INTERNATIONAL PAPER CO /NEW/ (IP) Risk Factors

Recent key developments

Concrete developments — dated events, named agreements and instruments, legal proceedings — that INTERNATIONAL PAPER CO /NEW/ surfaced in its latest filing.

• On February 20, 2026, the U.S. Supreme Court struck down certain tariffs imposed via executive orders under the International Emergency Economic Powers Act, eliminating key tariffs on imports from numerous major trading partners and resulting in potential refunds of previously paid tariffs.February 20, 2026
• New Executive Orders announced on February 20, 2026 restructuring U.S. tariff policy and exploring alternative statutory authorities.February 20, 2026
• The U.S. government in 2025 increased certain tariffs on imports from China, raising risk of retaliatory tariffs.2025
• In 2025, the company agreed to sell its Global Cellulose Fibers business, which was completed in January 2026.2025
• On January 29, 2026, the company announced plans to separate its EMEA packaging business into an independent public company, expected to be completed within 12-15 months.January 29, 2026
• The mill master collective bargaining agreement with the United Steelworkers union expires in August 2027.August 2027
• The mill joint pension council master agreement with the USW expires in September 2027.September 2027
• The converting master collective bargaining agreements expire in April 2028.April 2028
• The converting joint pension council master agreement expires in September 2028.September 2028
• The OECD Pillar Two global minimum tax of 15% has been enacted in countries where the company operates, with the first component effective in 2024 and the second in 2025.2024
• In January 2026, the OECD/G20 issued administrative guidance introducing two new Pillar Two safe harbors for US-parented multinational corporations, effective 2026.January 2026
• The EU AI Act, adopted in May 2024, entered its implementation phase in 2025 and imposes transparency, risk management, and data governance obligations for AI systems.May 2024
• Italian Competition Authority decision concerning anti-competitive behavior in Italy, with claims for compensation arising out of the decision.
• Purported class action complaint alleging violation of Sections 1 and 3 of the Sherman Act, alleging conspiracy to fix, raise, maintain, and/or stabilize prices of containerboard products beginning November 1, 2020.November 1, 2020
• Potential liability for Brazilian taxes under agreements with Sylvamo Corporation, with assessments for tax years 2007-2015 totaling approximately $394 million; International Paper's potential liability is approximately $274 million.
• Material weaknesses in ITGCs identified in DS Smith for fiscal years ended April 30, 2022, 2023, and 2024; management initiated a redesign of ITGCs and intends to implement the redesigned control framework in 2026.2026
• Publicly committed to reducing Scope 1, 2 and 3 GHG emissions by 35% from 2019 to 2030.2030
• Pension plan participation frozen for U.S. salaried employees effective January 1, 2019.January 1, 2019
• Legacy retiree life insurance benefit for a limited group of former employees continues through 2027.2027
• As of December 31, 2025, the U.S. qualified pension plan had a surplus of $366 million, and the UK qualified pension plan had a surplus of $112 million.December 31, 2025