EUDR in logistics: DDS number, customs clearance and transport

EUDR is primarily associated with plot geolocation, deforestation risk assessment and the obligations of producers or importers. From a logistics perspective, however, one of the key moments comes later - when the correct due diligence statement reference number must be linked to specific goods and used for customs clearance.

A DDS, or due diligence statement, is not another transport document. The DDS number does not replace a CMR, MRN, container number, batch number or transport order.

A carrier also does not automatically become an EUDR operator simply because it transports a product covered by the Regulation.

What matters for the entire process, however, is the flow of information. The correct identifier must be available at the right time and refer to the correct product and quantity.

Who will be covered by EUDR from 30 December 2026?

EUDR covers seven main commodities: cattle, cocoa, coffee, oil palm, rubber, soy and wood, as well as certain derived products listed in the Regulation.

Whether a specific product falls within the scope of EUDR is not determined by its common or commercial name. Its HS/CN code and the current scope of Annex I are what matter.

From 30 December 2026, the rules will apply to large and medium-sized operators, as well as micro and small operators that were previously covered by the EU Timber Regulation. For other micro and small operators, the application date is 30 June 2027.

An operator placing a relevant product on the EU market or exporting it must carry out due diligence and submit a DDS in the EUDR Information System before the operation.

A DDS number is not a shipment number

A DDS contains information including details of the operator, the product, its quantity, the country of production and the geolocation of production areas. For imports and exports, the EORI number is also relevant.

Once the statement has been processed, the system assigns a reference number and a linked verification number.

The DDS number links the declared product to the completed due diligence process. However, it does not function as a logistics identifier.

In practice, the link between the DDS and identifiers used for a specific operation therefore needs to be maintained - for example, the batch number, customs declaration, container or transport order.

The key question is not simply:

"Do we have a DDS number?"

but:

"Does this number cover the correct product, source and quantity?"

Why the DDS must be ready before customs clearance

The timing of the DDS number is particularly important for imports and exports.

For EUDR-covered products entering the EU market, the DDS reference number or the relevant identifier used under a simplified procedure must be available to customs authorities before the goods are released for free circulation.

The person lodging the customs declaration must provide the correct identifier. The corresponding principle applies to exports.

In practice, the sequence therefore matters. The operator must first determine the scope of its obligations, gather the required information, carry out due diligence and submit the DDS. Only then can the relevant identifier be used in the customs declaration.

It is therefore risky to assume that the number can simply be "added later".

The EUDR system provides for risk profiling after a statement has been submitted. In certain situations, the release of the number may be delayed in connection with a control.

Obtaining the DDS should therefore not be left until the final minutes before customs clearance.

One DDS may cover several shipments

The link between a DDS and transport does not always follow a simple "one statement - one shipment" model.

One DDS may cover several shipments or batches where the relevant requirements are met. The reverse is also possible - a single customs declaration may refer to several DDS numbers.

For example, a batch of goods covered by one DDS may be dispatched in several separate shipments. In such a case, information needs to be maintained on how much of the declared quantity has been used in each operation.

A consolidated load, on the other hand, may contain goods from different sources linked to different DDS numbers. Simply providing the customs broker with a list of several numbers is not enough if it is unclear which number relates to which product and quantity.

This is why the DDS should be treated as part of product traceability rather than as an additional number added to the documentation.

What happens when batches are consolidated or split?

The process can become more complex when goods are repacked, consolidated or divided into smaller batches.

A change of pallet, container or other logistics unit should not result in the loss of information about the origin of the goods and their link to the correct DDS.

From a transport planning perspective, it is therefore important to maintain the ability to trace a specific shipment back to the information identifying the batch and statement to which it relates.

This does not mean that all information from the due diligence process needs to be stored in a TMS or included in transport documents. The logistics process should, however, make it possible to clearly identify the operation concerned.

Who is responsible for the DDS and what is the role of logistics?

EUDR does not automatically transfer the due diligence obligation to the carrier or freight forwarder.

The party responsible under EUDR must determine whether a product falls within the scope of the Regulation, collect the required information, carry out due diligence and submit the DDS.

For imports or exports, the information must then reach the person preparing the customs declaration so that the correct identifier can be included.

The role of logistics is different.

Before arranging the shipment, it is worth making sure that the information required for customs clearance has been prepared and relates to the specific batch that is to be transported.

The carrier, in turn, should receive the information necessary to carry out the specific transport operation correctly. The mere fact of transporting a product covered by EUDR does not mean that the carrier is responsible for carrying out the due diligence process.

What should be checked before dispatch?

For the transport of products covered by EUDR, several basic points are worth checking before the operation begins:

• whether the specific product falls within the current scope of EUDR,
• whether the party responsible for fulfilling the obligations under the Regulation has been identified,
• whether the relevant DDS has been submitted and the required identifier obtained,
• whether the number relates to the correct product and source,
• whether it covers the appropriate quantity,
• whether the identifier has been provided to the person preparing the customs declaration,
• whether the link between the specific shipment and the correct DDS has been maintained when batches are split or consolidated.

The point is not for the freight forwarder or carrier to independently determine whether a product complies with EUDR.

From a transport perspective, the key is to make sure that the operation is ready for customs clearance and that the required information is available before the stage at which it is needed.

The key is linking the DDS to the correct goods

EUDR introduces new obligations primarily for operators placing certain goods on the EU market or exporting them. However, the effects of these obligations will also be visible in customs clearance and transport planning.

The DDS number alone is not enough.

It must relate to the correct product, source and quantity and, for imports or exports, reach the customs declaration at the right time.

The more batches, shipments, consolidations and parties involved in the process, the more important it becomes to maintain this link.

For logistics, one of the most important practical aspects of EUDR will therefore not be the creation of another transport document, but maintaining the correct link between the DDS, the goods and the specific transport operation.

—

This article is for informational purposes only. The scope of EUDR, the obligations of individual parties and the rules governing the Information System may be further clarified. The latest regulations and guidance from the European Commission should therefore be verified before carrying out a specific operation.