Hi,
We are concerned about the required timelines and the possibility of inspections by the authorities regarding the creation of DDS to our customers.
We are considering generating a DDS for our semi-finished products, grouped by the first two characters of the HS code. This would help us save time, as we could then use the same DDS for the finished products. Is this feasible with the platform?
Additionally, can we generate a DDS based on the work order number in advance of actual production, potentially overestimating the produced quantity?
Thank you for your assistance.
Best regards,
1 Answer
Anonymous User
Dear Francesco Del Moro,
you raise an interesting point with your question.
In general, the quantities of products declared in the DDS must correspond to the quantities that have been subject to due diligence. In the event of an exceedance of the quantity indicated in the DDS, this means that once the quantity of products covered by the due diligence statement has been fully placed on the market or exported, a new statement must be submitted for any additional quantities by the same operator.
However, an underestimation is generally permissible. It is therefore possible to declare a quantity in the DDS that is ultimately not fully placed on the market or exported. In such cases, the operator should maintain appropriate records explaining the discrepancy between the declared and the actual quantity placed on the market or exported. These records must be retained for five years and made available to the competent authority upon request.
In any case, whenever a DDS is issued in advance, the following should be kept in mind: While it is not necessary for the individual product to have already been manufactured, the relevant commodity should generally have already been produced—that is, grown, harvested, or obtained from or raised on the relevant plots of land or establishments.
Kind regards
Lisa Marie Koop
Hello Francesco,
to check if something is feasable in the platform, I recommend to test it. Also, get yourself a Traces ACCAPTANCE account and create a DDS with 3 digit HS Code manually. We don’t use 2 character HS Codes in our EUDR processes.
Your second questions seems to be for a lawyer. I am interested in whether such questions can also be answered in this forum. We probably won’t get an answer here, but we will discuss how one or other company plans to implement it.