Many companies preparing for the European regulation on deforestation-free products (EUDR) spend most of their time collecting geodata and supplier information. That is correct, but it is usually not the step where things go wrong. The most common mistake is in the declaration itself: a reference number that is missing, no longer valid, or does not match the consignment of goods for which it is used.
Anyone in the supply chain after the first economic operator — a trader, a processor, an importer reselling goods within the EU — may under certain conditions refer to the due diligence declaration already submitted earlier in the chain, instead of collecting all underlying data themselves. This is done via the reference number that the EU information system assigns upon submission. That is precisely where things often go wrong.
Why this happens so often
Reference numbers are often passed on by email or on a supplier invoice, separate from the product they actually belong to. For companies working with varying consignments and multiple suppliers, it quickly becomes unclear which number belongs to which delivery. Another recurring problem is that the number is correct at the time of receipt, but is no longer valid by the time the own declaration is submitted, for example because the underlying declaration has since been revoked or replaced.
It also happens that a number is taken over without checking whether it actually corresponds to the correct commodity, the correct country of origin and the correct quantity. This may not seem to be a problem at the first submission, but becomes apparent as soon as a competent authority traces back through the chain and the data do not match.
What the consequences are
A declaration with an incorrect or untraceable reference number may be rejected by the information system upon submission, or — more troublesome — may actually be accepted even though the underlying link is incorrect. In the latter case, you often only notice once questions arise, and then working out where things went wrong is more effort than recording it correctly in the first place.
How to prevent this
The principle is simple: record for each consignment of goods which reference number belongs to it, who you received it from and on which date. If in doubt, always verify with the supplier themselves whether the number is still valid, rather than relying on a number you received months earlier. the guidance per obligation in the knowledge base addresses what exactly must be recorded for each role, and when you as a trader may refer to an earlier declaration instead of conducting a full due diligence yourself.
If you are unsure whether you are in this situation — economic operator submitting first, or trader referring to an earlier link in the chain — you can have that clarified in a few questions. The role that fits your company determines not only the effective date of your obligation, but also whether you build a complete declaration yourself or can rely on the work of a link earlier in the chain.
Other mistakes that often appear together
An incorrect reference number rarely stands alone. Companies that have made this mistake often also have unclear ideas about which documents they need to keep alongside the declaration, and for how long. This is a separate obligation: data and underlying documents must remain accessible for a defined period, even after submission of the declaration. Ensure that the link between reference number, consignment of goods and underlying documents is recorded in one place, not scattered across emails and invoices.
Eudri.com structures this data by product stream: which supplier, which country of origin, which plots and which reference number belong together, with the associated documents. Based on this, we generate the due diligence statement or the simplified statement. We never declare ourselves that a product is deforestation-free; the statutory risk assessment remains with you as a market participant or trader. How we process the data and where the source attribution comes from is described on the page where the information comes from.
Would you like to know if this is relevant to your company, and which role and obligation applies to you? Take the free role check, or read the other topics in the knowledge base to see which step is first for your situation.