Printing company M has the print job for its customer produced by printing partner G for capacity reasons. For this purpose, M orders the required paper from the paper supplier. However, printing partner G orders the paper directly from the same paper supplier. After production, G delivers the finished but not yet processed brochure back to the production facility of printing company M. The latter produces the semi-finished product (flat printed sheets) into a finished print product (wire-stitched brochure) during further processing. This is because he has to add another printed product to the brochure.
Is a separate DDS required for each sub-product – printing the semi-finished product and producing the brochure from the semi-finished product?
3 Answers
Anonymous User
Hi Matteo,
Here is my take:
Company M must reference all relevant Due Diligence Statements (DDSs) for the semi-finished components used in the final product when preparing the DDS for the EUDR-relevant finished product. In this case, the final brochure includes:
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- Flat printed sheets produced by printing partner G, and
- An additional printed product processed by company M.
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Therefore, both semi-finished products must have their own DDS, and these must be referenced in the DDS for the final product.
Even if both semi-finished products originate from the same paper supplier, the supplier must still communicate the specific paper batch used to both printing partners (M and G). This is essential because:
- The batches may differ,
- The paper could come from different countries of origin,
- And the traceability required by the EUDR depends on batch-level information.
The key consideration is whether the semi-finished product undergoes a change in HS code when it is turned into the finished product. If the new HS code is covered by the EUDR, then the finished product is considered a new relevant product, and a separate DDS must be submitted (possibility to reference existing DDS of all relevant semi-finished products contained).
If there is no mixing of materials (i.e. all paper sheets come from the same batch with a valid DDS), company M can simply reference the DDS from the semi-finished product when preparing the DDS for the finished product. However, if there is mixing of products (e.g. paper from different batches), company M must reference each relevant DDS corresponding to the semi-finished components used.
Regards,
Gabriel
