Whether you have to submit a due diligence statement under the Deforestation Regulation, only collect reference numbers or do nothing at all depends on two things: what you do with the goods and which CN code they have. The check asks for both, plus company size and country of production. You then see your role, your deadline and your obligations as a checklist.
Step 1 of 3: Activity
Check each product and sourcing route separately. You can check further routes afterwards, the results add up.
The role follows first from the activity. Importers place the goods on the market with release for free circulation and are operators, even if the goods stay in their own business. Buying in the EU and reselling unchanged makes you a trader. Exporting goods bought in the EU makes you a downstream operator. Forwarders, warehouse keepers, customs representatives and toll processors who do not own the goods have no role of their own.
For processing, the CN code decides. Under FAQ 3.1.1 of the Commission as published on 21 August 2026, every change of the eight-digit CN code creates a new product: a roaster buying green coffee (0901 11) from a supplier established in the EU and selling roasted coffee (0901 21) is a downstream operator, although both fall under heading 0901. Only whoever passes the goods on under an unchanged CN code remains a trader. If your product is not listed in Annex I at all, such as bakery products with cocoa, you have no obligations for it. In the check, the CN code ruler shows which digits Annex I lists.
Size and country of production determine how much there is to do. For operators, the country sets the depth of due diligence: simplified for low risk, full for standard and high risk under Implementing Regulation (EU) 2025/1093. For downstream operators and traders, size decides whether registration and checks on reasoned concern are added. Anyone who produces or harvests in the EU and is a natural person, micro or small enterprise only submits a one-off simplified declaration.
Goods placed on the market before the relevant date are not covered by the Regulation. Timber from the annex of the Timber Regulation stays under the old rules together with derived products.
For ex headings only part of a CN code is covered, for example for seats, rubber articles or palm oil derivatives. The check shows the note from Annex I but does not make the individual classification. In groups, each company is assessed on its own, including for size. If you source through several routes, check each route separately; the check collects the results. And it is not legal advice.
For whole article lists there is the free scope checker as an Excel file. It matches your CN codes against Annex I and documents the check.
A roaster buying green coffee from a supplier established in the EU is a downstream operator: roasted coffee (0901 21) has a different CN code from green coffee (0901 11), and under FAQ 3.1.1 any change of the CN code counts. The roaster submits no due diligence statement (DDS) of its own; its deadline is 30 December 2026, even as a small enterprise. A roaster importing green coffee itself or buying it from an importer not established in the EU is the operator for it (Article 7).
No. The deferral under Article 38(3) applies only to operators that existed as a natural person, micro or small enterprise on 31 December 2024, and not to timber from the annex of the Timber Regulation. Traders and downstream operators of any size are bound from 30 December 2026.
That is common, for example for a furniture maker that buys panels in the EU and imports solid wood itself. Check each sourcing route separately. Whoever imports and processes into a product with a different CN code is the operator for the import and at the same time downstream for the new product (FAQ 3.1.1, 3.8).
None, as long as they do not own the goods. The due diligence statement remains the importer's obligation. The customs representative enters the importer's reference number with document code C716 in the customs declaration.
For this product, yes. What counts is the CN code, not the share of a commodity: bakery products with cocoa (1905) or metal furniture (9403 20) are not covered. Since 18 September 2026, cattle hides and leather, conveyor belts and other articles of vulcanised rubber have also been deleted.
No. Exporting goods bought in the EU makes you a downstream operator, and under FAQ 5.6.1 you do not state a reference number in the export declaration. The Commission has announced a dedicated TARIC certificate code for this, which had not been published by 18 September 2026. Whoever exports goods they imported themselves, unchanged, remains the operator and makes the reference number available to customs.
Under the Accounting Directive, two of three criteria on the balance sheet date count: balance sheet total, turnover and average number of employees. A small enterprise has at most EUR 5 million balance sheet total, EUR 10 million turnover and 50 employees. The individual company is assessed, not the group. The check can calculate the size from your figures.
No. The check runs in the browser, stores no inputs and sets no cookies. Only what you send yourself through the email form is transmitted.
It reflects the legal situation of 18 September 2026: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Annex I as amended by Delegated Regulation (EU) 2026/2102, the country list of Implementing Regulation (EU) 2025/1093 and the fifth edition of the Commission FAQ. When any of this changes, we update the check.
Operators need geodata, due diligence statements and reference numbers for every delivery. Downstream operators and traders have to collect reference numbers and keep them for five years. In a demo we show you, using your own products, how Polygon One handles both. Book a demo
Read on: EUDR guide 2026, reference number and passing it on, the EUDR for the timber industry, the EUDR for coffee and cocoa.
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