March 8, 2024
The Honorable Katherine Tai
United States Trade Representative
500 17th Street NW
Washington, DC 20508
Dear Ambassador Tai:
We write to express our concern about the potential effects of the European Union Deforestationfree Regulation (EUDR) on U.S. paper and pulp producers, which becomes enforceable in 2025.
We are concerned that the rule will negatively impact U.S. producers by imposing costly
requirements on U.S. exporters that will limit market access for the $3.5 billion in U.S. forestderived products entering the European Union (EU) annually. We appreciate the United States
Trade Representative’s (USTR) attention and engagement on EUDR and urge USTR to continue
to engage with the European Commission (EC), EU member states, and the World Trade
Organization (WTO) to ensure that U.S. paper and pulp producers are treated fairly under theseEU regulations.
The U.S. paper and pulp industry is the global leader in sustainably managing forests andproduces essential items such as baby diapers, toilet paper, boxes, packaging, and printingwriting paper. The industry collectively manufactures $350 billion worth of products, directlyemploys more than 920,000 Americans, and indirectly supports more than two million jobs.
Protecting the long-term health and stability of U.S. forests through sustainable practices haslong been a cornerstone of the industry.
While we applaud the EU’s commitment towards reducing deforestation, the EUDR, as currently
written, presents significant compliance issues due to its stringency and ambiguity. One specificconcern is the traceability requirement. The EUDR imposes a geolocation traceability
requirement that mandates sourcing to the individual plot of land for every shipment of timberproduct to the EU. In the U.S., 42 percent of the wood fiber used by pulp and paper mills comesfrom wood chips, forest residuals, and sawmill manufacturing residues – wood sources thatcannot be traced back to an individual forest plot. The EUDR traceability requirement will benearly impossible for a significant segment of the U.S. paper and pulp industry to comply with.
Additionally, the EUDR imposes a concerning requirement that for all timber and timber-derived
products entering the EU, the originating landowners be identified and their contact information
be made available. This requirement risks disclosure of confidential information between
business partners and could disrupt long-standing landowner-producer relationships.
Additionally, it is concerning that the regulation does not identify who would have access to thisproprietary data or how the data would be used for enforcement.

Proper stewardship has led to an American ecosystem of forests that are healthy and growing.
According to the U.S. Forest Service, more than one billion trees are planted each year in theUnited States and total forest area increased by 18 million acres between 1990 and 2020. That is
why we urge USTR to engage with their EU counterparts to ensure that EUDR implementation
focuses on countries in which illegal deforestation is occurring.
As USTR continues to engage with European regulators, we urge the agency to seek clarity on
the EUDR’s traceability requirements, data reporting, and country benchmarking. We ask that
USTR encourage the EU to recognize that the United States has robust regulatory standards toprotect the long-term health of U.S. forests. This will help American paper and pulp producers
achieve compliance under these new standards and ensure that the United States and theEuropean Union can maintain its mutually beneficial trade relationship in paper and pulp
products.
We appreciate your attention to this matter and for your consideration of these concerns. We ask
that you keep Congress apprised of relevant developments as they occur.

Sincerely,________________________
Marsha BlackburnUnited States Senator________________________
Angus S. King, Jr.
United States Senator________________________
Ted BuddUnited States Senator_________________________
Debbie Stabenow
United States Senator________________________
Bill Hagerty
United States Senator________________________Mark Warner
United States Senator________________________
Thom Tillis
United States Senator_________________________
Raphael Warnock
United States Senator________________________
John Boozman
United States Senator_________________________
Tammy Baldwin
United States Senator________________________
John Kennedy
United States Senator_________________________
John Cornyn
United States Senator________________________
Susan M. Collins
United States Senator_________________________Tim Kaine
United States Senator________________________Tim Scott
United States Senator_________________________
Mike Braun
United States Senator________________________Tommy Tuberville
United States Senator_________________________
Amy Klobuchar
United States Senator________________________
Katie Boyd Britt
United States Senator_________________________
Lindsey O. Graham
United States Senator________________________
Roger F. Wicker
United States Senator_________________________
Bill Cassidy, M.D.
United States Senator________________________Tom Cotton
United States Senator_________________________
Rick Scott
United States Senator________________________
Ted Cruz
United States Senator________________________Ron Johnson
United States Senator________________________
Marco Rubio
United States Senator

CC:
The Honorable Thomas J. Vilsack
United States Secretary of Agriculture
The Honorable Gina M. Raimondo
United States Secretary of Commerce