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
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.