DDS management for impregnated paper applied on a recycled particleboard (out of EUDR)
If Company (A) purchases raw paper and sells to Company (B) impregnated paper, the correct flow of DDS will be:
- Company A receives DDS from paper-mill with geodata
- Company A impregnates this paper and sells it to a company of the same group (B) that will apply this paper on a 100% recycled particleboard (out of EUDR). In this way, Company A will submit new DDS with only a link to the previous DDS received from the supplier of raw paper and will send it to Company B.
- Company (B) will submit a new DDS with only a link to the previous DDS received from Company A, and will send it to the final customer.
In this case the focus is to give at the end of the chain only the traceability of the raw paper used for a specific batch of recycled particleboard. The process of impregnation and prodcution of pressed particleboards are not relevant for EUDR (also the production of 100% recycled particleboard is out).
Is correct this flow?
2 Answers
Anonymous User
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).
Anonymous User
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:
- Company A buys raw paper → receives a DDS from the paper mill (including geolocation of origin of the raw material – wood pulp).
- Company A impregnates the paper → transforms it but doesn’t introduce new EUDR-relevant material → sends it to Company B (internal group company).
- Company B applies the impregnated paper to a 100% recycled particleboard (not in scope of EUDR) → sends the final product to the end customer.
- 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.
