When you submit a due diligence declaration under the EUDR in the EU information system, that declaration receives a reference number. If you don't pass that number on to the party that subsequently trades your product further, that party cannot rely on your declaration and may have to conduct due diligence themselves, with all the time and documentation that entails. In practice, this means delays, additional requests from your buyer, and a business relationship under strain.
The reference number is not an administrative detail; it is the link by which the information system traces a product through the supply chain. Anyone further down the chain who resells the same product without modification can refer to the declaration already submitted instead of preparing a new one. Without that number, that option disappears, and the burden shifts to the next link.
Why the number is the linchpin of the supply chain
The regulation distinguishes between economic operators, who place a product on the EU market for the first time, and traders, who subsequently trade it further. Traders without SME status must in principle either submit a declaration themselves or refer to an existing one. Smaller traders may, under certain conditions, refer to the reference number of their supplier. Without that number, that option disappears, and a separate declaration is still required, while the underlying data on origin and geolocation may not be held by that buyer but by you.
This affects not only the buyer. If your own declaration does not properly flow through to the next link, it can raise questions during an inspection further down the chain, and those questions often still reach you, because you are the source of the data. For more information on how roles and obligations in the supply chain are precisely interconnected, see the role check that shows your position in the supply chain in a few questions.
What goes wrong in practice
Most often it goes wrong in transfers within a group of companies, for example between an importer and an affiliated distributor, where it is assumed that the declaration is already 'known within the company'. However, the information system works per submission, not per company name. Also with mixed batches, where one shipment consists of multiple deliveries, it is not self-evident which reference number belongs to which part, and that requires careful administration per product stream.
A second recurring issue is timing. A declaration is submitted before a product is placed on the market or exported, but the reference number sometimes only reaches the next link after delivery, because it is not a standard part of the trading documents. Anyone who wants to prevent this systematically ensures the number is included as a standard part of invoicing or the delivery file, alongside the other data that is already being kept anyway. What such a file per product stream looks like, including the documents that go with it, is described in the knowledge base with topics for each situation.
What this means for your own administration
The obligation to retain data for five years applies not only to the declaration itself but also to the correspondence in which you have shared the reference number. An email or delivery note containing the number is part of that evidence. During an inspection, the competent authority can ask how a product has moved through the supply chain, and a missing link in that chain is harder to resolve afterward than to properly document beforehand.
The legal assessment of who in your specific supply chain must submit which declaration, and when a reference to an existing number is sufficient, remains your responsibility and, where necessary, that of a lawyer or the competent supervisory authority. More on how eudri.com structures dossiers and declarations without us stating that a product is deforestation-free can be read on the page that explains where our information comes from.
If you first want to clarify what your own role is and what obligation goes with it, that is the starting point. Take the free role check or browse through the topics in the most frequently asked questions about the EUDR to see which step is relevant for your situation.