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?
1 Answer
Anonymous User
Dear Matteo, thank you very much for describing your case. In principle, a DDS must be submitted before any relevant product is placed on the market, made available, or exported.
However, whether this is necessary in any specific case depends on many factors. First of all, it must be a relevant product within the meaning of the EUDR. This should usually be the case for paper and brochures. However, exceptions apply, for example, if the paper is 100% recycled. Furthermore, the type of company (SME or not) and its classification under the EUDR (operator or trader) also play a role in the obligation to prepare a DDS. Likewise, the definition of making available on the market and the required “supply” in the meaning of the EUDR depend on national law and the particular situation.
I would recommend checking in advance, based on Annex I to the EUDR, whether a relevant product is actually present in the respective steps and in what capacity company M is acting. Furthermore, the contractual specifics should be assessed.
