Problem statement
- No batch identification: Delivery batches are not labelled on the pulp bales.
- No batch separation in the warehouse: Storage is not separated by delivery batches; instead, a 'first-in, first-out' principle is applied.
- No traceability after pulping: Once the pulp has been placed in the pulper, it can no longer be assigned to a specific delivery.
- Fluctuating input quantities: Non-relevant raw materials (e.g. recovered paper, fillers) are added in varying quantities.
Practical consequence
Under these conditions, only a 'batch' approach is practicable:
- A production period X is defined during which various raw materials or pulps are processed.
- Precise attribution to individual deliveries is not possible.
- The EUDR permits more origins (DDS numbers) to be stated than are actually contained in the product.
- The information must be provided 'as precisely as possible'; at least once per calendar year, a DDS number must be created covering all origins used.
For paper manufacturers, the use of the average inventory turnover appears to be an appropriate interpretation of 'as precisely as possible'.
Uncertainties and their assessment
This approach inevitably leads to certain inaccuracies:
- Individual pulps may remain in the warehouse longer than the average.
- Other deliveries may be processed and shipped immediately before a new DDS number has been created.
The decisive point, however, is the following:
- DDS numbers are collected and verified for all pulps.
- No relevant raw materials enter production without a verified DDS number.
Due diligence for imports from non-EU countries
If the paper manufacturer imports raw materials into the EU:
- Due diligence: A documented due diligence process must be in place for these shipments.
- Supply chain transparency: The supply chain must be disclosed down to the forest plot level.
- Geolocation data: Geolocation data and harvesting permits must be available for the 'plots' from which the timber originates.
It is expected that pulp mills will soon provide aggregated geolocation data for timber origin areas. Otherwise, these would have to be collected and evidenced on a plot-by-plot basis.
Consideration of EU country benchmarking
- For countries with Benchmark 1 (low risk), no substantive risk assessment is required.
- Data and evidence must, however, continue to be collected and retained in order to remain EUDR-compliant.