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Associazione Italiana Editori

AIE

L’ Associazione Italiana Editori è l’associazione di categoria, aderente a Confindustria, degli editori italiani –e di quelli stranieri attivi in Italia- di libri, riviste scientifiche, di prodotti e contenuti dell’editoria digitale.

Lobbying Activity

Meeting with Mario Furore (Member of the European Parliament) and Paramount Global

20 Nov 2025 · Copyright and AI

Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

13 May 2025

The Italian Publishers Association (AIE) appreciates the opportunity to contribute to the present consultation and fully supports the goal of ensuring legal clarity for operators, traders and surveillance authorities on the categories of products falling within the scope of the EUDR. As representatives of book publishers, we particularly welcome further clarifications regarding the exclusion from the scope of packing materials and packing containers and of accessory materials (namely marketing materials), when not placed on the market on their own. This exclusion should encompass items such as boxes used to keep together a series of books in a collection, which are distributed and sold together with the books; and point-of-sale advertising displays made of cardboard, which hold or accompany certain books, and are distributed with the books and can be reused. The relevant part of point 2(kk) in the annex to the draft delegated regulation could be integrated to this end to read used exclusively to support, protect, carry, hold together or display another product. Any other clarification aiming at the same goal would be beneficial. We also welcome the intention to further clarify the situation of waste, second-hand and used products with a view to encourage circular and resource-efficient practices. Another specific feature of the book supply chain is the practice by retailers to return unsold books to publishers. These books are then destined to pulping (and recycling) or reintroduced into the commercial circuits. In both cases, they will have been already subjected to a complete chain of due diligence up until the retail stage. It would be disproportionately burdensome to keep goods at the end of their lifecycle, or unsold goods going back into commercial circulation to prevent waste, subjected to EUDR obligations well beyond a completed chain of due diligence. We recommend integrating the relevant part of point 2(ll) in the annex to the draft delegated regulation to read not including used, second-hand and returned products. On a related note, it is worth noting that books and other printed publications were not included in the original Commission proposal and therefore have not been included in the EUDR impact assessment. The complexities for a sector that is so remote from the beginning of the supply chain and therefore was excluded from the EUTR have not been adequately assessed. The magnitude of the information requirements at the stage of book manufacturing and commercialisation is staggering and risks seriously disrupting supply chains and possibly ending book imports altogether. Provisions such as allowing non-EU companies involved in supply chains to use the Information System to pass relevant data along to operators subjected to the EUDR are therefore essential. We also call for a sectorial dialogue with the Commission to address certain specificities of our sector.
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