A Detailed Guide to DDS Investigation Risk Assessment for Wooden, Paper, and Bamboo Tableware Factories
As a factory specializing in wooden, paper, and bamboo tableware, we understand that navigating the EU’s Due Diligence System (DDS) is critical for successful exports. Among all DDS procedures, risk assessment stands out as the core—it identifies potential compliance gaps in raw material sourcing, production, and supply chains, directly determining whether your products meet EU standards (such as EUDR and EUTR). This blog breaks down the DDS risk assessment process step by step, tailored to the unique characteristics of wooden, paper, and bamboo tableware.
Why DDS Risk Assessment Matters for Your Tableware Business
For tableware made from natural materials, DDS risk assessment is not just a regulatory requirement—it addresses material-specific vulnerabilities:
• Wooden tableware: Risks of illegal logging, formaldehyde exceeding the limits (per EU No 10/2011), or mismatched FSC certifications.
• Paper tableware: Risks of pulp sourced from deforested areas or heavy metal (lead, cadmium) residues in coatings.
• Bamboo tableware: Risks of unsustainable harvesting, toxic preservatives, or non-compliant moisture control.
A rigorous risk assessment avoids costly consequences like customs detention, fines, or permanent EU market bans.
The 3-Core-Step DDS Risk Assessment Process
DDS risk assessment follows a structured, material-specific approach. Below is the step-by-step breakdown for your tableware production:
Step 1: Information Collection – Lay the Foundation with Material-Specific Data
Risk assessment starts with gathering comprehensive, accurate data. For wooden, paper, and bamboo tableware, focus on these key information categories:
| Tableware Type | Must-Collect Information | Example Documents |
| Wooden Tableware | 1.Wood species (Latin name, e.g., Betula platyphylla for birch)
2. Felling location GPS (≤1km² accuracy)
3. FSC/PEFC certification
4. Formaldehyde emission test reports | FSC certificate with wood species confirmation; EU No 10/2011 test results |
Paper Tableware | 1.Pulp origin (country/region)
2.PEFC/CFCC pulp certification
3.Coating composition 4.Heavy metal test reports | Pulp origin declaration; Lead/cadmium test reports (per EU No 10/2011) |
Bamboo Tableware | 1.Bamboo harvesting area approval
2.Sustainable harvesting certificate
3.Treatment process records (e.g., preservative type)
4.Moisture content test data | Forestry department harvesting permit; Preservative safety certificate |
Step 2: Risk Identification – Pinpoint Material-Specific Vulnerabilities
With data in hand, analyze risks across three dimensions: legal compliance, supply chain integrity, and product safety. Below are high-priority risks for each tableware type:
1. Legal Compliance Risks
• Wooden Tableware: Does the felling permit match the actual wood species? (e.g., Using oak with a pine felling permit = illegal logging risk.)
• Paper Tableware: Is the pulp sourced from EU-sanctioned regions or deforested areas? (e.g., Pulp from unregulated Amazon plantations = non-compliance.)
• Bamboo Tableware: Does the harvesting area fall under protected forest zones? (e.g., Harvesting in China’s giant panda habitats = legal violation.)
2. Supply Chain Integrity Risks
• Wooden Tableware: Is there "wood mixing" (legal + illegal wood) in processing? (e.g., A supplier adding uncertified wood to reduce costs.)
• Paper Tableware: Are there unrecorded middlemen in the pulp supply chain? (e.g., A third-party vendor altering pulp origin documents.)
• Bamboo Tableware: Is the bamboo transported with forged inspection certificates? (e.g., Falsifying "pesticide-free" labels for treated bamboo.)
3. Product Safety Risks
• Wooden Tableware: Formaldehyde emissions exceeding 1.5mg/kg (EU limit) or pentachlorophenol residues.
• Paper Tableware: Heavy metal levels exceeding 0.01mg/kg (lead/cadmium) or non-food-grade coatings.
• Bamboo Tableware: Toxic preservatives (e.g., chromium) or moisture content >12% (risk of mold in EU storage).
Step 3: Risk Mitigation – Take Actionable Measures for Each Risk Level
After identifying risks, implement targeted solutions based on risk severity. Below are practical measures for Low/Medium/High risks:
| Risk Severity | Wooden Tableware Solutions | Paper Tableware Solutions | Bamboo Tableware Solutions |
| Low | Request supplier’s satellite logging monitoring reports to confirm felling location. | Audit pulp vendor’s delivery notes to match origin declarations. | Test bamboo moisture content on arrival and adjust drying processes if needed. |
| Medium | Replace high-risk suppliers with FSC-certified vendors (e.g., Finland vs. unregulated regions). | Switch to PEFC-certified pulp mills and sign "traceability contracts" (penalties for fraud). | Hire third-party auditors (e.g., SGS) to inspect bamboo harvesting areas quarterly. |
| High | Recall affected batches and terminate contracts with non-compliant suppliers. | Stop production and re-test all paper coatings; report violations to EU authorities if needed. | Destroy non-compliant bamboo stock and re-source from approved sustainable plantations. |
Practical Tips for Tableware Factories to Streamline Risk Assessment
1. Build a Material-Specific Database:
Store all wood/pulp/bamboo data (certifications, tests) in a cloud system (e.g., SharePoint) for easy access.
2. Train Your Team:
Conduct quarterly DDS workshops—teach production staff to spot red flags (e.g., blurry certification copies).
3. Collaborate with Importers:
Share risk assessment reports with EU importers to align on compliance goals (e.g., pre-approve low-risk suppliers together).
For wooden, paper, and bamboo tableware factories, DDS risk assessment is not a one-time task—it’s a continuous process to protect your brand and EU market access. By focusing on material-specific data collection, targeted risk identification, and actionable mitigation, you can turn compliance into a competitive edge, winning trust from importers and consumers alike.
