If you’re navigating EU Deforestation Regulation (EUDR) compliance, you’ve likely encountered the EU’s Information System - TRACES - and perhaps felt confused about what it is actually for. One of the most common misunderstandings we see is around the Due Diligence Statement (DDS) Reference Number and Verification Number. These two identifiers are often assumed to unlock a full picture of the supply chain, but that’s not the case.
This article clarifies exactly what information TRACES provides when you have a Reference Number and its corresponding Verification Number - and, just as importantly, what it doesn’t. Whether you're a downstream Trader trying to make sense of your Supplier's DDS or are using a platform like Interu which is fully integrated with TRACES, understanding these limitations is critical for building a compliant and efficient EUDR process.
But first, what is the TRACES DDS Verification Number?
When an Operator / Trader submits a DDS to TRACES and it is ‘approved’, a Reference Number and separate Verification Number are returned to the Operator / Trader.
Note: All this ‘approval’ indicates is that there has been an automated check for the presence of key data. There are no in-depth checks on the information provided at this point.
The Reference Number for upstream shipments plays a number of roles depending on the size of the downstream Operator / Trader - we urge you to refer to the recent scenarios published by the EU.
It can be referenced in downstream DDS to link products throughout a supply chain, and Operators / Traders (depending on their size) are obliged to store the Reference Number (and corresponding Verification Number) in their records for 5+ years, and pass onto downstream buyers (unless they are a downstream SME Trader, in which case their obligation is to keep a record of the Reference Numbers).
Each Reference Number is paired with a unique Verification Number. The Verification Number confirms that the Reference Number is valid, (i.e., authentically produced by TRACES), providing reassurances on record integrity. The Verification Number without the Reference Number and vice versa is meaningless. Therefore, when storing and passing on Reference Numbers, the corresponding Verification Number should be stored and passed on with it.
This is critical for organisations managing integration with TRACES directly, or integrating with 3rd party systems like Interu to link DDS Reference Numbers and Verification Numbers with PO (Purchase Orders) and other internal records. As seen in Interu below:
We perceive there to be a significant over-estimation of what the Verified Reference Number will actually do for downstream Operators / Trader, and how the information can be accessed.
What information will the Reference Number & corresponding Verification Numbers expose for downstream Operators / Traders?
When you receive a suppliers’ DDS (or multiple DDS) and look them up on TRACES, the only information you will see is:
- The name of your supplier
- The product HS Code
- The product description (given by the supplier)
- The name of the place of production
- Reference Numbers and Verification Numbers of any further upstream DDS records
And if your supplier has opted into sharing the geolocation coordinates with buyers, then you will also see a list of geocoordinates associated with the points of harvest.
Presently in TRACES there is no download or export button relating to this information, so users will have to manually copy and paste it into their own records.
TRACES itself, using the Reference Number and Verification Number, will not provide you with the following information:
- Names of suppliers beyond your Tier 1 supplier*
- Due diligence information
- Certification status of goods
*Even if a Tier 1 supplier’s Reference Number and Verification Number links back to upstream DDS records (i.e., to your Tier 2+ supplier’s DDS), you will need to manually look up the Tier 2+ records. The information in them will not present itself as part of the Tier 1 supplier records.
What about the TRACES API?
Those of you following the EUDR multi stakeholder meetings will be aware of the regular updates to TRACES and heard about the TRACES API.
The TRACES API is a way of organisations creating a connection between their system and TRACES to exchange information. In the case of Interu, we facilitate the creation of the DDS and submission to TRACES directly from Interu, so users do not need to log into TRACES to submit DDS or obtain the Reference Number and Verification Number.
As a reminder, TRACES has not been designed to facilitate record keeping, end to end traceability or due diligence. It is a system for Competent Authorities to capture declarations of negligible risk of deforestation in supply chains, and for them to organise their enforcement efforts based on the geolocations reported.
It is important to remember Operators and Traders must establish and maintain a due diligence system that includes evidence demonstrating that no deforestation has occurred after the cut-off date. This means having access to verifiable supply chain documentation, geolocation data, and risk assessment outcomes - much of which is not captured or surfaced by TRACES alone. A compliant due diligence system must go beyond basic TRACES lookups to ensure legality and negligible risk, backed by concrete proof and proper recordkeeping.
Want to ensure your business is fully EUDR-ready beyond the basics of TRACES?
At Interu, we don’t just help you submit DDS and manage Reference and Verification Numbers, we provide the infrastructure for full traceability, record-keeping, and due diligence - all the way back to source.
Let’s talk about how we can help you go beyond TRACES and build a robust, audit-ready compliance process. Request a Demo or Contact Us today.
