EUDR information system filing DDS references, declaration identifiers, and handoffs

Treat the filing as a release gate for in-scope relevant products. Operators must exercise due diligence before placing relevant products on the EU market or exporting them, and they must not place or export the product without prior submission of the due diligence statement. If due diligence supports compliance with Article 3 and shows no or negligible risk, the operator makes the due diligence statement available to competent authorities through the Article 33 information system.

The filing owner should therefore be the role that can confirm the product, supplier, shipment, or export fact pattern is ready for submission. An authorised representative may submit on the operator's behalf, but that handoff does not move compliance responsibility away from the operator.

Annex II defines the legal statement content: operator identity and address; Economic Operators Registration and Identification (EORI) number for products entering or leaving the market; Harmonised System code; free-text product description, trade name and scientific name where applicable; quantity; country of production; geolocation of every production plot or cattle establishment; the prescribed compliance declaration; and signature information.

A submitted EUDR due diligence statement produces a reference number that needs to move with the supply-chain handoff. For the simplified regime, a micro or small primary operator submits a one-time simplified declaration in the Article 33 information system and receives a declaration identifier. Those identifiers let later actors connect their product intake, sale, export, or authority response to the upstream EUDR filing.

Downstream operators and traders should collect supplier details and, where the supplier is an operator, the due diligence statement reference number or declaration identifier. They should also keep downstream recipient details so the evidence trail can show both where the covered product came from and where it went.

Article 4a(4) provides a separate route when all Annex III information is already held in a system or database under EU or Member State law. The Member State makes it available to the EUDR information system and the primary operator does not submit a separate declaration. The operator must still receive a declaration identifier before placing or exporting; an existing farm-register number alone does not satisfy that condition.

Ownership depends on the actor's EUDR role. Operators own the due diligence conclusion and the decision to submit the due diligence statement before placing on the market or exporting. Micro or small primary operators using the simplified route own the simplified declaration and declaration identifier. Non-SME downstream operators and non-SME traders register in the Article 33 information system before placing, making available, or exporting, but Article 5 no longer requires them to submit a new statement for already-covered products.

If an authorised representative submits the statement or simplified declaration, keep the operator's approval, the representative's written mandate and the returned reference number or declaration identifier together. Article 6 permits the representative to submit while the operator retains Article 3 compliance responsibility.

Keep evidence that lets a reviewer reconstruct the filing without guessing. The record should show the Article 3 compliance basis, the due diligence conclusion, the submission route used, the filing identifier returned, and the handoff to downstream actors. Operators keep due diligence statement records for five years from submission; downstream operators and traders keep Article 5(3) supply-chain information for at least five years from placing, making available or export and provide it to competent authorities on request.

For a simplified declaration, retain the Article 2(15a) eligibility analysis and the Annex III data: operator identity, EORI number where applicable, Harmonised System code, product description, one-off estimated annual quantity, country of production, geolocation or permitted postal addresses for all plots or cattle establishments, and the prescribed declaration. Article 4a permits an update following any major changes; record the trigger, revised data, submission result, and continuing eligibility.

Portal screens and technical fields can change under implementing rules. Keep the business and regulatory trail: scope decision, due diligence file, submitted statement or simplified declaration, returned reference number or declaration identifier, representative mandate if used, supplier and recipient records, and any amendment, withdrawal, or authority-response log.