Questions and answers

Start with the product being placed on the EU market, made available on the EU market, or exported. Then compare that product to Annex I, which is the regulation's product-scope list for relevant commodities and derived products. An item that matches is a relevant product. Representative matches include cocoa beans and chocolate under cocoa, coffee under heading 0901, specified cattle meat and leather, palm oil, natural rubber, soya beans, and listed wood, paper, and furniture products.

A useful lookup record should name the product or SKU, the supplier, the relevant commodity family, the Annex I product match or non-match, and the role affected by the transaction. If the item is in scope, Article 3 connects the product to the EUDR conditions: deforestation-free status, production in accordance with relevant legislation of the country of production, and a due diligence statement or simplified declaration where required.

Use customs and trade fields as evidence, not as a substitute for the Annex I check. Product descriptions, a CN code or HS classification, supplier master data, and invoices can help identify what the product is and which commodity family it links to, but this FAQ does not reproduce a standalone code list.

For an Annex entry marked "ex", match both the code and the narrower product description because the entry does not cover every good under that code. Goods produced entirely from material that completed its lifecycle and would otherwise have been discarded as waste are excluded under the Annex rule. The exclusion does not cover manufacturing by-products from a process that used material that was not waste. Do not treat offcuts from such a process as excluded merely because they are described as recycled.

Keep the official Annex I source next to the business evidence that explains why the product does or does not match. Do not copy an old spreadsheet of codes into the lookup and treat it as current unless it is reconciled to the official EUDR source used by the review.

Read Annex I with Commission Delegated Regulation (EU) 2026/2102, in force from 18 September 2026. It changes product descriptions, removals and exclusions. Specific added entries, including frozen cattle tongues and coffee extracts, apply from 30 December 2027. Check the exact amended entry and its date before deciding that a product is covered.

The lookup should be backed by records that let a reviewer connect the legal scope conclusion to the commercial movement. For an in-scope product, the record should show the supplier, the product identity, the commodity link, the transaction or shipment context, and the EUDR reference information available for the role.

Operators need due diligence evidence before placing relevant products on the market or exporting them. Downstream operators and traders need supply chain information, including supplier details and, when the supplier is an operator, due diligence statement reference numbers or declaration identifiers. Those records make the Annex I lookup usable after the original buyer or product owner leaves the team.

Repeat the Annex I check when product composition, supplier data, or trade classification changes. Checking only a product name, internal category, or customs field can produce the wrong scope result when the record is not tied to Annex I and supplier evidence.

For an in-scope item, identify which party must hold or pass on the due diligence statement, simplified declaration identifier, or Article 5 supply-chain information.

Country benchmarking is the Article 29 system that assigns countries, or parts of countries, to a low, standard, or high risk category for EUDR purposes. The category is about the country-of-production risk context; it does not decide by itself whether a shipment, product line, supplier, or plot complies with the Regulation.

Use the benchmark as one input in the EUDR due diligence file. The starting question remains whether the product is a relevant commodity or relevant product under Annex I and whether it can meet the Article 3 conditions: deforestation-free, produced in accordance with relevant legislation of the country of production, and covered by the required due diligence statement or simplified declaration.

For relevant products produced in a country, or part of a country, classified as low risk under Article 29, Article 13 can relieve operators from the Article 10 risk assessment and Article 11 risk mitigation steps. That relief is conditional: the operator must still assess supply-chain complexity and the risk of circumvention or mixing with products from other origins, and must be able to show documentation demonstrating negligible risk.

Low-risk status therefore narrows the due diligence work only after the operator has confirmed the production origin and checked for mixing or circumvention. It should not be used as a blanket rule for every supplier invoice, warehouse lot, or product batch connected to the country.

If relevant information or a substantiated concern points to non-compliance or circumvention, Article 13(2) requires the operator to carry out the Article 10 assessment and Article 11 mitigation and immediately communicate the relevant information to the competent authority. Keep the concern, authority notification, assessment and outcome with the affected product records; the low-risk country label does not preserve simplification in that case.

Low-risk benchmarking does not remove Article 9 information collection. Operators still need information and evidence for the relevant product, including production origin, geolocation of plots or establishments where required, and documentation showing the product is deforestation-free and produced in accordance with relevant legislation of the country of production.

The operator also still needs the required EUDR submission route. The Regulation describes due diligence statements through the Article 33 information system, and simplified declarations for micro or small primary operators where the amended Regulation allows them. Downstream operators and traders still need the required supply-chain information, including due diligence statement reference numbers or declaration identifiers when those apply.

Use Commission Implementing Regulation (EU) 2025/1093 for the current low- and high-risk lists. Its Annex lists, for example, Germany, the United States, China, and Ghana as low risk; Belarus, the Democratic People's Republic of Korea, Myanmar, and the Russian Federation are the high-risk countries. Brazil is not on either list and therefore remains standard risk under Article 1(2). These are classifications under that act, not permanent labels.

Because the Commission may review and update the list when new evidence warrants it, record the act and date checked rather than copying an unversioned country tier into a supplier record.

Match the benchmark to the country or part of country where the commodity was produced, not the supplier's address, exporter location, or port of shipment. Then document the product origin and any mixing or circumvention risk before relying on low-risk simplified due diligence.

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.

Keep the collected information, submitted statement or simplified declaration, and identifier handed to downstream parties. Where Articles 10 and 11 apply, include the assessment and any mitigation; where Article 13 simplified due diligence applies, retain the production-origin, supply-chain complexity, circumvention and mixing checks that support it.

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.

A DDS reference number supports traceability after an operator has completed the EUDR due diligence sequence and made the due diligence statement available through the Article 33 information system. The system assigns a reference number for each submitted due diligence statement. For micro or small primary operators using the simplified route, the parallel handoff is the declaration identifier assigned after the one-time declaration.

Use the number to link three things that are often held in different systems: the supplier or operator that made the EUDR filing, the relevant product or shipment record, and the downstream recipient that needs the reference to keep its own Article 5 information file.

When the immediate supplier is an operator, downstream operators and traders must record its details and the DDS reference number or declaration identifier before placing, making available, or exporting the product. When the immediate supplier is a downstream operator or trader, Article 5(3)(a) requires supplier details but does not require collection of that identifier.

For customs, export, logistics, and broker handoffs, carry the same EUDR reference field on the movement record and tie it back to the product line. Article 26 normally requires the reference number or declaration identifier before release for free circulation or export, but excludes exports by a downstream operator from that paragraph. Keep the control focused on the official identifier unless an official filing output or broker instruction requires an additional field.