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 Respuestas
Usuario anónimo
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:
-
-
- Flat printed sheets produced by printing partner G, and
- An additional printed product processed by company M.
-
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
Usuario anónimo
Hello Lisa
Thank you very much for your detailed feedback. What I left out of my scenario.Both companies are affected in the first wave due to their size.
The question is aimed at determining whether the last company in the supply chain, which does the mailing for export to the DACH region, is responsible for the DDS or whether the client (in this case printing company M) must pass this on to its service provider (in this case printing company G) in terms of order processing. I have not yet found any reference to this use case in EU Traces.
Kind regards, Matteo
Usuario anónimo
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.