These products are not in scope. For example shoes are under Chapter 64, not mentioned in Annex I, notebooks 8471, also not in scope. However, if you are a shoe manufacturer and you import leather (CN 4107) and then make shoes (Chapter 64), the import is in scope.  

Another example: If you buy leather (CN 4107) from the EU market and make shoes, you are not in scope (as there is no relevant import, and the product that you transfer ownership are shoes, therefore not in scope). 

The important date is the date of import into the EU. If cocoa was imported before December 30, 2025, it is not in scope, and you only need to provide evidence of the import date. However, cocoa produced before December 30, 2025, and imported after December 30, 2025, would fall under scope.

If the supplier is based in the EU: You only need to verify the DDS reference number in the time between purchase and delivery of the book.  

If the supplier is based outside of the EU: It’s more complicated. It depends on who is importer (if the consumer is the importer, then it is not in scope).  

Also, if you are a marketplace and the purchase contract is ultimately between the supplier and the customer, then you would also be out of scope.  

See above. A possible solution: Make delivery subject to EUDR compliance (contractually). Relevant EUDR data can be requested and checked automatically every time an order is placed or a confirmation document is received from the supplier. 

The SME should have a reference number, which you need for export. But you also need to submit your own DDS by referencing the previous DDS. If the goods were imported before December 30, 2025, you only need confirmation from SME that goods were imported before December 30, 2025. Upon export, you can use a reference number specifically set up for this purpose. 

No, only companies with an EORI number can use TRACES. Third country exporters can theoretically task an EU-based representative with the submission of a DDS, but the first EU company that then receives the goods will be considered the operator. Plus: the importer of record is always the operator.

EU suppliers need to provide Due Diligence Statements. If you’re placing beef from your own production on the market for the first time, you may also need to collect and assess your own geolocation data. osapiens HUB for EUDR allows you to collect, upload and run the risk assessment, and then combine batches (from different sources) to submit an accurate DDS with all included references (geolocation data and collected reference numbers).

Covered in the webinar. Purchases for own consumption are not relevant.

If included in the Annex I, SME operators must submit DDSs and share them with their customers if they place the paper products on the EU market.