EUDR
DDS number usage and missing land data for China imports

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:

  1. 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?
  2. 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?
  3. 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!

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Mark Mrosek Answered question