Hi everyone,
We import mat boards (passe-partout) from China and are currently looking into our EUDR compliance.
According to the information from our supplier, the Chinese paper mill uses bleached kraft pulp from different origins: Finland and Uruguay.
- For the hardwood pulp from Uruguay, we receive land parcel (geolocation) data.
- For the softwood pulp from Finland, no land data is provided. The explanation is that the Finnish supplier will generate a DDS number for export, and that we should use this DDS number for our own DDS.
We have a few questions and would really appreciate your insights:
- Can we rely on a DDS number from an EU exporter?
The exported product is bleached kraft pulp (HS 47032100), while our imported product is mat board (HS 4807008000) , both under Annex I of EUDR. Is it allowed to rely on that DDS in this case? - What about missing geolocation data?
If no land parcel data is provided for the Finnish pulp, can the DDS number from Finland replace this requirement? - Future compliance after 31 Dec 2026
Looking ahead, we see a potential issue: part of our product may lack both geolocation data (for the Finnish pulp) and an export DDS, as this requirement will only apply from December 31, 2025.
How should we handle this when submitting our DDS?
Thanks a lot in advance for your help!
1 noch keine Antwort
Anonymer Benutzer
Hi Michaela,
Let me answer to your questions.
In general you are allowed to use suppliers’ DDS reference number for your own DDS. Yet, you have the obligation to make sure and potentially audit the material flow, make sure that no mix of non-traceable source happens and that the supplier’s DDS is actually valid. For this, you need to have access to the geo-location data of all input materials of your product including the Finnish parts. Only with this access, you can ensure that the DDS is valid.
If you do not have access to this geo-location data, you need to require your supplier to provide this information as you are otherwise not able to put your product on the market.
I’m happy to discuss this with you in more detail. Send me a mail if needed to: mark.mrosek@westernacher.com
BR
Mark