What the Regulation requires at customs
Article 26(4) of Regulation (EU) 2023/1115, as amended by Regulation (EU) 2025/2650, requires the DDS reference number to be available to customs before release for free circulation or export. It is provided by whoever lodges the customs declaration: the importer or its customs representative. For micro or small primary operators, the declaration identifier of their simplified declaration replaces the reference number (Art. 4a).
The number goes into the declaration as a supporting document: box 44 in the classic Single Administrative Document layout, data element 12 03 in the Union Customs Code data model. The document type is a TARIC code and the reference is the number returned by TRACES.
To check whether your goods are under EUDR control, look up the code in TARIC: measure types 776 (import control) and 777 (export control) are the EUDR ones, and their conditions list the codes accepted. If you are unsure whether a CN code is in Annex I, start with the CN code checker.
The order: DDS first, customs declaration second
The DDS has to be submitted and available before you lodge the customs declaration, because the reference number does not exist until TRACES assigns it. This is how the work splits in a normal import, say a container of green coffee:
| Step | Who | What goes in the customs declaration |
|---|---|---|
| Due diligence and risk assessment | Operator (importer) | Nothing yet |
| Submit the DDS in TRACES, activity “import” | Operator or its authorised representative | Nothing yet |
| The DDS becomes “available” with a reference and a verification number | TRACES | Nothing yet |
| Lodge the declaration for release for free circulation | Importer or its customs representative | Code C716 and the DDS reference number |
| Sell the goods to another EU company | Operator | Nothing: it passes the numbers to its customer (Art. 4(7)) |
One DDS can cover several customs declarations and one declaration can carry several DDS, each as its own document. The Regulation only asks customs for the reference number; the verification number lets a third party look up the DDS in TRACES. How to submit the DDS is covered in how to submit a DDS in TRACES.
Which TARIC codes are used for the EUDR?
They were created by the Commission’s Directorate-General for Taxation and Customs Union (DG TAXUD), which updated them on 23 September 2026 (revision 1) to reflect Regulation (EU) 2025/2650 and Delegated Regulation (EU) 2026/2102. They apply to import and export unless stated:
| Code | When it is used | Reference |
|---|---|---|
| C716 | Standard case: the product has a DDS | DDS reference number |
| C717 | Micro or small primary operator (Art. 4a) | Declaration identifier of the simplified declaration |
| C720 / C725 | Re-import only, by a downstream operator that is not an SME (C720) or is one (C725) | Reference number received from the upstream operator |
| Y196 / Y188 | Export only, by a downstream operator that is not an SME (Y196) or is one (Y188) | Exemption: no own DDS |
| Y129 | “ex” code in Annex I and these particular goods are not covered | Exemption |
| Y132 | Product produced before 29 June 2023 (Art. 1(2)) | Exemption |
| C718 | Export or re-import of a product placed on the EU market between 30 June 2023 and the date of application | Exemption |
- Y133: used or second-hand products, waste, recovered products and products derived from them, and goods made from material that has completed its lifecycle.
- Y141: operators that were natural persons, micro or small undertakings on 31 December 2024. Only until 29 June 2027 and not for timber already covered by the EUTR.
- Y142: non-commercial activity, such as consumer-to-consumer consignments.
- Y187: samples of negligible value and quantity, and products to undergo examination, analysis or tests.
- Y190 and Y191: packing material and containers, products used to manufacture medicinal products, and correspondence or marketing material, only where Annex I provides for it.
Declaring an exemption without grounds is a wrong declaration. Keep whatever supports it (old invoice, technical sheet, composition) in case customs or the competent authority asks.
What happens if the reference is missing or the DDS is not available?
The EUDR measure in TARIC has a condition for when a DDS or simplified declaration is required, is not presented and no exemption applies: import or export is not allowed. In practice the declaration is not released until it is corrected.
While the DDS is “submitted”, TRACES is still processing it and there is no reference number yet, so there is nothing to put in the declaration. In the acceptance environment this takes one to a few minutes; even so, do not leave it for the morning of clearance. If TRACES rejects it, correct it and submit again. A withdrawn DDS can no longer be used in a declaration.
An amendment keeps the same reference number, so the customs declaration does not change. The deadlines to amend or withdraw are in the guide on amending or withdrawing a DDS.
Customs does not check the status of each DDS automatically yet. The Regulation provides for an electronic interface between customs systems and the information system, based on the EU Single Window Environment for Customs, to be in place by 1 December 2029 (Art. 28(1)). Until then, customs controls rely on risk analysis and cooperation with the competent authority (Art. 26(5) and 27). And release is not proof of compliance (Art. 26(10)): the authority can review the DDS and the due diligence behind it later.
Forwarders, customs agents and earlier statements
The person lodging the customs declaration need not be the one who submitted the DDS. If a customs agent does both, it needs two separate roles: customs representation and an EUDR authorised representative mandate (Art. 6). See the guide for freight forwarders and customs agents.
When an authorised representative submits the DDS, the reference number works exactly as if the importer had submitted it and goes into the declaration under C716. What needs agreeing is who passes the number to whom, and when, because the declaration cannot go out before the DDS is available.
If your DDS refers to earlier statements (for example your raw material supplier’s), they go into TRACES as referenced statements, and in the customs declaration you declare your own DDS. Sourevo stores the reference and verification numbers as soon as TRACES returns them and checks the status of submitted statements every 15 minutes, so the number sits on the DDS record ready to hand to the agent.
Export and re-import
An operator exporting an Annex I product submits a DDS with activity “export” and declares C716 with its reference number in the export declaration. Export declarations use the 8-digit CN code rather than the 10-digit TARIC code, which is why the export measure (777) is separate from the import one (776).
A downstream operator exporting products made from products already covered by a DDS does not have to give a reference number to customs (Art. 26(4), last sentence): it declares Y196 if it is not an SME or Y188 if it is. A downstream operator re-importing products that were already covered uses C720 or C725 with the reference number it received upstream. Who counts as a downstream operator is explained in the guide on downstream operators and traders.
Some codes that Delegated Regulation (EU) 2026/2102 added to Annex I apply from 30 December 2027. For those products, look up the measure in TARIC with the date of clearance.
Frequently asked questions
- Which number goes in the customs declaration, the reference or the verification number?
- The reference number, under code C716. Article 26(4) only requires the reference number at customs; the verification number lets others look up the DDS in TRACES.
- Can I lodge the customs declaration first and the DDS later?
- No. The reference number must be available to customs before release, and TRACES only assigns it once the DDS is available.
- Can one customs declaration carry several DDS?
- Yes. You can declare several DDS in one declaration, and one DDS can serve several declarations, as long as it covers the goods in each.
- What do I declare if my CN code is an “ex” code and my product is not covered?
- Code Y129. It applies when the CN code includes products that Annex I does not. Keep what proves it, such as the composition or the technical sheet.
- Who can use Y141?
- Only an operator that was a natural person, micro or small undertaking on 31 December 2024, only until 29 June 2027 and never for timber already under the EUTR. The dates are in the guide on deadlines.