Question 1

What is the EUDR?

Accepted Answer

The EUDR is Regulation (EU) 2023/1115. It bans placing on the EU market, or exporting from it, cattle, cocoa, coffee, oil palm, rubber, soya and wood products listed in its Annex I unless they are deforestation-free, were produced legally and are covered by a due diligence statement (DDS) submitted in TRACES.

Question 2

Which products does it cover?

Accepted Answer

Seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. The real scope is set by the CN codes in Annex I: a product is covered if its code is in the annex. A wooden table (9403) is in; a biscuit with chocolate (1905) is not. Printed products left the scope with Regulation (EU) 2025/2650.

Question 3

Does it apply to products made in the EU?

Accepted Answer

Yes. It applies to everything placed on the EU market, including what is produced in the EU. EU Member States are classified as low risk, so EU producers apply simplified due diligence, but they still need the geolocation of their plots.

Question 4

Who submits the DDS?

Accepted Answer

Since Regulation (EU) 2025/2650, only the operator, that is whoever first places the product on the EU market or exports it (typically the importer), or its authorised representative. Downstream operators and traders do not submit a DDS.

Question 5

What is a downstream operator?

Accepted Answer

A company that places on the market or exports Annex I products made from other Annex I products that are all already covered by a DDS or a simplified declaration, such as a roaster that buys green coffee from an EU importer. It keeps supplier and customer data for at least 5 years and, if it buys directly from the operator, the reference numbers of its DDS.

Question 6

And a trader?

Accepted Answer

Anyone else in the supply chain who makes the product available on the market, such as a distributor or a shop that resells it without processing. It has the same obligations as a downstream operator: no DDS, but supplier and customer records kept for at least 5 years.

Question 7

Do downstream operators and traders register in TRACES?

Accepted Answer

Only those that are not SMEs, before placing products on the market (Art. 5(2)). SMEs do not register, but they still collect and keep the information required by Article 5(3).

Question 8

What goes in a DDS?

Accepted Answer

The operator (with its EORI number for imports and exports), the CN code, description and quantity of the product (net mass in kg for imports and exports), the country of production, the geolocation of every plot and, for wood, the common and scientific name of each species. Supplier details do not go in the DDS: they go in your due diligence records.

Question 9

Is the risk assessment sent to TRACES?

Accepted Answer

No. The DDS only contains the statement that due diligence was carried out and the risk is none or negligible. The assessment and its evidence are kept for at least five years and shown to the competent authority on request.

Question 10

Can a DDS be amended or withdrawn?

Accepted Answer

Yes, once it is AVAILABLE in TRACES with its reference number. According to the TRACES API documentation there are 72 hours from that moment, and an amendment keeps the same reference number. After that, only with an extension from the competent authority; otherwise a new DDS is needed.

Question 11

How long must the information be kept?

Accepted Answer

At least 5 years. The operator keeps the DDS and the Article 9 information: product, quantity, country of production, geolocation, production date, name, postal address and email of the supplier and of the customer, and the evidence that the product is deforestation-free and legal.

Question 12

Where is the DDS submitted?

Accepted Answer

In the EUDR information system, inside TRACES NT, before customs clearance or export. It has its own registration, separate from the general TRACES NT used for animals and plants, and a test environment (ACCEPTANCE) with no legal value.

Question 13

What do I need to submit a DDS?

Accepted Answer

An EU Login account with two-step verification, your company registered as operator (or authorised representative) in the EUDR information system and, for imports and exports, an EORI number. To submit from software you also request “Web Services Access” in your TRACES profile, which gives you a username and an authentication key.

Question 14

Can my customs agent or forwarder submit it?

Accepted Answer

Yes, as authorised representative, with a written mandate from the operator (Art. 6). The representative must be established in the EU. The operator remains responsible for compliance, and the EUDR mandate is separate from customs representation.

Question 15

Point or polygon: what is the 4 hectare rule?

Accepted Answer

For plots of up to 4 hectares one point is enough; plots over 4 hectares need a polygon with their perimeter, except for cattle. Coordinates go in latitude and longitude with at least six decimal places. The plot is the unit, not the farm or the producer.

Question 16

How is cattle geolocated?

Accepted Answer

Not by pasture but by establishment: every place where the animal was kept, from birth to slaughter, with one point each, whatever its size. The 4 hectare rule does not apply.

Question 17

In what format does the geolocation go?

Accepted Answer

GeoJSON (RFC 7946) in WGS84 decimal degrees, with longitude first and then latitude. The geolocation of one DDS cannot exceed 25 MB in total, so a lot with hundreds of detailed polygons may have to be split across several statements.

Question 18

What is the cut-off date?

Accepted Answer

31 December 2020. The raw material must come from land that was not deforested after that date and, for wood, without forest degradation after it. The postponements moved the date of application, not the cut-off date.

Question 19

How do you check a plot against the cut-off date?

Accepted Answer

By crossing it with public satellite layers: the EU forest map for 2020, the annual tree cover loss of the University of Maryland and the Global Forest Watch alerts. A loss is a signal to review, not proof of deforestation: harvesting a plantation that already existed in 2020 also shows up as loss.

Question 20

How are countries classified?

Accepted Answer

Implementing Regulation (EU) 2025/1093 sets three levels. Low risk: all EU Member States, the United States, China and Ghana, among others. High risk: Belarus, North Korea, Myanmar and Russia. Every country not on either list, such as Brazil, Indonesia or Côte d’Ivoire, is standard risk. The country of production counts, not the port of shipment.

Question 21

What is simplified due diligence?

Accepted Answer

If everything was produced in low-risk countries, the operator does not have to assess and mitigate the risk (Art. 13), but it still collects the Article 9 information, geolocation included, submits the DDS and checks the risk of mixing with products from standard or high-risk countries.

Question 22

When does the EUDR apply?

Accepted Answer

From 30 December 2026 for large and medium-sized companies and for all downstream operators and traders. From 30 June 2027 for micro and small companies. Products added by Delegated Regulation (EU) 2026/2102, such as soluble coffee, from 30 December 2027.

Question 23

Do micro and small companies get more time?

Accepted Answer

Yes, until 30 June 2027, except for timber products that were already under the EUTR (most of chapter 44, pulp, paper and wooden furniture of 9403): for those, every company starts on 30 December 2026. Size only changes the date for those who submit a DDS.

Question 24

What are the penalties?

Accepted Answer

Article 25 leaves the amounts to each Member State, but requires fines with a maximum of at least 4% of the company’s total annual EU turnover, confiscation of the products and of the revenue, and temporary exclusion from public contracts and funding for up to 12 months. The 4% is a ceiling national law must allow, not a fixed fine.

Question 25

How does a cooperative declare its members’ plots?

Accepted Answer

With one entry for each plot of each member: a member with two separate plots has two entries, each with the producer’s name. The address of the cooperative or the mill is not a valid location.

Question 26

What is the simplified declaration?

Accepted Answer

A one-off declaration (Art. 4a) for micro and small primary operators in low-risk countries who sell what they grow or raise themselves. Instead of a DDS per shipment they receive a declaration identifier, which plays the role of the reference number for their buyers and at customs (code C717).

Question 27

Which number goes in the customs declaration?

Accepted Answer

The DDS reference number, declared with TARIC document code C716. The verification number only lets third parties look up the DDS in TRACES. Without a reference number or a valid exemption code, the import or export is not authorised.

Question 28

Can I lodge the customs declaration first and the DDS later?

Accepted Answer

No. The reference number must be available to customs before release for free circulation or export, and TRACES only assigns it when the DDS becomes AVAILABLE. In the test environment that takes one to a few minutes; do not leave it for the morning of clearance.

EUDR: frequently asked questions

What the EUDR is