself to our listeners.

Simon Crump: Well, thank you very much. My name is Simon Crump. I have been in publishing for nearly 30 years now. I've worked for some major publishers around the world, and since leaving my last full-time role with Cambridge University Press, I now work as a consultant for myself and for a number of other organizations. At the moment, the main one is BIC, which is the Book Industry Communication Ltd. in the UK, which is all about the book industry supply chain. And I work as their environmental consultant. And it's through my work there that I've been studying, trying to understand a lot about EUDR, the European Union Deforestation Regulations, which is why I believe we're here today to talk about that.

Nataly: Thank you, Simon. Yeah, that's the topic for today. And I cannot wait to get to our questions. So, the first one is, can you please give us an overview of the European Union Deforestation Regulation and what it aims to achieve particularly for our industry?

Simon: Right, yes, the European Union Deforestation Regulations have been set up, and they cover seven commodities. And those commodities are timber in all its forms. So, we're talking furniture, books, paper, everything like that. It also includes rubber, soy, palm oil, coffee, cattle and cocoa. The reason the EU are doing this is they want to make sure that any imports or anything they export from the EU trading area is not causing deforestation around the world or degradation to land. And that's the basic reason of why they have created this regulation.

Nataly: And what do you think are the implications for our industry in particular?

Simon: I think the implications for our industry is the fact that it's going to be more data recording or management of data around this. But I would say that, you know, and I'll come back to this again, that because we have things like FSC and PEFC, our industry isn't a good place with how it manages its timber and therefore its paper production and so forth. So, I think that is a very positive thing. Overall, I think despite what people might think of the actual regulation, the idea behind it is actually a very good one to stop deforestation and degradation of land. We hear about this all the time. And those of us in sustainability and just generally, we want to protect the world as much as we can.

Nataly: Absolutely. Can you please also elaborate on some of the uncertainties that still exist about the EUDR at this stage?

Simon: Well, I think one of the biggest uncertainties, which actually today [Dec. 4, 2024] has sort of been cleared up because the regulation was due to come into force on the 30 of December 2024. And then they were pushing for a delay of implementation, shall we say, to December 30, 2025. It looks like that is now all clear and will go ahead. I think that this is a good thing because it will now allow organizations in the book industry supply chain to get everything aligned and be able to work out how they're going to work within the system, what data they need to collect, what data they need to pass on to the next person in the supply chain. They can then work on their content management systems or whatever system they're using of where are they going to record this information and when are they going to have to pass it on. So, actually, you talk about a delay and uncertainty, but I think the delays and uncertainties give us an advantage that gives us a year to work out how we're actually going to implement it before any organization is fined or anything or has their imports blocked because we now have time to actually do that.

Nataly: Related to this, aside from the data collection piece, what other impact do you foresee that the EUDR will have for the book supply chain?

Simon: Well, obviously it's going to create more admin and record keeping for publishers, and printers, and paper mills and so forth so it's passed down. Hopefully, most of this can be done within the EU system, that they are creating and by my knowledge, my understanding is the first person, if you're say talking about European paper mills, they're the first people to put the product paper on the market. So, they are the ones who in their due diligence statement have to quote all their geo locations of where the trees have come from and so forth.

Now, the way the system is set up, they do not have to let the geo-location data flow down through the supply chain, but they do let the due diligence statement be available to people. And from what I have seen in the EU system is the fact that you actually reference the previous due diligence statement created by the organization above you. Therefore, you're not looking at all these geo location files, you're looking for maybe because we know with books, you've got covers, you've got end papers, you've got the text paper, you might be looking for a number of due diligence statements that you then reference within your own for those particular products.

So, in that sense, it makes it easier to manage, and this should be all inside the EU system. I do know with the EU system, they have opened it up to people that they can register. So, if you're not in the EU, you can get hold of the specific number that you need to be able to work in the system. So, you become registered that you can actually work within the EU system to create your due diligence statements. So, I think that that is going to be a lot easier for people to be able to use. Obviously, then you're going to have to note somewhere, "Okay, what due diligence statement have I created for this particular product, for a particular title, ISBN, or for the printing of it, or whatever?" And I think the development of IT systems is going to be a bit more of a challenge going ahead.

But hopefully, as I've already said, we've now got a year that we can start working out how we can do this. I would also add to this that if you fall into the category of being an SME or small, medium-sized enterprise micro-publisher, you're not required to be compliant until it will be the end of June 2026 now. And because of that, it will mean hopefully, how one works in the system will be resolved over the next year so those people will be able to pick up, because this is something that really ought to be collaborative and shared across the whole of the book supply chain worldwide about, right, this is how you do it. So, someone will have created and he can create a document that will help people to understand what they do.

And I think that this is the greatest fear and concern that people have at the moment is because they don't know what... They know what is required at one level, but they don't know what is required on a day to day, "What am I going to have to do?" And if you're very visual or whatever, you want to see a map of it. You want to understand what is required. And I think that the next year is going to provide that kind of documentation. And that's the kind of thing that BIC does. It's all about the supply chain and what goes on in the supply chain. And therefore, we will be there because the bigger organizations will have taken more of the pain, that it can then be shared to smaller organizations because as we know, smaller organizations suffer with resources and time because the employee's generally doing more than one job that you would do if you worked in a larger organization. And nothing's wrong either way. But hopefully, there will be a roadmap for those organizations to follow in the coming year.

Nataly: So it sounds like the next few months will have to be dedicated to figuring out ways to communicate better, collaborate better, and optimize some workflows for precisely what you were saying. Just making sure that everyone has access to that information and they can use it, right?

Simon: Yes. Yes. And I think the next year we'll see a lot of workshops taking place where organizations are getting into rooms. They're going to have large amounts of flip charts and things, and people are going to be discussing it. And then they're going to be drawing up documentation and maps and everything and process flow maps to understand what is required and what is needed. Everybody's going to have to say, "Well, I don't quite do it like that, I do it like this." But if one can create something that's pretty generic and it breaks down visually for people to understand what they need to do, I think that would be very beneficial for our whole industry.

Nataly: Absolutely. I agree. So, now bringing things home for me. So, for Canadian-owned and operated publishers, what are some practical first steps that they can take to begin aligning and planning for the EUDR requirements?

Simon: I think for Canadian publishers, it's a bit small or even UK publishers because we're not in the EU anymore. But one of the practical things you can do is you could start mapping out your own supply chain. You can start working out... You know who your printers are. Where are they getting their paper from? You need to be talking to the people in your supply chain, working backwards and mapping out where everything comes in to you, talking to the printers and saying, "What are you doing on this topic? What have you learnt about it?" And I think that is a practical thing that people can do now.

And there are lots of seminars going on. They're generally being held across the world, I think. Definitely hearing of them, sort of, in North America, presumably in Canada as well, that go and listen to those. Just sign up to them and listen. BIC provides information on its website. We have the BIC Green Hub. And in there, there is information around EUDR and everything that it's doing on sustainability. You've got the FSC and PEFC are providing seminars and talks around all of this, and they are being set at times that are sensible for Canadian publishers that they can tap into this and they can listen.

But I would say, don't panic about it. Just start doing your research now. You've effectively now got 18 months to get yourself prepared. Hopefully, a lot of it will be done by other people, and you can piggyback on that and learn from that. But just start reading up if you haven't already, and be thankful that there has been this sort of year of implementation that we've all been given. And I think that's come about because all the seven commodities that are captured under this regulation are all saying the same thing as like, "How are we meant to work with it? How are we meant to use it? Because we're all trying to do the same thing." Although whether you're talking about coffee or you're talking about paper or you're talking about a chair or something or even comes down to the wood sometimes used in the heels of shoes, those can be FSC, but it's still got to be known about and so forth so...

Nataly: Absolutely. That sounds like a great plan. And we will actually be sharing a link to a presentation that Graham Bell from EDItEUR did a few days ago for BISG and BookNet Canada precisely about this topic from the metadata and perspective and how to leverage ONIX for the sharing of this information. So, everyone, please watch that. It will be very helpful.

What about publishers with multinational counterparts and suppliers? What do you think will be expected from the Canadian publishing houses versus their distributors and data providers, etc.?

Simon: I would say it comes back to mapping your supply chain and here it is, it's working out whether you're an operator or you're a trader. An operator is anyone who makes a product available on the European market for the first time or exports from the EU. You have a slightly different requirement being an operator to being a trader. As being a trader, you're more likely to be creating a due diligence statement or working with your suppliers, but it's the operator who has to make sure that the due diligence statement, kind of, goes with the paperwork. It's just another piece of paper or might be on an invoice or a packing requirement but goes with all the packing requirement documentation to say, yes, this is all certified as being deforestation-free, land degradation-free, and you can follow all the chain of custody through all these due diligence statements back to the original mill and creation and where they say, "Well, these trees all came from this area and we can guarantee that that hasn't actually happened." It's working with your suppliers, working out what your role is, what their role is, and your role can change depending on where you are and what you're doing slightly differently.

Nataly: Yeah, it sounds like regardless of what role your organization has in the book supply chain, it is still important to get familiar with this and figure out like what is it that you will have to do, what it means for you in your particular context.

Simon: Yes.

Nataly: Just get as much information as you can early on.

Simon: Yeah, because I assume, and correct me if I'm wrong, but Canadian publishers will probably be using a freight forwarder or a shipper or something, or they might even be using, I don't know how much they use, say, a distributed print model whereby they're printing not only in Canada but maybe in the UK, in Europe as well. And those people down their supply chain line are likely to be the operator of placing Canadian publications on the EU market. And they're the ones that need to do that final bit to make sure that they've got all the information necessary. So, in that sense, a Canadian publisher is going to be a facilitator of making sure that the documentation and the information can flow freely through all the systems.

Nataly: Thank you. Thank you. Are there any tools, resources, or partnerships that you recommend for non-European publishers to better understand and comply with the EUDR?

Simon: Yes, as I've already said, if you look at the BIC Green Hub, there's a big bite on this topic. I've actually done an update to it because of the updates that we've just had and we'll be doing that sort of thing. Look at FSC, look at PEFC, look at their websites. Go to their seminars. Maybe your paper mills or someone you're hearing or printers. In the UK, there's a printer who's been doing a lot about this to help their customers and just see what is available. Look for various things, sign up for them and attend as much as you can. There is information out there. There are slides and various things on people's websites that help you with this.

Nataly: Thank you. And finally, our last question. While the EUDR is a major policy, what are your thoughts on sustainable publishing? As we approach the end of 2024, do you think that EUDR is it or is there more that the industry can build upon as we look to 2025?

Simon: EUDR is not it. There is always more that we can do as an industry, as the world needs to. BIC has its Green Work Plan, which was created by its Green Supply Chain Committee, that is looking at all aspects of the supply chain and how we can improve things, how we can make things more sustainable. One of the major projects that I'm working on, and we're now in part 3 because we had to cut it into parts to make it manageable, is around design for recycling and how can we make our books so that they are more sustainable. What can we do with the initial design? Thinking about that from when we're starting to produce a book all the way through to its end of life. Part 3 is now looking at the manufactured book to end of life. So, we're looking at all the packaging that is used in the supply chain and what happens with that and what companies are doing.

And I would say actually what we're not very good about as an industry is shouting about all the good stuff that is going on. You talk to printers and you talk to people in the supply chain and they will say, "Actually we're recycling 98% or more of all of our waste." There are regulations on how chemicals are dealt with and everything. We hear a lot of negative stories but we're not hearing the positive stories. Actually, that's a really high percentage of the byproducts you've got or whatever, what they're being used for and what's done with them. So, there are things like that, working towards publishers and sustainability.

If you're working on the UN SDGs, there's one around education. Well, this is where the publishers have a great thing because if you're publishing around sustainability and all the good things, then you're pushing that information out there. You're making it available to people. And I think something that is required on all of us, there's a lot of disinformation. There's a lot of greenwashing and stuff. As much as we can, we need to knock that down and get the truth out there. That's something major that people can do more going forward is, sort of, what is the truth behind this? There's a comment that comes out and I said, "Is that really true? What is actually going on here?" Back to what I've already said, there's a lot of positive stuff that we are doing as an industry worldwide and that needs to be talked about more.

Nataly: Absolutely, I agree. So, we have a Tech Forum series. It's an educational series that we do. They're virtual webinars that we host once every month or a couple of times per month. And in one of those, for example, we invited three publishers, different sizes in terms of operations. And they talked about all the things that they were doing in terms of sustainability, big and small. And we were all pleasantly surprised to learn exactly what you were saying, right? Yes, sustainability is something that can feel very overwhelming or unachievable, but there are people doing the work and there's a lot that is being done in different capacities, small and big. And we will also be talking about sustainability again in a session in January where we are going to have Fanny from EIBF talking about a recent study that they did about sustainability from the bookselling perspective. And we are going to have actually a bookseller from the UK joining us. They are a B Corp, and they have been doing amazing work. It's always nice to hear about all these stories that sometimes get overlooked.

Simon: To add to that, everyone says, "Oh, we don't have the money, we don't have the time," or whatever. I'm arguing against that it's true, and the big companies are doing an awful lot, but sometimes the big organizations have to take a long time to do this. They have to go through so many hoops to get approval, to get money to do stuff. Whereas a small organization can turn around and say, "Well, let's try this. Oh, great, that really worked," or, "No, it doesn't work." But because they are small, they can be dynamic and they can try something completely different on one product because that's what the author wants or something and say, "Wow, that really worked or it didn't work, but we learnt all of this from it." So, they can be very nimble and do things differently.

And I think you shouldn't get bogged down in the fact of, yes, it does take time and it can take money, but it doesn't mean that you can't throw away those constraints and actually do something completely different. Then everybody might pick up. As an example, there's a publisher over here that does a lot of large-print books, and they're also a distributor, and they mainly go to libraries. And in the UK, libraries cover books in extra plastic to protect them and everything. And the managing director of the company said, "I'm not going to do that anymore." There was only one library that was very hesitant and they explained and they said, "Right, well, if the book falls apart within five years or whatever, we'll give you another one for free." And they've now gone plastic-free on their books because they're confident that they will stand up to it. And that is removing an amount of plastic from the ecosystem. Well, shall we say the publishing ecosystem and the life of a book and so forth. And that's someone small just saying, "I'm going to do something differently and see how it works."

Nataly: I love that. Well, Simon, we've reached the end of our questions. Thank you so much for taking the time to meet with me, have this conversation, share your expertise with us. I also would like to thank Karina from BIC for helping us make this interview happen. I am very excited to see where this legislation might take us. I feel like it's going to be a stepping stone towards a more sustainable book supply chain. So, let's hope for that.

Simon: I hope so too. And thank you very much. It's been my pleasure. This is a very interesting topic, and it's not going anywhere. So, we all need to keep working and keep moving forwards on it all.

Nataly: If you're interested in learning more about the EUDR, check out the links in the episode's transcript. I highly recommend watching Graham Bell's webinar, EUDR and ONIX: A Supply Chain Lunch & Learn, which the BISG and Tech Forum, BookNet's educational series, hosted in partnership. In this webinar, Graham discusses the impact of the EUDR, the responsibilities it places on publishers, distributors and retailers, both within and outside the EU, and the importance of data collection and record-keeping regarding the sources of raw materials used in the book industry. He also explains how ONIX is used to communicate essential metadata for regulatory compliance.

Before I go, I’d like to take a moment to acknowledge that BookNet Canada’s operations are remote and our colleagues contribute their work from the traditional territories of the Mississaugas of the Credit, the Anishinaabe, the Haudenosaunee, the Wyandot, the Mi’kmaq, the Ojibwa of Fort William First Nation, the Three Fires Confederacy of First Nations (which includes the Ojibwa, the Odawa, and the Potawatomie), and the Métis, the original nations and peoples of the lands we now call Beeton, Brampton, Guelph, Halifax, Thunder Bay, Toronto, Vaughan, and Windsor. We encourage you to visit the native-land.ca website to learn more about the peoples whose land you are listening from today.

Moreover, BookNet endorses the Calls to Action from the Truth and Reconciliation Commission of Canada and supports an ongoing shift from gatekeeping to spacemaking in the book industry. The book industry has long been an industry of gatekeeping. Anyone who works at any stage of the book supply chain carries a responsibility to serve readers by publishing, promoting, and supplying works that represent the wide extent of human experiences and identities in all that complicated intersectionality.

We, at BookNet, are committed to working with our partners in the industry as we move towards a framework that supports "spacemaking," which ensures that marginalized creators and professionals all have the opportunity to contribute, work, and lead. We'd also like to acknowledge the Government of Canada for their financial support through the Canada Book Fund. And of course, thanks to you for listening.

Podcast: An introduction to the European Union Deforestation Regulation

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