How should a team check whether a product is in EUDR Annex I?
Start with the product that is actually 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.
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.
Identify the traded product, not only a marketing category or internal material group.
Check whether the product falls under one of the covered commodity families named in the EUDR: cattle, cocoa, coffee, oil palm, rubber, soya, or wood, including derived products listed in Annex I.
Record whether the business is acting as an operator, downstream operator, or trader for that movement.
If the product is in scope, link the lookup to the due diligence statement, simplified declaration identifier, or downstream supplier information required for the role.
If the product is out of scope, preserve the reason for the non-match and the evidence used, because product composition, suppliers, and trade descriptions can change.
Supports the Annex I scope trigger, Article 3 conditions, role definitions, and the need to connect in-scope products to due diligence or simplified declaration evidence.
How should commodity links, CN codes, HS codes, and customs descriptions be handled?
Use customs and trade fields as evidence, not as a substitute for the Annex I check. Product descriptions, CN or HS classifications, 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.
That means the safer operational rule is to 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.
Use customs descriptions to confirm the actual product being traded.
Use CN, HS, or tariff fields as pointers to review, especially when product names are vague or supplier descriptions differ.
Do not publish or rely on an internal code table unless the source and review date are clear.
Where product composition is ambiguous, ask the supplier for the material or commodity basis before marking the item out of scope.
Keep the final conclusion tied to the official Annex I product-scope source, not only to an ERP category or brokerage description.
What supplier and trade evidence should support an Annex I lookup?
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 file 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.
Product or SKU name, supplier part number, and trade description used for the lookup.
Supplier identity and upstream role, including whether the supplier provides a due diligence statement reference number or declaration identifier.
Commodity family and Annex I match used for the scope conclusion.
Invoices, purchase orders, import/export records, or shipment records that tie the conclusion to the actual movement.
Downstream recipient information where the business is required to keep supply chain information.
Review note for unresolved uncertainty, such as a supplier description that does not clearly identify the commodity basis.
Supports due diligence information collection, supply chain information, supplier details, due diligence statement references, declaration identifiers, and five-year recordkeeping.
What are the most common mistakes in EUDR Annex I product lookup?
The main mistake is treating Annex I lookup as a one-time legal label instead of a repeatable product-data control. A product can be misclassified when the team checks only the product name, only an internal category, or only a customs field without tying the conclusion back to the official scope source and supplier evidence.
Another mistake is using broad commodity claims without tracing the product to the role-specific obligation. If an item is a relevant product, the next question is not just whether EUDR applies; it is which party must hold or pass on the due diligence statement, simplified declaration identifier, or Article 5 supply chain information.
Do not assume every product connected to a covered commodity is automatically listed; check the product against Annex I.
Do not assume a product is out of scope because the supplier description avoids the commodity name.
Do not rely on unsupported copied code lists, stale tariff mappings, or internal material groups as the only evidence.
Do not separate the lookup from supplier due diligence references or downstream trade records.
Do not mark a product out of scope without keeping the reason and the source used for the conclusion.
EUDR country benchmarking FAQ: low, standard, and high risk
What is country benchmarking under the EU Deforestation Regulation?
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.
Low risk: may support simplified due diligence for products produced in that country or part of a country, if the operator also checks supply-chain complexity and circumvention or mixing risk.
Standard risk: does not create the low-risk simplification; ordinary information collection, risk assessment, and risk mitigation logic remains relevant.
High risk: should be treated as a stronger risk signal in the operator's assessment and controls, not as a reason to skip product-level evidence.
EUDR country benchmarking FAQ: low, standard, and high risk
How does low-risk benchmarking affect simplified due diligence?
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.
Confirm the relevant product was produced in the low-risk country or part of a country, not merely shipped from it.
Check whether the supply chain mixes origins, commodities, plots, establishments, or batches in a way that could undermine the low-risk conclusion.
Keep documentation that explains why the operator treated the risk of circumvention or mixing as negligible.
EUDR country benchmarking FAQ: low, standard, and high risk
What must still be collected even when production is low risk?
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.
Product and commodity identity, including whether the product is listed in Annex I.
Country or part of country of production, backed by production-origin evidence rather than shipping-origin assumptions.
Geolocation or permitted substitute information where the Regulation allows it for a specific actor.
Documentation showing deforestation-free status and production in accordance with relevant legislation in the country of production.
Due diligence statement reference numbers, declaration identifiers, supplier details, and downstream recipient details where the actor's role requires them.
Supports the continuing Article 9 information and evidence collection duties, including geolocation and proof of deforestation-free and legal production.
EUDR country benchmarking FAQ: low, standard, and high risk
Should an EUDR FAQ name low-risk and high-risk countries?
Do not name country lists unless the page is citing the current official Commission list or implementing act used for that claim. A country name copied into static guidance can become misleading if the official list changes, if the classification applies only to part of a country, or if the product's real production origin differs from the trading route.
A safer public answer is to explain how the benchmark category affects the due diligence analysis, then require the working file to capture the exact official source, the country or part of country, the date the list was checked, the production-origin evidence, and the conclusion on mixing or circumvention risk.
Name a country only when the official source being cited contains that classification.
Record whether the classification applies to the whole country or only to a part of it.
Separate production origin from supplier location, exporter location, and port of shipment.
Refresh benchmark evidence before relying on low-risk simplified due diligence for a new product, supplier, or origin path.
Supports the point that benchmarking applies to countries or parts of countries and should be tied to the official Article 29 classification being relied on.
What should teams do before customs or import release under the EUDR?
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.
A customs-release checklist should therefore be an evidence checkpoint, not a substitute for due diligence. If the required reference is missing, if the supplier cannot identify the operator responsible for the statement, or if new information suggests non-compliance, the product should be held from release planning until the EUDR owner resolves the gap.
Confirm the relevant product and commodity are in the EUDR scope before the shipment is approved for release.
Record whether the party responsible is acting as operator, downstream operator, trader, importer, authorised representative, or customs broker support.
Require the due diligence statement reference number or simplified declaration identifier before release instructions are finalised.
Keep the evidence file separate from the customs filing so teams do not mistake a reference number for proof that the underlying due diligence is complete.
Supports the customs-readiness gate: relevant products must meet Article 3 conditions and be covered by a due diligence statement or simplified declaration where required.
How should teams handle due diligence statement references?
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, the receiving team should match the reference or declaration identifier to the supplier, product, shipment, and internal evidence file before instructing release. The FAQ answer should not claim a specific customs declaration box, data element, or national filing format unless that mechanic is separately confirmed from an official customs source.
Capture the EUDR reference or declaration identifier as a required shipment-readiness field.
Link the identifier to the supplier record, product line, EUDR role, and due diligence evidence file.
Escalate missing, mismatched, expired, duplicated, or unexplained identifiers before release instructions are issued.
Do not rewrite the due diligence statement after customs clearance just to fit a shipment file; correct the underlying EUDR record first.
Supports the reference-number handoff because operators keep due diligence statement records and communicate reference numbers or declaration identifiers downstream.
What should operators, importers, and brokers hand off to each other?
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 actually 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.
Operator to importer or downstream recipient: EUDR role, covered product, due diligence statement reference number or declaration identifier, and evidence-file owner.
Importer or downstream recipient to broker: release instruction, matched identifier, hold/release status, and escalation contact for EUDR exceptions.
Broker to importer: confirmation that the provided identifier was used as instructed and any customs authority query was returned to the EUDR owner.
EUDR owner to procurement and logistics: stop-release rules for missing identifiers, substantiated concerns, or unresolved supplier evidence gaps.
Supports downstream handoffs because downstream operators and traders must collect and keep supplier information and reference numbers or declaration identifiers.
Keep evidence that proves why the product was considered ready for release, not just a screenshot or shipment email. The EUDR due diligence file should show information collection, risk assessment, risk mitigation where needed, the submitted due diligence statement or simplified declaration route, and the reference or declaration identifier handed to downstream parties.
Retention should cover both the customs-release event and the EUDR evidence behind it. The grounded record set includes due diligence statements kept by operators, Article 9 information and evidence such as geolocation and documentation demonstrating deforestation-free and legal production, and Article 5 supply-chain information kept by downstream operators and traders.
Product and supplier identity used for the release decision.
Due diligence statement reference number or simplified declaration identifier.
Evidence that the product is deforestation-free and produced in accordance with relevant legislation of the country of production.
Geolocation or establishment information required for the applicable EUDR route.
Risk assessment result, mitigation record, and unresolved-risk escalation if risk was not negligible.
Release hold, approval, or authority-query log tied back to the EUDR evidence owner.
Supports evidence content because Article 9 covers geolocation, documentation demonstrating deforestation-free and legal production, and availability to authorities on request.
The common mistake is to treat EUDR customs release as a filing-format problem. The official grounding supports due diligence statements, reference numbers, information-system workflows, and supply-chain handoffs; it does not justify unsupported claims about exact customs declaration fields, national data elements, or automatic clearance outcomes.
The safer operating model is to make customs release dependent on a matched EUDR reference or declaration identifier and a complete evidence file. That gives import, procurement, sustainability, and broker teams a practical stop point without pretending that a customs filing alone proves EUDR compliance.
Do not publish procedures that name a customs field or declaration code unless an official customs source supports it.
Do not accept a bare reference number without matching it to the supplier, product, shipment, and EUDR evidence file.
Do not let the broker become the evidence owner when the legal responsibility sits with the operator, downstream operator, or trader.
Do not release products when new information or substantiated concerns require verification before placing, making available, or exporting.
Supports stop-release handling where substantiated concerns or information indicating non-compliance require verification before placing, making available, or exporting.
EUDR DDS Reference Numbers: What to Record and Pass Down
What does an EUDR DDS reference number support?
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. For micro or small primary operators using the simplified route, the parallel handoff is the declaration identifier.
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.
Operator filing: keep the due diligence statement record and its reference number together.
Downstream handoff: pass the DDS reference number, or declaration identifier where applicable, to downstream operators and traders further down the supply chain.
Recipient record: downstream operators and traders should store supplier details, the relevant DDS reference number or declaration identifier, and downstream recipient details.
Authority response: keep the record usable for competent-authority requests instead of burying the number in email threads or shipment notes.
Supports the operator duty to submit a due diligence statement through the Article 33 information system, keep statement records, and communicate reference numbers downstream.
EUDR DDS Reference Numbers: What to Record and Pass Down
How should downstream operators, traders, and customs handoffs record DDS references?
Downstream teams should treat the DDS reference number as a required supply-chain data field, not as optional correspondence. When the supplier is an operator, record the supplier details and the DDS reference number or declaration identifier before the product is placed, made available, or exported under the downstream actor's process.
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. Keep the control focused on the DDS reference number or simplified declaration identifier unless an official filing output or broker instruction requires an additional field.
Store the supplier legal name and contact details with the EUDR reference field.
Record whether the field is a due diligence statement reference number or a simplified declaration identifier.
Map the reference to the product, commodity, lot, purchase order, shipment, export file, or customs broker handoff it supports.
Keep downstream recipient details so the same reference can be traced through the next supply-chain step.
Escalate missing, mismatched, or stale references before relying on the shipment or sales record as EUDR evidence.
Supports the requirement that downstream operators and traders possess the Article 5 information before placing, making available, or exporting relevant products.
EUDR DDS Reference Numbers: What to Record and Pass Down
What evidence should teams keep with each EUDR DDS reference number?
Keep enough evidence to show what the reference number points to and who relied on it. The number alone does not prove deforestation-free status, lawful production, or no/negligible risk; those conclusions sit in the due diligence file behind the statement.
A useful record lets a reviewer answer four questions quickly: which EUDR product movement used the reference, who supplied it, which downstream actor received it, and where the underlying due diligence or simplified declaration record is retained.
The due diligence statement reference number or declaration identifier exactly as received from the EUDR information-system workflow.
The supplier/operator details and the downstream recipient details linked to the reference.
The product, commodity, lot, shipment, invoice, purchase order, or export file that used the reference.
The underlying due diligence statement, simplified declaration, or internal link to the retained EUDR filing record.
Any later notice that the product may be at risk of non-compliance, plus the authority or downstream notification record where required.
A retention marker showing the Article 5 information file is kept for at least five years.
EUDR DDS Reference Numbers: What to Record and Pass Down
What is the main mistake to avoid with EUDR DDS reference numbers?
The main mistake is treating the DDS reference number as a standalone compliance certificate. The reference number is a filing and handoff identifier; the substantive compliance case remains the due diligence statement, simplified declaration where applicable, Article 9 evidence, risk assessment, and any risk mitigation record.
Do not build public or internal guidance around assumed verification-number steps. In this FAQ, the supported fields are the due diligence statement reference number and the simplified declaration identifier.
Do not replace due diligence evidence with a bare reference number.
Do not accept a reference that cannot be tied to the supplier, product, and downstream recipient record.
Do not mix DDS reference numbers and simplified declaration identifiers without labeling which route applies.
Do not create a separate verification-number workflow from unsupported assumptions.
What should teams do about geolocation plots and polygons under the EUDR?
For each in-scope relevant product, collect plot-level geolocation evidence for the land where the relevant commodities in that product were produced, then keep it tied to the due diligence file. The record should show the relevant commodity or product, supplier, production country or area, plot evidence, supporting documentation for deforestation-free and legal production, and the due diligence statement or simplified declaration reference when one exists.
Do not treat polygons as a standalone compliance artifact. The useful control is traceability: the geolocation evidence must remain connected to the product lot, shipment, batch, or consignment that will be placed on the market, made available, or exported. If the same supplier ships mixed material from multiple production plots, the evidence file needs to preserve which plots support which product movement.
Start from the relevant product and commodity in Annex I scope, not from a map file.
Request supplier evidence that identifies the plots or establishments behind the commodity used in the product.
Link the plot evidence to purchase orders, batches, lots, consignments, or export records so it can support a due diligence statement.
Use the plot evidence in the Article 10 risk assessment and do not proceed unless the assessment shows no or only negligible risk of non-compliance.
Avoid publishing ungrounded rules about coordinate formats, polygon file types, or plot-size thresholds unless they are supported by the applicable source for that product workflow.
What supplier evidence should support EUDR geolocation records?
Supplier evidence should let the operator or downstream reviewer trace the product back to the production plots or establishments and evaluate whether the EUDR conditions are met. A supplier name alone is not enough if it cannot be connected to the land where the commodity was produced and to the specific product movement being reviewed.
For upstream operators, this usually means collecting and retaining the geolocation information and documentation demonstrating deforestation-free and legal production. For downstream operators and traders, the record should also preserve the supplier details and, where the supplier is an operator, the due diligence statement reference number or simplified declaration identifier communicated through the supply chain.
Supplier identity and the supplier's role in the EUDR chain.
Relevant commodity and product identifiers used in purchasing, production, and shipment records.
Production country or production area information tied to the supplier evidence.
Plot or establishment geolocation evidence where required for the product fact pattern.
Documentation supporting deforestation-free and legal production claims.
Due diligence statement reference numbers or simplified declaration identifiers received from upstream operators.
How should geolocation evidence connect to products, consignments, and statements?
Build the link in both directions. From a product or consignment, a reviewer should be able to identify the supplier evidence and production plots or establishments that support it. From a plot record, a reviewer should be able to see which product lots, consignments, due diligence statements, or simplified declaration identifiers used that evidence.
This matters because EUDR due diligence is performed before placing relevant products on the market or exporting them. Operators submit or make available the due diligence statement through the Article 33 information system when due diligence concludes compliance. Downstream operators and traders then rely on supply-chain information, including reference numbers or declaration identifiers where relevant, rather than a disconnected map archive.
Keep product SKU, commodity, batch, lot, shipment, and consignment identifiers consistent across procurement and due diligence records.
Store the plot or establishment evidence with the supplier record used for that product movement.
Record whether the movement is supported by an operator due diligence statement, a simplified declaration, or downstream supply-chain information.
Preserve reference numbers or declaration identifiers received from upstream parties and pass required references further down the chain.
Keep due diligence statement records for the period required by the EUDR grounding source.