DDS management for impregnated paper applied on a recycled particleboard (out of EUDR)

Dear Iacopo,

Sorry for the late reply, but therefore more extensively 🙂

Thank you for the very clear and relevant follow-up, Iacopo. This is a key question when it comes to the practical implementation of EUDR in real-world production processes with batch-based raw materials and partial usage over time.

Yes, in each final DDS, you need to specify only the actual quantity of in-scope raw material used for that specific delivery — not the full purchased amount. Partial usage, waste, or non-compliance must be accounted for by accurate material allocation and documentation at batch level.

Detailed Explanation
1. Partial Use of Raw Materials

EUDR requires traceability down to the plot of land for each kg or m³ of in-scope product placed on the EU market.

Therefore:

• If from your 3.000 kg raw paper and 10.000 kg virgin pine wood you only use:
  • 1.000 kg raw paper
  • 3.000 kg virgin wood
    …then your DDS must reflect only these quantities for this specific product batch/delivery.

DO: State used quantity per batch (not full batch size).
DON’T: Report full purchased quantity unless fully used in the same delivery.

2. Per-Delivery Quantity Specification

Each DDS must match the actual quantities of in-scope materials used in that delivery. That means:

• For every delivery, generate a DDS that includes:
  • Raw paper: batch ID + quantity used (kg)
  • Virgin wood: batch ID + quantity used (kg or m³)
  • Reference to upstream DDSs
  • Processing steps (e.g., impregnation, pressing)

This supports traceability and prevents over-reporting.

3. Waste and Non-Compliant Material

Waste or rejected production is not part of the DDS, as it is not placed on the market.

But you should:

• Track waste internally (for audit trail)
• Subtract it from the batch’s available quantity
• Only include usable, compliant output in DDSs

Tip: Consider implementing a material reconciliation report, which helps you link:

• Input batch quantities
• Quantities used per production order
• Waste quantities
• Output quantities (per DDS)

  Suggested Best Practices  ( sorry tables are difficulkt in this form here )

Topic                                                                Recommendation

Raw material tracking                                         Use batch-level tracking in ERP or MES

DDS generation per delivery                               Automate creation based on production order BOM

Waste tracking                                                    Exclude from DDS, but keep documentation internally

Shared batches over customers                           Split quantities logically and reference original batch in each DDS

Traceability tools                                                 Osapiens HUB, SAP Batch Management, or equivalent DDS-capable tools

Example Template for DDS (Simplified)

Component                            Batch                           Quantity Used                              Reference DDS

Raw Paper                         RP-2025-001                            1.000 kg                                DDS-XXXX (from A)

Virgin Wood Pine                 WP-2025-017                             3.000 kg                           DDS-YYYY (from Supplier)

Product Output         Fibreboard + Melamine Paper           Delivery #ABC123                         New DDS-ZZZZ

Conclusion

• Yes, always report the actual quantities used for the delivery.
• You can reuse batches over time, but must allocate portions in the DDSs accordingly.
• Waste and non-compliant materials are excluded from DDS but must be documented internally.
• Clear traceability and consistent data management are key to EUDR compliance.

Thank you so much Timo for your response, very exhaustive.

In the case of a fibreboard from virgin wood, Company B will reuse DDS received from A concerning the impregnated paper, plus DDS received from the supplier of virgin wood (used to produce fibreboard).

In the final DDS to our customer (fibreboard with melamine paper applied) we have to insert kg of raw paper used and m3 of fibreboard used for each delivery?

For example:

• Purchased Raw Paper: 3.000 Kg Batch XXXX
• Purchased Wood Pine: 10.000 Kg Batch XXXX

We impregnate 1.000 Kg of Raw Paper pressed on fibreboards produced with 3.000 Kg of wood pine (and the remained quantities will be used next month).

How we have to manage the quantities in the submitted DDS in the case of partial production of the same batch of raw material purchased? We have to specify the quantities used in each delivery? And if we have waste during production or non-compliant material how we have to proceed?

The main point of this question is to understand how to manage in every DDS the purchased quantity (ex. 10.000 Kg) and partial produced quantites (different production orders for different customers).

Yes – your described DDS flow is mostly correct and aligns with the logic and intention of the EUDR. Here’s a detailed breakdown with confirmation and some clarifying notes:

Summary of your scenario:

1. Company A buys raw paper → receives a DDS from the paper mill (including geolocation of origin of the raw material – wood pulp).
2. Company A impregnates the paper → transforms it but doesn’t introduce new EUDR-relevant material → sends it to Company B (internal group company).
3. Company B applies the impregnated paper to a 100% recycled particleboard (not in scope of EUDR) → sends the final product to the end customer.
4. The focus is to track the wood-based raw paper only — since recycled board is out of EUDR scope.

Correct handling of DDS according to EUDR:

• Company A passes the DDS they received from the paper mill without modification, but optionally adds a link/reference to it (or creates a new DDS referencing the upstream one).
• Company B reuses the DDS received from A and passes it further to the customer.
• No new DDS is needed for the recycled particleboard, since it is explicitly out of scope (per EUDR Article 1(3)).

Notes and Best Practices:

• Even if Company B is within the same group, each entity must submit their own DDS when placing a product on the market or processing it further – unless they qualify under the group exemption (still pending further guidance).
• The impregnation process does not alter the EUDR relevance of the raw paper, as it’s a processing step and does not require new geodata.
• The final DDS submitted to the customer/importer should reference the original DDS of the paper mill – traceability to the forest remains intact.

Conclusion:

Yes, your DDS flow is compliant and appropriate. You’re following the EUDR’s intent: ensuring traceability of in-scope raw materials (the paper from virgin pulp), while correctly excluding recycled particleboard from DDS obligations.