Problem Statement
- No batch identification: Delivery batches are not marked on the pulp bales.
- No batch segregation in storage: Storage does not segregate by delivery batch; instead, a "first-in, first-out" principle is applied.
- No traceability after pulping: Once pulp is fed into the pulper, it can no longer be traced back to a specific delivery.
- Fluctuating input volumes: Non-relevant raw materials (e.g. recovered paper, fillers) are added in varying amounts.
Practical Consequence
Under these conditions, only a batch approach is practicable:
- A production period X is defined, during which various pulps are processed.
- Exact allocation to individual deliveries is not possible.
- The EUDR allows more origins (DDS numbers) to be indicated 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, using the average inventory turnover appears to be a reasonable interpretation of "as precisely as possible."
Uncertainties and Their Assessment
This approach inevitably leads to certain inaccuracies:
- Individual pulps may remain in storage longer than the average.
- Other deliveries may be processed immediately and shipped before a new DDS number has been created.
However, what is essential is:
- 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 obligation: A documented due diligence process must be in place for these consignments.
- Supply chain transparency: The supply chain must be disclosed up to the forest plot(s).
- Geolocation data: For the "plots of land" from which the timber originates, geolocation data and harvesting permits must be available.
It is expected that pulp mills will soon provide aggregated geolocation data for timber origins. Otherwise, these would have to be collected and evidenced plot by plot.
Consideration of the EU Country Benchmarking
- For countries with Benchmark 1 (low risk), no substantive risk assessment is required.
- However, data and evidence must still be collected and retained to remain EUDR-compliant.