EUDR Information System and Due Diligence Statements Explained

The system records the declaration, not the whole investigation

This entry is the working guide to the system: the record types it holds, the actors who submit them and how submissions are managed in practice. For the short definition of what the system is, see the separate entry 'What Is the EUDR Information System?'.

The EUDR Information System is the Commission's TRACES-based platform for submitting and managing due diligence statements and simplified declarations. It links the responsible business, the declared relevant products and the prescribed origin information to a regulatory record that authorities can examine. Using the platform correctly is an important part of compliance, but successful submission does not prove that the goods satisfy the deforestation-free and legality conditions.

An operator must first establish the relevant evidence and reach the required conclusion. It then makes the prescribed declaration available before the covered placing on the market or export, once the applicable obligations start. The legal process should drive the software workflow. An organisation that obtains a reference number before anybody has reviewed contradictory origin evidence has completed a technical action without resolving its substantive compliance problem.

The current baseline includes the 2025 revision of the EUDR actor model and the July 2026 amendment to the Information System implementing rules. Older instructions describing every downstream business as an ordinary statement submitter, or treating simplified declarations as a future concept outside the system, can mislead users preparing for the current obligations.

Assign the correct actor and record type

Operators subject to Article 4 submit ordinary due diligence statements under Annex II. Qualifying micro or small primary operators use the separate Article 4a regime and Annex III simplified declaration. The qualification is specific: being a micro or small company does not alone entitle a purchaser or importer to use the primary-operator route.

A simplified declaration is a one-time mechanism with rules for updates and, in specified circumstances, information made available by a Member State from an existing legally established database. It results in a declaration identifier. The primary operator must have that identifier before the covered placing or export even where the Member State database route applies. The Article 4a postal-address alternative also belongs to that particular regime.

Downstream operators and traders have separate Article 5 duties. Non-SME downstream operators and non-SME traders must register in the Information System, but registration does not imply an ordinary duty to submit a fresh statement for every product already covered upstream. The statement responsibility guide explains how to assign the obligation to the actual transaction rather than the company's commercial label.

Registration and authority to act

Keep personal authentication, legal entity registration and submission identifiers distinct. An employee's EU Login authenticates the individual; it does not establish that the employee can act for any company in the group. The implementing rules provide for a single account with roles and require registration information to remain current. An account arrangement should preserve responsibility as staff and organisation details change.

An authorised representative can submit within the applicable mandate, but the operator remains responsible for the underlying compliance. Decide how final content is approved and how records are returned to the operator. If one representative or service user works for several entities, selecting the correct represented operator is essential. Shared branding and a central purchasing function do not make separate legal persons interchangeable.

The attribution rule for ordinary statements changed with application from 15 October 2026. Statements are attributed to the competent authorities of the Member State in which the operator is established. For an operator outside the Union, attribution follows the Member State associated with its unique identifier in the system. Do not copy the former entry-or-exit-country hierarchy from an older manual without checking this change.

Prepare the ordinary statement's information

Annex II requires operator identity and the applicable EORI information, product code and description, quantities in the prescribed units, country of production and required geolocation. For wood, the current implementing rules require full scientific names of the relevant species. The prescribed confirmation records the completed due diligence and conclusion of no or only negligible risk regarding the deforestation-free and legality conditions.

Do not confuse the electronic statement with the complete Article 9 evidence file. Supplier documents, legal production evidence and the analysis supporting a risk conclusion can remain crucial even where they are not mandatory attachments to the statement. The operator needs a reliable way to explain why the submitted description and origins correspond to the actual products.

Location data can be entered through the interface or prepared in the supported GeoJSON format. The geolocation submission guide explains the importance of matching the technical file to the real production locations. A well-formed polygon in the wrong place can pass a structural check while leaving the statement factually wrong.

Understand the three identifier concepts

The system assigns a reference number to an ordinary due diligence statement and a declaration identifier to a simplified declaration. It also assigns an associated verification number, which serves an additional security purpose for information access. Keep these values labelled separately in commercial and technical records. An internal field named “EUDR code” can conceal which value staff are actually using.

After the prescribed risk profiling, the identifiers become available under the implementing rules, subject to the applicable authority powers to delay availability. The risk status is not a score disclosed to the submitting user. Nor does receiving a number prevent later checks or corrective action. The reference number explanation covers the product association that must remain clear after the number is issued.

Article 4(7) addresses the operator's communication of reference numbers or declaration identifiers to supplied downstream businesses. Under Article 5(3)(a), downstream identifier collection is expressly required where the supplier is an operator. Do not turn that rule into a universal duty to transmit and resubmit numbers through every later downstream sale. Broader commercial traceability arrangements should be identified as such.

Submit before the relevant transaction

The general substantive application date is 30 December 2026. Most qualifying micro and small operators have the later 30 June 2027 date, subject to the exact Article 38 conditions and exceptions. Product-specific deferred scope dates also need separate checking. Opening an account or using the platform for training before those dates does not change the business's statutory application date.

Plan submission after the evidence and approval are complete and before the relevant placing or export. Do not confuse a network acknowledgement with a completed outcome. For imports and exports, coordinate the Information System record with the applicable customs identifier requirements under Article 26. A release process should identify unresolved submissions and give staff authority to hold the affected goods where required.

Changes and grouping have legal limits

Ordinary statements have a standard 72-hour amendment or withdrawal window after the reference becomes available, subject to earlier lockouts. Relevant events include customs presentation, market placement or export, an ongoing notified check and use in grouping under the amended provision. A reasoned authority extension is limited and conditional. The correction guide explains why the window is not a general permission to rewrite records after use.

Article 8a provides for grouping a user's own previous records, including the specified same-operator representative case. Individual records become grouped and replaced, and the grouped identifier is used for the stated communication and customs purposes. This is not a mechanism for downstream businesses to combine unrelated suppliers' records into an ordinary new declaration. The September 2026 user guide describes interface grouping as available and requires the group head's products and quantities to be entered correctly. Check the separate API service support before automating that workflow.

Automation, outages and durable evidence

The official interface and API are different routes into the same regulatory process. Follow current technical specifications, keep acceptance and production separate and reconcile each automated action to its outcome. Some official technical pages contain release-dependent descriptions, so verify the actual supported service and behaviour rather than treating every published example as a legal rule.

The 2026 amendment requires public availability and contingency information by 30 December 2026, including measures for qualifying unplanned outages exceeding 60 minutes. At this article's October review date, that requirement does not establish that a particular emergency-number procedure is already operational. Use published official arrangements when available, without inventing a substitute reference during a local error.

Keep the approved data, supporting conclusion, submitted record, identifiers and product associations under the business's retention controls. The evidence checklist offers a practical reconstruction test. A colleague should be able to take a commercial lot and identify its responsible entity, reviewed origins, regulatory record and change history. That ability is a stronger indication of readiness than a functioning account alone.