Exporting Disposable Wooden Tableware to the EU: Core Essentials of DDS Investigation & Collaboration Guidelines for Importers
As a factory specializing in disposable wooden tableware production, we frequently receive inquiries from clients regarding the "DDS Investigation" — compliance requirements for wooden knives, forks, spoons, and food containers in the EU market are becoming increasingly stringent, and whether an order can be finalized directly depends on passing the DDS Investigation. Today, we will break down the DDS Investigation from basic concepts to practical processes, while clarifying how our factory should collaborate with importers to achieve compliance.
First, What is a Corporate DDS Investigation?
DDS (Due Diligence System) is a mandatory compliance mechanism for wood products imposed by the European Union via the EU Deforestation-Free Regulation (EUDR) and EU Timber Regulation (EUTR). Its core purpose is to verify that wooden products use legally sourced wood, have a traceable supply chain, and meet environmental and safety standards.
For our disposable wooden tableware factory, the DDS Investigation is not a "routine procedure" but a "compliance audit" covering the entire product lifecycle: For example, does the wood used for wooden spoons come from legally harvested forests? Does the coating on food containers contain excessive formaldehyde? Is there a risk of "mixing legally sourced and illegally sourced wood" in the supply chain? All these questions must be verified through the DDS Investigation.
Full Risk Assessment Process of DDS Investigation (with Practical Cases for Wooden Tableware)
Aligned with the production characteristics of disposable wooden tableware, the DDS risk assessment follows three steps — "Information Collection → Risk Identification → Risk Mitigation" — with clear industry-specific requirements for each step:
1. Step 1: Information Collection — Map the "Origins and Lifecycle of Wooden Tableware"
This is the foundation of risk assessment; missing any piece of information may lead to investigation failure. Our factory must focus on preparing the following information:
| Information Category | Special Requirements for Wooden Tableware |
| Wood Source Info | Latin name of the wood species (e.g., birch Betula platyphylla), GPS coordinates of the felling area (accurate to within 1km²) |
| Supply Chain Qualifications | Felling permits from upstream logging facilities, business licenses of wood processing plants, fumigation certificates |
| Product Safety Documents | Formaldehyde emission test reports (EU requirement: ≤1.5mg/kg), antifungal agent residue tests (compliant with EU No 10/2011) |
Environmental Certifications | FSC / PEFC (Programme for the Endorsement of Forest Certification) certifications (prioritize certifications covering the wood species used) |
2. Step 2: Risk Identification — Pinpoint "Compliance Risks for Wooden Tableware"
Import the collected information into the assessment system, focusing on 4 key risk categories that most impact wooden tableware:
• Legal Logging Risk: Verify that the felling permit matches the actual wood species (e.g., using oak when the permit specifies pine is a violation); confirm the felling area complies with the origin country’s environmental laws (e.g., Laos prohibits the felling of young trees, so proof of tree age is required).
• Supply Chain Mixing Risk: Trace the entire process from "felling → drying → forming → packaging". For instance, when our factory receives wood, we must verify the traceability code of each batch to prevent mixing in unqualified illegal wood.
• Certification Validity Risk: Verify that the FSC certification is within its validity period and that the certification scope includes "wood processing for tableware" (some certifications only cover wood for construction and cannot be used for tableware).
• Chemical Safety Risk (Unique to Wooden Tableware): Test formaldehyde emissions from wooden tableware coatings (per EU No 10/2011 limits) and pentachlorophenol residues (zero tolerance). Especially for knives, forks, and spoons labeled "food-contact", third-party test reports must be provided.
3. Step 3: Risk Mitigation — Practical Solutions for Wooden Tableware Factories
When facing "non-negligible risks", our factory should take proactive, verifiable measures instead of waiting for importers to follow up:
• Low Risk (e.g., missing fumigation certificate): Contact the wood supplier to supplement the latest fumigation report, clearly marked "for disposable wooden tableware production";
• Medium Risk (e.g., ambiguous felling area proof): Entrust a third-party organization (e.g., SGS) to issue a satellite remote sensing report of the felling area to prove the wood comes from a legal region;
• High Risk (e.g., excessive formaldehyde in tests): Immediately replace the wood coating supplier with one providing EU-compliant water-based coatings, re-submit samples for testing, and retain the report; if the compliance of the wood species is in doubt, prioritize switching to wood from low-risk regions such as Finland or Germany.C
What Factories Must Know: What Support Do Importers Need From Us?
EU importers cannot achieve DDS compliance without support from our factory. We must prepare in advance for these 5 core tasks:
1.Assist in Submitting DDS Electronic Declarations
When uploading declarations to the EU TRACES NT system, we need to provide: GeoJSON coordinate files of the wooden tableware production site (accurate to the factory workshop), and a list of wood traceability codes for each product batch (corresponding to felling area information).
2.Fully Disclose Supply Chain Information
Provide detailed information on three-tier upstream suppliers: "logging facility → wood processing plant → our factory", including: felling permit numbers of logging facilities, and drying process descriptions from processing plants (to prevent wood mildew from affecting compliance).
3.Archive and Share Compliance Documents
Store documents for 5 years as required by the EU, and share them with importers: copies of FSC certifications, quarterly formaldehyde/antifungal agent test reports, and food contact material compliance statements for wooden tableware.
4.Rapidly Respond to Risk Alerts
If the importer receives an EU "compliance concern notice" (e.g., suspicion of wood mixing), we must provide within 48 hours: inbound logs of the batch (marked with traceability codes) and workshop production surveillance footage (to prove no other wood was mixed in).
5.Prepare Samples for Customs Inspection
Prepare samples in advance as required by the importer: 10 sets of each type of wooden tableware (knives, forks, spoons, food containers), with sample labels (marking wood species, production batch, and test report number) to facilitate on-site material verification and safety testing by customs.
Compliance Recommendations for Disposable Wooden Tableware Factories
1."Pre-Screen" at the Raw Material Stage: Prioritize purchasing FSC-certified wood and establish a supplier classification system (high-risk: unregistered small factories in Southeast Asia; low-risk: local EU wood suppliers) to avoid subsequent compliance risks.
2."Visualize" at the Production Stage: Set up a "DDS Compliance Information Board" in the workshop, marking traceability codes and test results for each batch of wood to facilitate on-site inspections by clients (importers).
3."Regularize" at the Testing Stage: In addition to client-required tests, proactively conduct quarterly sampling tests for antifungal agent residues (targeting wooden food containers prone to mildew in humid environments) to avoid EU notification risks in advance.
4."Package and Deliver" at the Export Stage: Organize the "DDS Compliance Data Package" for importers by category: "wood traceability → test reports → supply chain qualifications", with user guides (e.g., "How to Upload Declarations to the TRACES System") to improve collaboration efficiency.
For our factory, the DDS Investigation is not a "trade barrier" but a "green pass" to enter the high-end EU market. Refining compliance processes and fully supporting importers at every step not only reduces export risks but also demonstrates our professionalism and responsibility to clients — this is the core competitiveness for long-term cooperation.
