Submitting an EUDR declaration: does it differ per EU country?

The EU information system for the EUDR declaration is one system for the entire Union, but who may submit the declaration and who oversees it depends on where your business is established and in which country you are active.

One system, but not the same route everywhere

The EU information system in which you submit the due diligence declaration is one central system for the entire European Union. You do not submit a separate form per country and there is no Dutch, German or French version of the declaration itself. What does differ per country is who may be granted access to that system on behalf of your business, which competent authority provides oversight, and whether you as a non-EU-established party must comply with additional conditions. These differences are therefore not in the form, but in the organisation around it.

For an SME that only purchases and sells from the Netherlands or Belgium, this distinction is usually a matter of administration: you register your business once, and the reference number of your declaration is subsequently usable throughout the entire Union when you pass goods on to a trader in another EU country. For businesses that are organised more internationally, or that operate through a parent company outside the EU, this is more nuanced.

What remains the same, regardless of country

The core of the regulation — the role you perform, the obligation that comes with it and the product involved — does not change per member state. A coffee roaster in Rotterdam and a coffee roaster in Hamburg fall under the same definitions and the same obligations. Also, the reference number that the system assigns to a submitted declaration is valid EU-wide: if you resell goods to a trader in another member state, that trader can refer to your due diligence declaration using the same number, without needing a new declaration for the same batch. Which role exactly you have in your specific chain, you can have that clarified in a few questions.

What does differ: oversight and representation

What differs per country is which competent authority carries out the checks. Each member state appoints its own supervisor, and that authority looks at the market participants and traders that are established in that country or place goods on the market there. This means that the body you come into contact with during an inspection depends on your place of establishment and not on where your raw material comes from.

A second difference applies to businesses that are not established in the European Union, but do place goods on the EU market. The regulation provides for the possibility of appointing an authorised representative: a party that is established in the EU and that fulfils the obligations on behalf of the non-EU business, including submitting the declaration in the information system. For an SME importer that is itself based in the EU and purchases directly from a producer outside the Union, this changes little; for a group with headquarters outside the EU and a sales operation within the EU, this is a matter to arrange in advance, preferably with legal advice on the precise structure.

Why this is often confused with the country classification of countries of origin

This classification per member state of establishment is in practice often confused with the risk classification of countries of origin — the classification into low, standard or high risk that determines how strictly a country of origin is assessed. That is a different mechanism: the risk classification says something about the country where your coffee, cocoa or timber comes from, while the role of the competent authority says something about the country where your business is established. Both play a role in the same file, but they answer a different question. Which document exactly you need per raw material and country of origin can be found in a detailed overview in the knowledge base by topic.

In practice: what this means for your submission

For most SMEs with a single location in the EU, little changes in practice: you register your business, submit the declaration via the EU-wide system, and the competent authority of your own country is the one that oversees it. It becomes more complex as soon as you import goods via another EU country than the one where your business is established, or when your business structure includes a non-EU entity. In those cases, it is advisable to clarify in advance which entity within your group is the submitting party, and which authority is associated with it. How we structure the data for such a file and which sources underpin it, you can read on the page about how our information is created.

The legal assessment of your specific situation, especially with an international business structure, remains a matter for yourself or your lawyer; we structure and validate data, but never declare on your behalf that a submission is complete or correct for the competent authority.