The EUDR reference number: format, verification number, sharing along the supply chain and why you cannot apply for one

Hardly any question about the Deforestation Regulation is asked as often as the one about the reference number, and hardly any is answered incorrectly as often. You cannot apply for it. It does not travel through the entire supply chain. And it is not proof that a product is deforestation-free, only the receipt showing that someone has submitted a due diligence statement.

This article explains how the number comes about, what the verification number alongside it is for, who has to pass it on to whom and exactly where the obligation to pass it on ends, what belongs in the customs declaration and what applies if you have no number at all. At the end there is a cheat sheet to download that you can hand to purchasing, sales and your customs department.

What the reference number is

An operator who places a relevant product on the market or exports it submits a due diligence statement in the EU information system beforehand. The system then creates a risk profile and immediately assigns a reference number to the statement, together with an associated verification number (Article 7 of Implementing Regulation (EU) 2024/3084 as amended by Implementing Regulation (EU) 2026/1565). Both are made available to the user in the system.

The reference number therefore identifies a statement, not a product and not a company. It says: for these goods a due diligence statement exists, submitted by this operator, with this content. It does not say whether the underlying due diligence was properly carried out.

The verification number is something different. Under Article 3(f) of the Implementing Regulation it is a security code that the system additionally assigns to the statement in order to protect the data it contains. It is known only to the declarant and the competent authority and is passed on confidentially together with the reference number when a downstream actor wants to reference the upstream statement in its own statement (EUDR user manual, section 2.1). Anyone who passes on the reference number but withholds the verification number thereby prevents the recipient from viewing or linking the statement in the system.

Since Implementing Regulation (EU) 2026/1565 there has been a third number: micro and small operators with their own production from a low-risk country submit a simplified declaration instead of a due diligence statement and receive an identification number for it, likewise with a verification number. Wherever the reference number is referred to in what follows, the identification number applies accordingly for this group.

On the format: the Regulation prescribes none; the system issues the number. The structure can be derived from the Commission's specification for the so-called conventional reference number, which has the format 99EU9999999999: two digits for the year, two letters for the country code, ten digits as a sequential number. If you want to check whether a number you have received is genuine, use the verification function in the information system, which is also available as a bulk CSV check (Commission FAQ 7.25). That is the only reliable way to validate a number, not the plausibility of the number pattern.

Why you do not apply for one

The search term "apply for EUDR reference number" is one of the most frequent, and behind it sits a misunderstanding with consequences. There is no office where you order a number. The route is always the same: register in the information system, carry out the due diligence, submit the statement, receive the number. If you do not submit a due diligence statement, you do not get a number, and if you are not an operator, you do not submit a statement and do not need one either.

Two things can get in the way. First, the competent authorities may delay the provision of the number in order to check whether the product complies with the requirements. The delay should be as short as possible, but may be extended at the authority's discretion (Article 7(3) of the Implementing Regulation). Second, authorities may reject a due diligence statement for as long as the number has not yet been provided. A rejected product then counts as a product without a due diligence statement (Article 8). Both are an argument for not waiting until the day of customs clearance to submit statements.

What the due diligence statement looks like in substance and what belongs in it is set out in EUDR due diligence statement: template, mandatory content and submission in the information system.

Who passes it to whom, and where it stops

This is where the second major misconception lies, the one that has kept many companies busy for months: the reference number does not cascade through the entire supply chain.

Article 4(7) obliges operators to communicate the reference numbers of the due diligence statements to downstream operators and traders, and where applicable the identification numbers. The Federal Office for Agriculture and Food (BLE) put it in a nutshell in its webinar answers of May 2026: the operator is obliged to pass the reference number on to the first downstream actor, who must keep it. That first downstream actor is under no obligation to pass it on.

For the first downstream operator or trader, the number is therefore passive information: they collect it, store it and present it at the authority's request. Article 5(3) requires downstream operators and traders to record the identity of their suppliers and of their business customers and, where the supplier is an operator, the reference numbers in addition. Nothing more. They neither have to submit a due diligence statement of their own nor verify the upstream due diligence (guidelines OJ C/2026/3896, section on the obligations of downstream operators and traders).

Further down the chain nobody receives a number any more, because the supplier there is no longer an operator but a downstream actor themselves. If, as the third or fourth link, you demand a reference number from your upstream supplier, you are demanding something that this supplier does not legally owe. The study on EUDR simplification by the German Economic Institute (IW) puts it like this: the obligation to record and pass on reference numbers along the entire supply chain no longer applies.

Two exceptions round out the picture. Downstream operators and traders that are not SMEs may, when submitting a due diligence statement of their own, refer to the upstream due diligence by quoting the relevant reference number (Article 4(9)). For that they need the verification number as well. And micro and small operators that use products for which a due diligence statement has already been submitted do not have to carry out due diligence of their own and instead quote to customs the reference number of the statement already submitted (Article 4(8), TARIC code C717).

How to determine your own role is set out in Trader or operator? EUDR roles, SME thresholds and deadlines.

In what form the number is passed on

The Regulation lays down no requirements here. The BLE expressly confirmed in its webinar answers that the number is not passed on through the EU information system, and that the Regulation does not govern how this is to happen. The invoice, the delivery note, an email or accompanying documents are all possible. The Commission makes the same point in its FAQ 3.8 and leaves it to the parties to settle under private law how the number is passed on.

In practice this means: settle it contractually, and commit to a single place. A number that turns up on the delivery note one time and in an email signature the next is one that nobody in goods receipt will find again. What works well is a dedicated line on the invoice or the delivery note with the reference number, the verification number and the goods item they relate to, supplemented by a clause in the framework agreement that fixes the format and the timing.

The information is kept for five years. That applies to the operator's due diligence documentation just as much as to the details collected by downstream actors under Article 5(3).

What happens at customs

On import and export, the reference number meets the customs system. The number is entered in the customs declaration in the documents section, with the appropriate TARIC document code. Six scenarios cover everyday practice.

Standard import case: The declarant enters code C716 together with the reference number of the due diligence statement. Without this entry, the import is not permitted after the check.

Micro and small operators under Article 4(8): Code C717 with the reference number of the statement already submitted earlier.

Export by an operator: The reference number or the statement identifier must be made available to the customs authorities before export (Article 26(4)).

Export by a downstream operator: No reference number is to be entered here. Instead, a dedicated TARIC certificate code is available that exempts downstream operators from making the entry (Commission FAQ 5.6.1). This concerns, for example, a company that buys coffee beans on the European market and exports them, or a chocolate manufacturer that processes imported cocoa and exports the chocolate. As at September 2026, this code had been announced but not yet published; check the current TARIC status before you export.

Goods from the transitional period: For products placed on the market before the date of application, no due diligence statement has to be submitted in the system. If they are exported or re-imported later, the conventional reference number in the format 99EU9999999999 may be used in the customs declaration. It may stand alongside genuine reference numbers in the same declaration, for different goods items or even for the same one. Its use is recorded in the customs systems, and the competent authorities may require evidence that the goods were in fact placed on the market during the transitional period. As evidence the Commission accepts, for imported goods, the customs declaration from that time and, for EU goods, for example felling records, ear tags and animal passports, invoices, freight documents or delivery notes (FAQ 9.2).

No number at all, because the Regulation does not apply: There are separate Y codes for this. Y129 for goods under an ex code of Annex I that do not fall within the scope. Y132 for products manufactured before the cut-off date. Y133 for goods consisting entirely of material that has completed its life cycle and would otherwise be waste. Y142 for customs declarations connected with a non-commercial activity. The former code Y141 for the transitional arrangement for micro and small enterprises could only be used until 29 June 2025.

Which goods are affected at all, and how you check this against the customs tariff number, is covered in Which products and customs tariff numbers fall under the EUDR.

What to do when no number arrives

The most common call in the purchasing department: the supplier delivers, but no reference number. Before you escalate, clarify three questions.

Is your supplier an operator at all? Only in that case does the supplier owe you the number. If they buy in within the EU themselves and merely process or resell, they are a downstream actor and do not have to pass anything on to you. In that case you do not need the number either, only the identity of your supplier under Article 5(3).

Have the goods been released for free circulation at all? The BLE has described a typical case: cocoa powder comes from a Swiss supplier but is delivered from a German warehouse. If the goods have already been released for free circulation, the operator who did so has fulfilled the due diligence and must pass the number on to the first downstream actor. If, by contrast, they are held under customs warehousing or inward processing, they are not yet considered placed on the market, and whoever releases them later becomes the operator, possibly you yourself.

Do the goods fall within the transitional period or outside the scope? Then there is no number, but evidence or a Y code instead.

If it remains the case that your supplier is an operator and does not deliver the number, that is not a compliance problem but a procurement problem: without the information under Article 5(3) you may not make the product available on the market. And if you receive information pointing to non-compliance, you must inform the competent authority without delay, regardless of your size (Article 4(5), Article 5(5)).

The most common mistakes

1. Wanting to apply for the number. It arises only from a submitted due diligence statement.
2. Demanding it along the entire chain. The obligation to pass it on ends with the first downstream actor.
3. Forgetting the verification number. Without it the recipient cannot reference the statement.
4. Making the verification number public. It is a security code and does not belong in open distribution lists or catalogues.
5. Treating the number as proof of compliance. It only proves that a statement exists.
6. Looking for a number when exporting as a downstream operator. That is what the TARIC certificate code is for.
7. Submitting statements only on the day of customs clearance. Authorities may delay the provision of the number.
8. Not settling in the contract how the number is passed on. Without a fixed place and time, the number gets lost in goods receipt.

How to proceed in practice

1. Determine your role for each supply relationship. Operator, downstream operator or trader, and whether you are an SME or not. It follows from this whether you generate numbers, receive them or need none at all.

2. Sort your suppliers. Which of your suppliers are operators and owe you the number, and which are not? This sorting saves you half of the follow-up enquiries.

3. Define the handover point. One field on the invoice or the delivery note, with the reference number, the verification number and the link to the goods item, fixed by contract.

4. Check incoming numbers and file them. Record numbers at goods receipt, check their validity in the information system and store them in audit-proof form for five years.

5. Coordinate with customs. Whoever files the declaration needs the number in good time and must know which code applies in which case.

6. Allow lead time. Submit statements with a buffer so that a delay on the part of the authorities does not block the shipment.

How Polygon One helps

Polygon One generates due diligence statements from your product, supplier and geolocation data and submits them to the EU information system. The reference number and the verification number come back automatically and stay attached to the relevant shipment instead of ending up in a spreadsheet. Where you are a downstream actor, you record incoming numbers against the supply relationship and keep track of which items are still open. The information required under Article 5(3), that is the identity of your suppliers and your customers together with the numbers, is therefore held in one place and can be exported for a request from the authorities.

What the platform does not do: fulfil the due diligence obligation on your behalf, determine your role in legal terms or file the customs declaration. It makes sure that the numbers are where they are needed, and that in five years you can still trace which number belonged to which shipment.

If you would like to see what this looks like with your own supply chains, book a demo or read on at the product page for the EUDR module.

Download the cheat sheet

Two pages for purchasing, sales and customs: who gives which number to whom, what has to be stored, which TARIC code applies in which case, plus wording templates for the supplier enquiry and for the entry on the invoice and the delivery note.

• Download: EUDR reference number, cheat sheet for supply chain and customs (PDF)

Frequently asked questions

What is a DDS number?

Colloquially, the reference number of the due diligence statement (DDS). The information system assigns it as soon as the statement has been submitted and the risk profile created.

How is the EUDR reference number structured?

The Regulation does not prescribe a format. The format of the conventional reference number, 99EU9999999999, shows the structure: year, country code and sequential number. To find out whether a number is valid, check it in the information system.

Can I apply for a reference number?

No. It comes into existence solely through the submission of a due diligence statement in the EU information system.

Who has to store the reference number and who does not?

The operator passes it on to the first downstream operator or trader, who stores it and presents it on request. There is no obligation to pass it on beyond that point.

What is the verification number?

A security code that the system additionally assigns to the statement. It is known only to the declarant and the authority and is passed on confidentially together with the reference number if the recipient wants to reference the statement.

How do I state the reference number at customs?

On import, in the documents section of the customs declaration with TARIC document code C716; for the exemption under Article 4(8), with C717. On export, the number must be available to the customs authorities before the export takes place.

What applies on export if I am a downstream operator?

Then you do not need a reference number. A dedicated TARIC certificate code is envisaged for this case.

My supplier is not giving me a number. What now?

First check whether they are an operator at all. If they are not, they owe you no number. If they are, you need the information under Article 5(3) before you may make the goods available on the market.

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Articles 3, 4, 5, 9, 13, 26 and 33. Implementing Regulation (EU) 2024/3084 as amended by Implementing Regulation (EU) 2026/1565, Articles 3, 6, 7 and 8. Commission FAQ version 5 of 4 May 2026, questions 2.9, 3.4, 3.5, 3.8, 5.6.1, 5.8, 7.24 to 7.26 and 9.1 to 9.3. Commission guidelines, OJ C/2026/3896. Commission document on the conventional reference number. TARIC explanatory notes on the integration of the EUDR. EUDR user manual for operators v1.0. Responses of the Federal Office for Agriculture and Food to the IHK webinar of 21 May 2026. This article describes the legal position as at September 2026 and does not replace legal advice.