Category: Public Affairs

While this document isn’t legally binding, we hope it’s a handy resource for you and your suppliers.

At the end of last year, the EU Deforestation Regulation (EUDR) was formally revised to include an exemption for printed products and a further one-year delay before implementation.

These changes aim to simplify its implementation and ensure that operators, traders, and authorities are adequately prepared. For organisations whose products are still under scope, the application of the regulation has been delayed to 30 December 2026 for large/medium operators and 30 June 2027 for micro/small operators.

Specific regulatory changes

On 17 December 2025, the Parliament formally adopted the political agreement. On 18 December, the Council confirmed they had formally endorsed the agreement. And on 23 December, the Regulation amending the EUDR went through its final stage by being published in the Official Journal of the EU:

“In Annex I, in the table, the line ‘ex 49 Printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts…’ is deleted”

Products that come under the EUDR’s scope are listed in its itinerary, which uses HS (Harmonized System) Codes: a standardised numerical method used internationally to classify traded products.

The amendment quoted above expressly removes all products under HS Code 49. In the European Database, Chapter 49 covers “printed books, newspapers, pictures and other products of the printing industry; manuscripts, [and] typescripts”.

Under Chapter 49, HS Code 4902 covers “newspapers, journals and periodicals, whether or not illustrated or containing advertising material”. Magazines are therefore exempt from EUDR.

Items that remain under EUDR’s scope have implications for suppliers

While products under HS Code 49 have been removed from EUDR’s scope, those under HS Code 48 remain, carrying implications for suppliers. In the European Database, Chapter 48 covers “paper and paperboard; articles of paper pulp, of paper or of paperboard”. A full list of products that fall under this code can be found here.

Paper:

• Once publishers print on paper, it becomes a printed product, which is exempt from EUDR.
  
  
• Publishers exporting printed products, such as magazines, into the EU will not be required to have done due diligence or to show evidence of their suppliers’ due diligence.

Packaging products sold in bulk:

• From 2027, companies that sell packaging products will be required to evidence compliance with EUDR.
  
  
• Once packaging products are used to package a printed product, they will be exempt from EUDR.
  
  
• Publishers packaging printed products to ship into the EU will not be required to do due diligence or show evidence of their suppliers’ due diligence.

Looking forward

This exemption is an important recognition of the publishing sector’s existing high standard of sustainability and the lower deforestation risk associated with printed products.

The EUDR contains a review clause which leaves open the possibility that commodities can be added (or removed) in the future. It is therefore prudent for businesses, even those whose products are not currently in-scope of the Regulation, to continue to monitor relevant policy developments.

This means that an ongoing commitment to sustainable best practice and awareness of environmental impact will continue to be important for publishers.

Within the context of EUDR, this could include monitoring any potential deforestation risk associated with products purchased outside of EU territories; on top of existing compliance activities such as the FSC (Forrest Stewardship Council), PEFC (Programme for the Endorsement of Forest Certification), and other sustainability certifications.

As part of the revision, a mandatory simplification review has been scheduled for completion by 30 April 2026, which will focus on streamlining due diligence and improving IT system functionality. More details will follow its completion, but we do not currently foresee this introducing any new requirements for publishers.

As it stands, from 2027, publishers should not be required to engage in EUDR. The PPA will continue to monitor the landscape and will provide prompt updates of any further changes.

Contact charlotte.jeffreys@ppa.co.uk with any questions.

This comes after the CMA gave the platform “Strategic Market Status” under its new digital competition regime last year, ruling that Google has substantial market power.

The publisher conduct requirement is intended to address the lack of meaningful choice for publishers; insufficient transparency over how content is collected for search and used in Google’s generative AI responses; and the lack of appropriate attribution when Search Content is used.

Specifically, the proposed publisher requirements are: 

1. Effective controls 
    
   Google will be required to provide “effective controls”, allowing publishers to withhold their Search Content from being used in the training and grounding[1] of broader generative AI services. As well as from the grounding of Google’s search generative AI features. Google must ensure these controls evolve appropriately as generative AI services and features develop. 
    

2. Transparency and metrics 
    
   Google will be required to publish clear information explaining how Search Content is used for training and grounding across its generative AI services and features, including the scope and effect of the available controls. Google must also provide publishers with clear, detailed metrics on user engagement where their Search Content is used in search generative AI features.  
    

3. Attribution and factuality 
    
   Google will be required to take reasonable steps to ensure Search Content is sufficiently attributed when used in generative AI search features, and to publish clear information explaining the measures it has taken to ensure and assess the factual accuracy of those features. 

The proposed conduct requirement also cover data portability, fairness in search rankings, and user choice architecture.   

The CMA is running a consultation on the Conduct Requirements, which closes on 25 February 2026. The PPA’s Head of Policy and Public Affairs, Eilidh Wilson, is leading on a response.  

Sajeeda Merali, PPA, CEO made the following statement: 

“Publishers are looking for proof, proper checks, and practical enforceability. The wish list is simple: clear data on how AI affects visibility, reliable guarantees that opting out won’t disadvantage them, and an auditable system so we can independently verify what’s happening in practice. 

On visibility, publishers want to know when their content is used in AI overviews, how it is attributed, and what traffic patterns follow. It’s vital that Google builds a reporting infrastructure that delivers the granular, auditable data that publishers are looking for. 

This means providing verifiable, like-for-like performance data covering both classic search and AI overviews. Publishers will need to see stable indexing, unchanged rankings, and no reduction in referral quality or volume. Anything less leaves too much uncertainty for an already fragile digital advertising environment. 

Self policing alone would not be sufficient. These measures only work if they are backed by clear obligations, external oversight, and enforceable consequences for non-compliance. That’s precisely why the CMA’s proposed conduct requirements matter: it introduces independent scrutiny for the first time and must be supported by an infrastructure that will enforce the requirements. 

Opt out is an essential safeguard, but it doesn’t resolve the wider value exchange question. AI Overviews still replace clicks in many contexts, and without a clear model for licensing, the commercial imbalance remains. Today’s proposal is a major step forward, but it is not the end of the conversation on publisher compensation. 

Overall, this consultation provides an encouraging foundation for a fairer digital marketplace. We will continue to engage constructively with the CMA and our members throughout the upcoming consultation period to ensure the final requirements deliver the clarity, safeguards, and accountability that publishers urgently need.” 

If you have any questions, or would like to find out more, please get in touch: eilidh.wilson@ppa.co.uk 

Footnote: [1] the PPA interprets grounding as the process of connecting an AI mechanism to an external data point (such as publisher Search Content) in real-time for features such as fact- checking.  

Edwards was clear that while the ICO shares the government’s interest in economic growth, it does not take direction from ministers on how to balance growth against data protection.

He said, “[the ICO] have a statutory obligation to act independently… there’s a limit in the granularity that government can deliver in terms of directing an independent office such as ours”.

Edwards noted that he does not feel pressure from the government to change the ICO’s approach to risk or enforcement, affirming that the ICO is “trusted to make those decisions.”

The ICO is an executive non-departmental public body, sponsored by the Department for Science, Innovation, and Technology. You can find more about their work, here. 

The ICO is reviewing evidence from stakeholders on ad tech regulation and consent requirements, including from the PPA. They are expected to publish a response in due course.

The PPA is also coordinating with the ICO to arrange a meeting later this year to discuss publishers’ views on their work. If you wish to discuss these issues further, please contact eilidh.wilson@ppa.co.uk

Officials are regularly engaging with the Information Commissioner’s Office (ICO), which is gathering evidence from technical experts and industry leaders on how online advertising operates in practice.

The ICO is currently considering whether additional exceptions to cookie consent requirements could be justified, particularly for “lower-risk” uses, and is expected to make formal recommendations to the Government this year.

The Government has not yet reached a position on the balance between contextual and personalised advertising, nor has it confirmed a formal comparative assessment of their economic and privacy impacts.

However, ministers have acknowledged that some uses of cookies are lower risk and that privacy-enhancing techniques such as pseudonymisation can further reduce privacy concerns.

Government officials have met with the PPA and other trade bodies – committing to further engagement with stakeholders before deciding whether to proceed with any new exemptions.

Ministers noted that while the importance of the publishing sector and advertising-funded content is recognised, the economic impact of any new regulatory approach will be assessed once the ICO’s recommendations are received.

The PPA has contacted the ICO to request a meeting with its new Director of Regulation to discuss this work and will engage relevant members on next steps as appropriate.

Members wishing to discuss these issues with the PPA Public Affairs team can contact eilidh.wilson@ppa.co.uk

From 5 January 2026, ads for “identifiable” less healthy food and drink products will be banned from appearing:

• on television and on-demand programme services between 5:30am and 9:00pm 
• in paid online media at any time
  
  

The final rules reflecting each restriction are accompanied by advertising guidance on their implementation, which you can read here.

Advertisers must ensure that their ads comply with the new rules. This applies to all new ads and existing ads appearing on or after 5 January 2026.

The Advertising Standards Authority (ASA) strongly encourages advertisers to use the secondary advice resources and to seek further advice through their Copy Advice service. For broadcast clearance matters, advertisers should contact Clearcast.

You can read the Committees of Advertising Practice regulatory statement here and their consultation outcome and guidance here.

On 18 December, the European Council formally adopted a targeted revision of the EU regulation on deforestation-free products (EUDR).

To reduce administrative burden, certain printed products (such as books, newspapers, magazine, printed pictures) were removed from the scope of the regulation, reflecting the limited deforestation risk associated with these items. The revision streamlines the due diligence requirements and postpones the application of the regulation for all operators until 30 December 2026, with an extra six-month cushion for micro and small operators. 

This means that publishers and their partners can pause efforts to achieve compliance with EUDR while the exemption of printed products is formally adopted, which should go ahead at the end of 2026.

The revised regulation will be published in the Official Journal of the European Union and enter into force three days after publication. It is stressed that the revisions will not legally take effect until they are published in the Official Journal.

Overall, this is good news for the publishing sector. It appears that there will no longer be any obligations under EUDR for publishers and our value chain partners. The PPA will monitor the situation and provide updates should any changes occur.

For more information, see the official press release here, or contact charlotte.jeffreys@ppa.co.uk.

This statement was delivered in response to commitments made during the passage of the Data Bill, following sustained engagement from the Make It Fair campaign. 

The Secretary of State reiterated the government’s position that any approach must support growth and innovation while also protecting the creative industries. She highlighted the lack of international consensus, referenced the government’s ongoing technical working groups and stakeholder engagement, and confirmed the intention to publish an economic impact assessment next year. 

The PPA has secured representation on the government’s technical working group on licensing and is working closely with members to advocate for transparency requirements as a means of supporting the growth of the emerging AI licensing market.  

You can read Liz Kendall’s full statement here.  

For more information about this, please contact eilidh.wilson@ppa.co.uk  

The BBC’s Royal Charter serves as the BBC’s constitution and mission statement. The Charter requires the BBC to act in the public interest, serving all audiences through the provision of impartial, high-quality, and distinctive output and services that inform, educate, and entertain. As the BBC’s regulator, Ofcom monitor the BBC’s adherence to the framework set out in the Charter, including any market impacts on competitors.  

The review comes during a challenging period for the BBC, with the threat of a lawsuit from US President Donald Trump, long-standing questions on impartiality and audience trust, and declining licence-fee income amidst a rapidly evolving media landscape that carries increased global competition. The review, which recognises the BBC as “not just a broadcaster but a national institution”, will consider what reforms are necessary to futureproof the BBC. 

The review sets out four priority areas for the future of the BBC: that it should be a trusted institution; deliver services for the public good; drive growth across the UK; and receive sustainable and fair funding. Within these areas, a variety of different policies are proposed for consideration. The bulk of the paper is focused on the BBC’s broadcasting and radio/audio outputs.  

Most notable for publishers will be proposed reforms to regulation aimed at increasing the BBC’s partnerships and reform of the licence fee, which could open the door for more commercial options such as advertising or subscription models. 

The current consultation, known as a Green Paper, will close on 10 March 2026. Once that feedback has been collated, a further policy document, called a White Paper, is expected to be published later in the year. Following another consultation period, and reflecting any changes from that, the final Charter will be granted from 2028. This will replace the current Charter, which is due to expire at the end of 2027. 

The PPA will consult members in the New Year and respond to the consultation in due course.