EUDR Customs Declarations: DDS Reference Numbers, Declaration Identifiers, and Export Compliance

EUDR customs declarations are an important part of the compliance process for businesses importing or exporting products covered by the EU Deforestation Regulation (EUDR). For relevant products entering or leaving the EU market, customs procedures do not operate separately from EUDR compliance. The relevant EUDR reference must be made available to customs before the product is released for free circulation or exported.

For upstream operators, this creates a practical link between the EUDR Information System, the Due Diligence Statement (DDS), and the customs declaration. For downstream operators, the process can be different where products are already covered by an upstream DDS or simplified declaration. Understanding who must submit a DDS, which reference is required, and when it must be provided can prevent avoidable delays in import and export workflows.

Key Takeaways

• DDS reference numbers are essential for linking an EUDR-covered shipment to its Due Diligence Statement.
• Customs declarations must include the applicable DDS reference number or declaration identifier for relevant imports and exports.
• A DDS can cover multiple shipments or batches when the applicable requirements are met.
• Downstream operators may not need to submit a new DDS when the relevant product is already covered by an upstream DDS or simplified declaration.
• Accurate reference management is critical to connect customs declarations, shipments, products and the underlying EUDR due-diligence evidence.
• EUDR compliance goes beyond submitting a DDS—companies need reliable processes to manage references and trace them back to the relevant supply-chain information.

What Is an EUDR Customs Declaration?

An EUDR customs declaration is the customs declaration associated with relevant products entering or leaving the EU market under the customs procedures ‘release for free circulation’ or ‘export’. Under Article 26 of Regulation (EU) 2023/1115, relevant products placed under these procedures are subject to EUDR controls. Customs authorities perform controls on the relevant customs declarations, while competent authorities are responsible for the broader enforcement of the EUDR.

The EUDR therefore adds a compliance data requirement to the customs process: the reference number of the applicable DDS, or where applicable the declaration identifier for a simplified declaration by a micro or small primary operator, must be available to customs before release for free circulation or export.

When Is the EUDR DDS Reference Number Required?

For an upstream operator placing imported relevant products on the EU market or exporting relevant products, the DDS reference number must be made available to customs before the relevant product is released for free circulation or exported. The current Regulation provides an exception where the DDS is made available to customs through the electronic interface established under the Regulation.

A DDS reference number is assigned by the EUDR Information System after the DDS has been processed through the system’s applicable workflow. The system also assigns a verification number. Businesses should therefore treat the DDS reference as a transaction-critical compliance identifier rather than as a document number that can be added later.

Example: Coffee Import Into the EU

A coffee importer brings green coffee from India into the EU. The importer is the operator responsible for the relevant imported product. Before the coffee can be released for free circulation, the applicable DDS reference must be available to customs, unless the DDS is made available through the relevant electronic interface.

Operationally, the importer should connect the customs declaration, shipment or batch, product information, DDS reference and supporting EUDR evidence in its compliance workflow.

Learn how to track, link, and manage DDS reference numbers and declaration identifiers across suppliers, products, shipments, and customs declarations.

Read our complete guide to EUDR Reference Management →

What Is a Declaration Identifier?

The EUDR Information System also provides for simplified declarations for micro or small primary operators. A declaration identifier is the identifier assigned to such a simplified declaration. The current implementing rules define a declaration identifier separately from the DDS reference number.

This distinction matters because businesses should not treat every EUDR customs reference as a DDS number. The correct identifier depends on the type of EUDR submission associated with the relevant product.

Understand how Micro and Small Primary Operators (MSPOs) are treated under EUDR, including simplified declarations, geolocation requirements, and the specific compliance obligations that apply to qualifying smallholders and primary producers.

Read our complete guide to MSPOs in EUDR →

Release for Free Circulation vs Export

The customs link applies to the two procedures specifically identified in Article 26: release for free circulation and export. For imports, the customs declaration is connected to the product entering the EU market. For exports, the relevant declaration concerns a relevant product leaving the Union.

Example: An Indian exporter shipping a relevant rubber product to an EU customer should understand that the EU-side import process and EUDR obligations need to be coordinated with the operator responsible for placing the product on the EU market. Separately, an EU-based operator exporting a relevant product must account for the EUDR requirements applicable to exports.

Can One DDS Reference Number Be Used for Multiple Shipments?

A DDS may cover multiple shipments or batches when the scope and conditions of the DDS support those shipments. In that situation, the same DDS reference number may be used in several customs declarations, provided the products and transactions remain within the coverage of the DDS and all applicable EUDR requirements are met.

This is particularly important for companies managing recurring shipments from the same supply chain. The operational control should not simply be ‘reuse the DDS number’; it should be ‘verify that each shipment is actually covered by the DDS before reusing its reference’.

Example: Multiple Coffee Shipments

An importer has a DDS covering a defined set of compliant coffee products sourced from identified production plots. The importer receives three shipments covered by that DDS. The same DDS reference may be associated with multiple customs declarations where the DDS legitimately covers each shipment. If a later shipment falls outside the scope or facts supporting the DDS, the reference should not be reused without the appropriate compliance action.

Understand how EUDR DDS consolidation can simplify compliance by combining multiple Due Diligence Statements, reducing administrative effort while maintaining the required traceability and reference links.

Read our complete guide to EUDR DDS Consolidation →

What About Downstream Operators?

A key distinction in EUDR customs compliance is between upstream operators and downstream operators. Where a downstream operator places on the market or exports relevant products that are already covered by an upstream DDS or applicable simplified declaration, it does not necessarily submit a new DDS for those products.

Instead, the downstream operator’s obligations depend on its role, the product, the transaction and the information already available through the upstream supply chain. The EUDR framework requires relevant reference information to be communicated through the supply chain in the circumstances specified by the Regulation.

This means a downstream business should not automatically create a new DDS for every transaction. It should first determine whether the product is already covered by an upstream DDS or simplified declaration and identify the applicable downstream obligations.

Example: Downstream Wood Product Manufacturer

A European furniture manufacturer purchases wood panels that are already covered by an upstream operator’s EUDR DDS. The manufacturer later exports a relevant finished product. The compliance team should first establish whether the product and transaction fall within the downstream rules and whether the existing upstream DDS or simplified declaration provides the required coverage. The company should then maintain the applicable reference information and supporting records rather than assuming that a completely new DDS is always required.

Understand how EUDR obligations change once a product moves downstream, including DDS reference management, traceability, record-keeping, SME vs non-SME requirements, and responsibilities when non-compliance concerns arise.

Read our complete guide to EUDR Downstream Operators →

How the EUDR Information System Connects to Customs

The EUDR Information System assigns reference numbers to DDS submissions and declaration identifiers to simplified declarations. The implementing rules also provide for grouping DDSs and simplified declarations. A grouped DDS or simplified declaration can represent the individual submissions it references for the purposes of EUDR compliance, with the grouped reference or identifier communicated where the Regulation requires it.

For businesses, this means the EUDR compliance platform should be capable of maintaining a clear relationship between original submissions, grouped submissions, products, shipments and customs declarations.

How Can TraceX Support EUDR Customs Compliance?

TraceX EUDR Solutions helps businesses operationalize EUDR customs compliance by connecting DDS reference numbers and declaration identifiers with the underlying supplier, product, batch, shipment, and due-diligence data. Instead of managing references separately in spreadsheets or across multiple systems, companies can maintain a connected compliance trail from source-level information through procurement and shipment. This makes it easier to retrieve the correct EUDR reference for customs declarations, maintain traceability across shipments, and demonstrate the supporting evidence behind each declaration when required.

Common EUDR Customs Declaration Mistakes

• Treating the EUDR DDS as a document that can be submitted after customs release.
• Confusing a DDS reference number with a customs MRN or other customs identifier.
• Using a DDS reference for a shipment without checking whether the DDS actually covers that shipment.
• Creating a new DDS for every downstream transaction without first checking the applicable downstream rules.
• Failing to link the DDS reference to the shipment and customs declaration in internal systems.
• Relying on spreadsheets or emails without a controlled audit trail for reference numbers and coverage.

EUDR Customs Declaration Checklist

• Is the product within EUDR scope?
• Who is the operator responsible for the relevant placing on the market or export?
• Is the customs procedure release for free circulation or export?
• Has the applicable DDS or simplified declaration been submitted?
• Has the Information System assigned the applicable reference number or declaration identifier?
• Is the reference available to customs before release or export, where required?
• Does the reference cover the specific product and shipment?
• If the product is downstream, is it already covered by an upstream DDS or simplified declaration?
• Are the customs, shipment and EUDR records linked and retrievable?

Conclusion

EUDR customs declarations connect regulatory due diligence with the practical movement of goods across the EU border. For upstream operators, the key operational requirement is to ensure that the applicable DDS reference number or, where relevant, the declaration identifier is available to customs before release for free circulation or export.

For downstream operators, the analysis is different. Products may already be covered by an upstream DDS or simplified declaration, so businesses should first establish the applicable downstream obligations rather than assuming that every transaction requires a new DDS.

The most reliable approach is to connect EUDR submissions with shipment, batch and customs data in a single traceability workflow. This gives compliance teams a clear audit trail and helps ensure that the correct EUDR reference is available when customs and competent authorities need it.

Frequently Asked Questions (FAQ’s)