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.

In brief

The reference number identifies a submitted due diligence statement, not a product and not a company. The EU information system assigns it together with a verification number once the statement has been submitted; you cannot apply for it.

The operator passes the number on to the first downstream operator or trader, who keeps it for five years together with the verification number. Beyond that first step there is no obligation to pass it on.

At customs, the standard import case carries C716 with the reference number, micro and small primary operators under Article 4a declare C717 with the identifier of their simplified declaration, and re-imports by downstream operators carry C720 (non-SME) or C725 (SME). Downstream operators that export need no number and declare Y196 or Y188 instead.

The number only shows that a statement exists. It is not proof that the product is deforestation-free.

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.

The referencing rules in Article 4(8) and (9) were deleted by Regulation (EU) 2025/2650. Downstream operators and traders submit no due diligence statement of their own, whatever their size; they keep the reference number they received, together with the verification number, for at least five years under Article 5(3) and (4) and quote it to customs on re-import with code C725 as an SME or C720 as a non-SME. Micro and small primary operators with a simplified declaration under Article 4a declare its identifier with C717.

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

Conventional reference number 99EU9999999999 and document code C718

For products placed on the market during the transitional period, the Commission FAQ names a conventional reference number, 99EU9999999999, which is used in the customs declaration on their export or re-import; since the TARIC revision of 23 September 2026 document code C718 goes with it. It is not issued by the Information System and belongs to no company. When and how it is used, with the evidence you need, is explained in the article on export, re-import and re-export.

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) (Article 5(4)).

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. It has to be made available by whoever lodges the customs declaration (Article 26(4)), which may also be a freight forwarder or customs representative acting for the operator. What forwarders and customs representatives need from their clients for this is set out in EUDR for freight forwarders and customs brokers. Seven scenarios cover everyday practice. An overview of all codes: TARIC document codes.

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 primary operators under Article 4a: Code C717 with the identifier of their simplified declaration.

Re-import by a downstream operator: Code C725 as an SME or C720 as a non-SME, together with the reference number of the upstream statement (Article 5(3)(a)); there is no statement of its own.

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, the export declaration carries the exemption code Y188 as an SME or Y196 as a non-SME (Commission FAQ 5.6.1, TARIC document revision 1 of 23 September 2026). 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.

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, document code C718 with 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 used and second-hand products, waste, recovered products and goods consisting entirely of material that has completed its life cycle. Y142 for customs declarations connected with a non-commercial activity. Y141 for micro and small enterprises established as such by 31 December 2024, usable until 29 June 2027. Since 23 September 2026, Y187 for samples and test products, Y190 for packing material and Y191 for medicinal-product inputs and accompanying materials have been added.

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.

Reference number for courier and express shipments (DHL, UPS, FedEx)

If a courier such as DHL Express, UPS or FedEx handles customs clearance, it lodges the customs declaration as a customs representative under Article 18 of the Union Customs Code. It then acts either in the name and on behalf of its principal (direct representation) or in its own name on the principal's behalf (indirect representation). In neither case does the courier become an operator. According to Commission FAQ 3.15, customs representatives are never operators, because they neither place products on the market nor export them. Under the guidelines, freight forwarders, shipping agents and customs representatives without ownership of the goods are likewise neither operators nor traders, as long as they do not place products on the market, make them available or export them. A courier submits the due diligence statement only if it has also been given a separate mandate as authorised representative under Article 6.

On import, the operator is generally whoever is entered as importer in the customs declaration (guidelines OJ C/2026/3896). That person submits the due diligence statement before the import and receives the reference number. If the importer is not established in the EU, the first person established in the EU who makes the product available on the market is also deemed an operator (Article 7). A consumer is never an operator, even if entered as importer in the customs declaration; the operator is then whoever supplies the product commercially, for example the online retailer (Commission FAQ 3.19).

The reference number must be available to customs before release for free circulation. It has to be provided by the person lodging the customs declaration (Article 26(4)), so where the courier clears the goods, by the courier. It is entered in the documents section with TARIC code C716, the identifier of a simplified declaration with C717; for exempt goods the declaration carries the applicable Y code (Commission TARIC working document, revision 1 of 23 September 2026).

DHL Express asks the shipper or importer for the reference number or the TARIC document code, and for exempt goods the exemption code, electronically through its shipping systems when the shipment is created. According to the DHL Express customer notice, shipments without this entry cannot be cleared through customs. UPS makes the business that places the goods on the market or exports them responsible for providing the reference number when creating the UPS shipment, and requires it on the commercial invoice. FedEx advises registering in the Information System early so that the shipper can include the number for each product on the commercial invoice and the air waybill before shipping. While the shipment is on its way, FedEx may ask you to confirm the number or an exemption; storage charges may apply if shipments are held while waiting for EUDR information. None of the three notices says whether the courier acts as direct or indirect representative, or which field of its shipping systems the number goes into. Clarify both with your courier before the first shipment.

For exports, the UPS notice asks EU-based businesses that buy the goods from a supplier in the EU to put that supplier's reference number on the commercial invoice. According to Commission FAQ 5.6.1, however, a business that buys in the EU and exports is a downstream operator, and under Article 26(4) it needs no reference number on export; the export declaration then carries Y188 or Y196. In that case, agree with UPS what goes into the declaration.

There is no value or quantity threshold below which the Regulation does not apply (Commission FAQ 2.3). A single parcel therefore also needs a reference number, the identifier of a simplified declaration or an exemption code. Letters and other items of correspondence need no customs declaration, but if the envelope contains a relevant product, the customs declaration and the reference number apply as for any other shipment (FAQ 2.13).

Exempt are samples of negligible value and quantity which, by their presentation and quantity, can only be used to solicit orders, and products undergoing examination, analysis or tests that are used up or destroyed in the process or kept or returned only to meet legal or contractual obligations (Annex I, note 5, inserted by Delegated Regulation (EU) 2026/2102). The customs declaration then carries Y187. Parcels between private individuals, for example between relatives, are outside the Regulation (FAQ 3.16); the code for this is Y142.

Before shipping, the courier needs for each goods item concerned the commodity code and either the reference number of the due diligence statement, the identifier of a simplified declaration or the applicable exemption code. If your supplier abroad creates the shipment, give them the number before they do. Because the authority may delay the provision of the number, the due diligence statement should already have been submitted by then.

Requesting the reference number from your supplier

If you buy goods from an operator in the EU, you do not get the reference number from the Information System but from the supplier. The request should cover the supplier's role, the reference number with the verification number for each delivery item, and an agreement on where the number will appear from now on. The text module from the cheat sheet:

What to do with the answer: check the number and the verification number in the Information System (the verification function, also available as a CSV bulk check, Commission FAQ 7.25), assign them to the delivery item and keep both for five years. How the check works step by step is in the next section. If no number arrives, the section “What to do when no number arrives” helps.

Verify a supplier's reference number in TRACES (verification number)

You do not check a reference number from a supplier by looking at the number pattern, but in the EU information system. That is what the verification function “Verification” is for (Commission FAQ 7.25). It needs two entries: the reference number and the associated verification number. Without the verification number a statement cannot be checked, which is why it belongs in every supplier request.

1. 1. Obtain both numbers per delivery item. Under Article 4(7) the operator owes you the reference number. The operator does not have to provide the verification number unasked; non-SMEs can ask for it in case of substantiated concerns. Agree by contract on one fixed place for both, for example a line on the invoice or the delivery note.
2. 2. Check in the information system. Via the blue button “Verification” you enter the reference number and the verification number. For many numbers at once, the Commission FAQ describes a bulk check by CSV file. Where the function is and how to get into the system is explained in the submission guide. Some EUDR tools check incoming reference and verification numbers against the information system automatically; which ones describe this publicly is shown in the matrix of our EUDR software comparison.
3. 3. Read the result. The system answers with one of three results: valid, meaning available; not valid, meaning the statement exists but is not available, for example because it was withdrawn, rejected by the authority or merged into a grouping statement; or not found.
4. 4. File the result. The result can be saved as a dated PDF. File it with the delivery item and keep it together with the reference number and the verification number for at least five years (Article 5(4)).

What the answer shows, and what it does not. “Valid” means that an available due diligence statement exists in the system under this number. Nothing more. The verification function shows neither the content of the statement nor the geolocation data, and it does not say whether the product is deforestation-free or whether due diligence was properly exercised. Only downstream operators and traders that are not SMEs may view the content of an upstream statement, and only in case of substantiated concerns (Article 5(6)); they see the geolocation only if the submitter released it when submitting.

Who may verify, and who must. Downstream operators and traders of any size can verify. Non-SMEs are registered in the information system anyway under Article 5(2); for SMEs registration is voluntary. The Commission does not require a routine check of every number. What is mandatory is only to record and keep the numbers together with the information under Article 5(3).

If the result is “not found” or “not valid”. First check for typing errors and the link to the delivery item, and ask the supplier: within 72 hours after the number has been made available, the supplier can still amend or withdraw the statement, and the authority may delay the provision of the number. If that remains the case, you lack the information under Article 5(3) and may not make the product available on the market. If the information points to non-compliance, inform the competent authority without delay (Article 5(5)).

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 exemption codes Y188 and Y196 are 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. 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. 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. 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. 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. 5. Coordinate with customs. Whoever files the declaration needs the number in good time and must know which code applies in which case.
6. 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; on re-import by a downstream operator with C725 as an SME or C720 as a non-SME. On export, the number must be available to the customs authorities before the export takes place.

How do I provide the due diligence statement reference number to DHL, UPS or FedEx?

If the courier clears the goods, it lodges the customs declaration as customs representative and must make the reference number available to customs (Article 26(4)). DHL Express asks for it or the applicable TARIC code electronically when the shipment is created, UPS likewise when the shipment is created and on the commercial invoice. FedEx advises that the shipper include it on the commercial invoice and the air waybill before shipping. The due diligence statement itself is submitted by the operator, on import generally the importer; a customs representative is never an operator.

What applies on export if I am a downstream operator?

Then you do not need a reference number. The export declaration carries the exemption code Y188 as an SME or Y196 as a non-SME.

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.

What is a due diligence statement reference number?

A due diligence statement reference number is the number the EU information system assigns to a submitted due diligence statement (DDS), together with a verification number. It identifies the statement, not a product and not a company. It shows that a due diligence statement from a particular operator exists for the goods. It does not prove that the product is deforestation-free or that the underlying due diligence was properly carried out.

How do I get a due diligence statement reference number?

You get a due diligence statement reference number only by submitting a due diligence statement in the EU information system: register, carry out the due diligence, submit the statement, receive the number. There is no office where you order one. Downstream operators and traders submit no statement of their own; the operator passes the number on to the first downstream operator or trader. Allow lead time, because authorities may delay the provision of the number.

Do I need to register in the EU information system?

Yes, if you are an operator: registration in the EU information system is the first step before you submit a due diligence statement and receive its reference number; registration alone produces no number. Micro and small primary operators for their simplified declaration, authorised representatives, and downstream operators and traders that are not SMEs (Article 5(2)) must register as well. Downstream operators and traders that are SMEs do not have to register.

How do I ask my supplier for the reference number?

In writing, per delivery item, and with a question about the supplier's role: only an operator passes on a reference number; a downstream operator or trader instead confirms its role and its company details. A text module is in the section “Requesting the reference number from your supplier” and in the cheat sheet.

How do I verify my supplier's reference number?

In the EU information system via the verification function “Verification”: enter the reference number and the verification number, and the system answers with valid, not valid or not found; for many numbers there is a bulk check by CSV file (Commission FAQ 7.25). The result only proves that an available statement exists, not its content and not that the goods are deforestation-free. The steps are in the section “Verify a supplier's reference number in TRACES”.

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, revised on 21 August 2026, questions 2.3, 2.9, 2.13, 3.4, 3.5, 3.8, 3.15, 3.16, 3.19, 5.6.1, 5.8, 7.24 to 7.26 and 9.1 to 9.3. Commission guidelines, OJ C/2026/3896. Delegated Regulation (EU) 2026/2102, Annex I note 5. Union Customs Code (Regulation (EU) No 952/2013), Article 18. 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. EUDR customer notices from DHL Express, UPS and FedEx, retrieved on 12 October 2026. This article describes the legal position as at September 2026 and does not replace legal advice.