EU Deforestation Regulation customs and import release readiness

Do not wait for the customs broker or import filing to discover an EUDR gap. Before a relevant product is placed on the EU market or exported, confirm that the product is in the EUDR scope, that the operator has completed due diligence or the applicable simplified declaration route, and that the release file includes the due diligence statement reference number or declaration identifier needed for the shipment.

Article 26 requires the due diligence statement reference number, or the declaration identifier for an eligible micro or small primary operator, to be made available to customs authorities before release for free circulation or export. Except where the statement is supplied through the Article 28 electronic interface, the person lodging the customs declaration provides that identifier. Article 26(4) excludes exports by downstream operators from this paragraph; the exclusion does not remove their separate Article 5 duties.

The EUDR reference number is a handoff control. Operators submit the due diligence statement through the Article 33 information system after due diligence shows no or negligible risk, then communicate the reference number to downstream operators and traders further down the supply chain. Where a micro or small primary operator uses a simplified declaration route, the handoff should capture the declaration identifier instead.

For import release, match the reference or declaration identifier to the supplier, product, and customs movement. Before the Article 28 electronic interface is in place, customs and competent authorities exchange information under Article 27. Once the interface is in place, customs authorities use it to examine the status assigned to the statement. A status requiring checks can suspend release; a competent-authority finding of non-compliance prevents release.

The handoff should be explicit about roles. The operator remains responsible for compliance when it makes a due diligence statement available, even if an authorised representative submits the statement on its behalf. Downstream operators and traders need supplier information and, where the supplier is an operator, the due diligence statement reference number or declaration identifier.

Customs brokers can help enforce release readiness, but they should not be made the owner of EUDR due diligence unless they hold that legal role. Give brokers the identifiers and release instructions they need; keep product scope, supplier evidence, geolocation evidence, risk assessment, mitigation, and authority-response ownership with the EUDR compliance owner.

A screenshot or shipment email does not explain why the product was ready for release. Keep the information collected, risk assessment, mitigation where needed, submitted statement or simplified declaration, and the identifier handed to downstream parties.

Retention should cover both the customs-release event and the EUDR evidence behind it. Operators keep due diligence statement records for five years, and downstream operators and traders keep their Article 5(3) supply-chain information for at least five years. The wider file includes Article 9 information and evidence such as geolocation and documentation demonstrating deforestation-free and legal production.

No. Article 26(10) states that release for free circulation or export is not proof of compliance with Union law or the EUDR. Customs release confirms that the applicable customs conditions allowed the movement at that point; the operator still needs the due diligence evidence supporting Article 3 compliance.

Keep the identifier and customs outcome with the evidence file. If competent authorities identify the product for checks, customs authorities suspend release under Article 26. If competent authorities conclude that it is non-compliant, customs authorities must not release it.