EUDR at the Border: The Customs Codes, DDS Reference Numbers, and Declaration Fields That Clear Your Shipment

Your due diligence statement is filed. Your geolocation data is clean. Your risk assessment is documented and defensible. And your container is still sitting at the port, because the customs declaration carried the wrong document code.

EUDR compliance has two halves. The first - collect supplier data, assess risk, file a due diligence statement (DDS) - is where almost all the attention goes. The second half happens in the customs declaration, where that DDS has to be produced: right code, right field, right party, right shipment. From 30 December 2026, the second half is what actually determines whether goods move.

This post covers the second half. If you still need the first, start with our walkthrough on filing a due diligence statement in TRACES NT.

Customs is a chokepoint, not a checkpoint

The distinction matters. A checkpoint inspects a sample. A chokepoint stops everything that does not have the right paperwork.

Under the EUDR, goods that require a due diligence statement cannot be released into free circulation without the declarant providing the DDS reference in the customs declaration. Customs authorities are the operational layer that makes the regulation bite at the border - the competent authority runs the substantive checks, but customs controls the release.

One nuance that saves a lot of panic: not every customs procedure triggers the requirement immediately. Finnish Customs, for example, states that goods covered by the Regulation can be placed under customs warehousing, inward processing or transit without a due diligence statement - but that when those products are released into free circulation from warehousing, inward processing or transit, the required information must be included in the customs declaration (Finnish Customs). The obligation follows the release, not the arrival.

The two numbers people confuse

When you submit a DDS in the EUDR Information System, you get back identifiers. Two of them matter downstream and they are routinely mixed up.

The reference number identifies the due diligence statement itself. This is the number that goes into your customs declaration. You obtain it from the Commission's EUDR Information System after submitting the statement, and you need an EU Login account to get there (Finnish Customs).

The verification number is the companion value used to confirm that a given reference number genuinely belongs to the party quoting it. Its practical function is downstream: when you pass a DDS reference to a customer, the pair lets them confirm the statement is real and is yours, rather than a number typed into an email.

The operational rule of thumb: the reference number is what customs wants; the reference and verification number together are what your customer wants. If you only collect reference numbers from your suppliers, you have collected strings you cannot validate.

The document codes that do the work

The EUDR did not create a new customs message format. It reused existing data elements - the declaration fields you already have - and populated them with new codes. Finnish Customs is explicit on this point: the Regulation "does not bring changes to message descriptions," and condition codes and DDS reference numbers are provided using existing data elements (Finnish Customs).

The codes fall into two families.

Document codes, which say "a due diligence statement exists and here is its number":

Code	What it declares
C716	Due diligence statement to be presented upon import or export under Article 3 of Regulation (EU) 2023/1115. Enter the DDS reference number with this code.
C717	Reference number of a previous due diligence statement under Article 4(8) - used when the statement was provided earlier in the supply chain.

Exception codes (the "Y" series), which say "no due diligence statement is required here, and this is why":

Code	What it declares
Y132	Products manufactured before 29 June 2023.
Y133	Exception under the second explanatory note to Annex I - goods made from material that has completed its lifecycle.
Y141	Exception for operators under Article 38(3) - the transitional arrangement for micro and small enterprises.
Y142	Exception concerning non-commercial activity, under Article 2(15), (17) or (18).

Codes as listed by Finnish Customs. The same condition codes are usable in both import and export declarations.

Two practical points that are easy to miss. First, several due diligence statements can be included in a single customs declaration, and a single DDS can be used across several customs declarations. Second, the C717 code exists precisely for the downstream case - if you are relying on a statement filed upstream rather than filing your own, C717 is the field, not C716. Getting that wrong misrepresents your role in the supply chain on an official declaration.

A caution on dates. Guidance published by national customs authorities before the December 2025 amendment quotes the original timetable - Finnish Customs' page, for instance, refers to effect from 30 December 2025 and a transition period for small businesses until 29 June 2026. Those dates were superseded by the twelve-month postponement. The codes and mechanics still stand; the dates do not. The current position is that the Regulation applies from 30 December 2026 for large and medium-sized operators and traders, and for micro and small operators already covered by the EU Timber Regulation, and from 30 June 2027 for other micro and small operators (European Commission). Before you rely on any Y-code expiry date you read online, confirm it against your national customs authority's current TARIC guidance.

Automatic checking is not switched on yet - and that cuts both ways

Here is the detail most compliance teams have not internalised. At launch, the customs system does not validate your DDS reference number against the EUDR Information System in real time. The declarant declares possession of a valid statement; the systems do not necessarily talk to each other yet.

Finnish Customs puts a date on the transition: the intended latest date for introducing automatic checking of DDS reference numbers is 30 June 2028, after which the Customs Clearance System interfaces with the EUDR system to check that the declared information matches (Finnish Customs). Timelines for automated checking are set nationally, so confirm the position with your own authority.

Do not read this as a grace period. It means the opposite of what people assume:

• A typo will not be caught at the border. It will be caught later, in a competent-authority audit, across every declaration you filed with it.
• A reference number that does not correspond to the goods declared is a false declaration, whether or not a machine noticed at the time.
• The absence of an automated check makes your own internal reconciliation the only control. Nobody else is checking your work.

The operators who will struggle in 2028 are the ones who spend 2027 assuming that "it cleared customs" means "it was correct."

Commodity codes: HS, CN, TARIC, and why the mapping is not a one-off

Annex I of the EUDR expresses scope in Combined Nomenclature (CN) codes. Your broker works in TARIC codes, which extend the CN with EU-specific measures. Your supplier abroad probably quotes six-digit HS codes. Three vocabularies, one product.

Most scope errors trace back to this seam. A supplier's HS-6 code maps to several CN-8 codes, only some of which are in Annex I. A product that is out of scope at HS-6 can be in scope at CN-8, and vice versa.

And the mapping moves. On 13 July 2026 the Commission adopted a Delegated Act updating Annex I. It removes cattle hides, skins and leather, re-treaded tyres, soybeans for sowing, articles of vulcanised rubber, conveyor and transmission belts, and aircraft and motor vehicle seats from scope, while adding soluble coffee, certain palm oil derivatives and frozen cattle tongues (European Commission).

Two timing points with direct customs consequences:

• The newly added products become subject to the Regulation from 30 December 2027, not from the general application date - the Commission built in extra preparation time for them (European Commission). Your code mapping therefore has two switch-on dates, not one.
• The Delegated Act goes to the European Parliament and the Council for scrutiny before entering into force (European Commission).

We covered the substance of the Annex I changes in detail in our post on the 13 July 2026 delegated act. The customs takeaway is narrower: treat your CN-to-TARIC scope mapping as a maintained dataset with a review owner and a review cadence, not as a spreadsheet somebody built once in 2025.

Exports and re-exports

The EUDR covers products exported from the EU as well as placed on it, so export declarations carry the same code logic - the same condition codes are usable in both directions.

The case that catches people is export by a downstream operator. Downstream operators have materially lighter obligations than first operators, and the declaration machinery reflects that: rather than filing a fresh statement, the downstream position rests on referencing the statement filed upstream. In declaration terms, that is the C717 route rather than C716. If your organisation exports goods it did not itself first place on the market, confirm with your broker which code your specific fact pattern requires - and see our guide on what downstream operators actually have to do.

The failure modes that actually stop shipments

Failure	What causes it	Mitigation
Quantity mismatch	DDS covers a volume different from the declared consignment	Reconcile DDS quantity to commercial invoice before the declaration is lodged, not after
Wrong legal entity	DDS filed by a group parent, declaration lodged by a subsidiary EORI	Map EORI numbers to EUDR operator registrations once, centrally, and freeze the mapping
C716 used where C717 applies	Team assumes it must file its own statement when relying on an upstream one	Classify each flow by role - first operator, trader, downstream operator - before go-live
Reference number arrives late	DDS filed after goods are already in transit	Move DDS filing upstream of shipment booking, not upstream of arrival
Scope error at CN-8	Mapping built from supplier HS-6 codes	Rebuild the mapping from your own CN-8 tariff data and re-run it after each Annex I change
Information System unavailable	Outage during a filing window	Know your national authority's contingency route and keep evidence of attempted filing

The operator-to-broker handoff

Most border problems are not compliance failures. They are handoff failures. A short protocol prevents almost all of them:

1. Before booking. Confirm the CN-8 code and whether it is in scope, including which of the two switch-on dates applies.
2. Before shipment. File the DDS. Capture the reference number and verification number in the shipment record, not in an inbox.
3. To the broker. Send the reference number, the code to use (C716 or C717), the CN-8 code, and the quantity the DDS covers. Four fields.
4. From the broker. Get back confirmation of what was actually entered on the declaration, and keep it.
5. After release. Reconcile declared quantity against DDS quantity. Monthly, at minimum, for as long as automatic checking is not live.
6. Retain. The declaration, the DDS, and the underlying evidence, per our guidance on EUDR record-keeping and audit readiness.

What to do this quarter

If you import or export in-scope goods, the border work is a distinct workstream from the due diligence work, and it has a different owner - usually customs or logistics rather than sustainability. Give it a name, an owner, and a test.

The single most valuable thing you can do before December is a dry run: pick one real flow, file a real DDS in the reopened Information System, hand the reference to your broker, and lodge a test declaration. The Commission reopened the Information System at the end of June and has been running training sessions for companies since the end of July (European Commission). The gap between "we understand the codes" and "the code was accepted on our declaration" is where December will be won or lost.

Because when the chokepoint closes, it does not ask why.