EUDR and customs clearance: how the DDS reference works

A due diligence statement does not clear your goods on its own. Customs will only release a consignment for free circulation or export once a valid DDS reference number is attached to the customs declaration, all ordinary customs formalities are met, and the consignment has not been flagged for a check. Filing the DDS in TRACES and clearing customs are two separate systems that have to agree with each other before goods move.

This guide covers the mechanics: what has to be true at the border, how the reference number gets from TRACES into your customs declaration, what happens when a consignment is flagged, and the gaps in the system you need to plan around rather than assume away.

What customs actually checks

Under Article 26 of Regulation (EU) 2023/1115, customs authorities are the gatekeepers for relevant products entering or leaving the EU market, but they are not the ones assessing deforestation risk. Their role is narrower and mechanical:

• Confirm a DDS reference number (or, for certain transitional cases, a conventional reference entry — see below) is present on the customs declaration.
• Confirm the consignment has not been flagged for verification by the national competent authority under Article 17(2), the risk-based control mechanism that sits behind TRACES.
• Suspend release if a flag exists, or if the competent authority asks for a hold, until that authority clears it.
• Release the product once ordinary customs formalities (classification, valuation, any other licensing) are also satisfied.

The legal basis for scope and the deforestation-free assessment itself sits entirely in the due diligence obligations under Articles 4 to 12 — customs does not re-run that assessment. For what the statement itself has to contain and how to file it, see how to submit an EUDR due diligence statement in TRACES, step by step; this guide picks up from an accepted statement and follows it through to the border.

Why the interface isn't fully automatic yet

The regulation anticipates a direct electronic interface, under Article 28(1), between the EU's Information System (built on TRACES) and national customs systems, so that a customs declaration naming a DDS reference number is checked against the Information System automatically. That interface is being built as part of the EU's wider Single Window Environment for Customs programme, which connects multiple partner-authority systems — plant health, CITES licensing and others — to national customs declarations, not just EUDR.

Until that interface is live for EUDR, Article 26 says its paragraphs on automated interface checks do not apply, and customs authorities instead rely on cooperation with national competent authorities under Article 27: information exchange, risk-based targeting and manual follow-up rather than a live system-to-system check on every declaration. In practice this means:

• The reference number still has to be on the declaration, and customs can still ask for it to be produced.
• Flags and holds are coordinated through the competent authority rather than triggered automatically by the customs system itself.
• Build in more lead time at the border than you would for a fully automated check, since a manual query takes longer than a system match.

Expect this to tighten over time rather than loosen. Note the date here if you are relying on it operationally, and check for an update before each applicable date.

Getting the reference number onto the declaration

The practical sequence, for a standard import:

1. File the DDS in TRACES before the goods arrive, not after. The reference number has to exist before you can use it.
2. Pass the reference number to whoever lodges your customs declaration — in-house customs team, freight forwarder or customs agent. Freight forwarders and carriers generally sit outside EUDR's own due diligence duties, but they still need the reference number from you to complete the declaration correctly; it is not their job to source it.
3. Enter the DDS reference number on the import declaration, alongside the normal customs data set — CN code, value, origin. National customs systems generally use a specific procedure code or additional-information code for this; check your member state's customs guidance for the exact field, since the data element differs by national system even though the requirement is EU-wide.
4. Where the product is explicitly out of scope (see when EUDR applies to packaging for one example of a scope boundary), a specific code exists for declaring a consignment as not covered by the regulation, rather than leaving the field blank. Confirm the current code with your customs authority or software provider before relying on it — these codes have been updated as the IT build has progressed, so a code from an older customs circular can be wrong by the time you file.
5. Keep the reference number reconciled against the commercial invoice and transport documents for that consignment. A mismatch between declared quantity and the DDS is one of the more common reasons a consignment gets held, not just a reason a DDS gets rejected.

Transitional rule for stock already in the pipeline

For products placed on the EU market, or exported, using a due diligence statement filed before the relevant application date, customs guidance has introduced a transitional entry — sometimes referred to as a conventional DDS reference — to cover declarations for stock that was already moving through the supply chain when the obligation to reference a live DDS number took effect. This is a bridging mechanism, not a way to avoid filing: it exists so that goods already in transit or storage are not stranded by a hard cut-over date. If you hold stock that will clear customs on or shortly after your applicable date, confirm with your customs agent or national authority whether this transitional entry applies to it, rather than assuming either that you need a fresh DDS for stock already covered, or that you can skip the reference entirely.

General statements covering more than one consignment

Most of this guide describes a single DDS matched to a single consignment, but the regulation also allows a general statement covering an expected volume of the same product over a stated period, filed once rather than per shipment. That changes how the customs side works, not the due diligence behind it:

• The same reference number is used on every customs declaration for a consignment that falls within what the general statement covers — same product, same supplier relationship, within the stated period and volume.
• If an actual shipment falls outside what the general statement described — a different supplier, a different country of production, or volume that exceeds what was declared — that shipment needs its own statement. Reusing a general statement's reference number for a consignment it does not actually cover is a mismatch, not a shortcut, and is the kind of discrepancy a competent authority's check is designed to catch.
• Keep a record, separate from the DDS itself, of which actual shipments you have matched against a general statement and how much of its declared volume remains. Nothing in the customs declaration itself tracks that running total for you.

For a freight-heavy importer moving the same commodity from the same supplier repeatedly, this is usually worth setting up deliberately with whoever manages your TRACES filing, rather than defaulting to one DDS per consignment and finding out later that a general statement would have saved real filing volume.

What holds a consignment at the border

Situation	What happens	What to do
No DDS reference on the declaration	Customs cannot release the consignment	File the DDS and obtain the reference before the goods are due to arrive, not on the day
Consignment flagged for a check (Article 17(2))	Release suspended until the competent authority clears it	Respond promptly to any request from the authority; do not reschedule transport assuming the hold will lift on your timeline
Reference number doesn't match the declared product, quantity or origin	Declaration likely rejected or queried	Reconcile DDS data against the commercial invoice before filing either
Product classified under a CN code outside current Annex I scope	Declaration may be incorrectly treated as requiring a DDS, or incorrectly treated as exempt	Confirm CN code against the current Annex I list — see what changed in Annex I under Delegated Regulation (EU) 2026/2102
Stock already in transit at your applicable date	May qualify for the transitional reference entry	Check with your customs authority before clearance, not after a hold

Setting this up with a freight forwarder or customs agent

If you use a third party to lodge declarations, treat the EUDR reference number the same way you treat an EORI number or a preferential-origin certificate: a standing data requirement for every relevant shipment, agreed in writing, not a one-off favour you ask for when a consignment is already moving. Three things are worth confirming with them directly, rather than assuming:

• Which of your product lines they currently treat as in scope. A forwarder working from an outdated product list may be entering a DDS reference where none is needed, or — more seriously — leaving it off a declaration that does need one, because their classification reference has not caught up with the current Annex I list.
• What happens when a reference number is missing at the point they need to lodge the declaration. Agree in advance whether they hold the declaration and contact you, or whether they decline to lodge it — a mid-shipment debate about who is at fault for a missed deadline is the wrong moment to have that conversation for the first time.
• Who is notified if a consignment is flagged. The competent authority's query may go to the operator of record rather than to the agent who lodged the declaration, so make sure your own team, not just the agent, is watching for it.

None of this shifts legal responsibility for the due diligence itself, which stays with the operator regardless of who presses submit on the customs declaration. It simply avoids the gap where everyone assumed someone else was watching the border.

Where the responsibility sits

Customs clearance failing is not a customs problem to solve after the fact — it is a symptom of the due diligence work not being ready in time. The obligation to have a valid, accurate DDS sits with the operator, not with the customs agent who lodges the declaration or the carrier who moves the goods. If you are a downstream trader rather than the first operator to place the product on the market, you are not filing your own DDS at all; you are relying on an upstream reference number, and what downstream operators and traders still have to do covers what you are responsible for checking instead.

Freight and logistics teams that handle customs declarations on a client's behalf should treat the reference number as a mandatory data field to request at booking, the same way they would request an EORI number, rather than something to chase once a consignment is already at the port.

Get ahead of your first live filing

The border is the wrong place to discover that a DDS is missing, wrong, or filed under the wrong statement type. File early, reconcile the reference number against your commercial documents before the goods move, and confirm with your customs agent which national declaration field and codes apply to your member state.

Check what your business needs to do under the EUDR to get a dated plan for registration, filing and the records your customs declarations will need to match.