We recently returned as guest speakers for the Department for Business, Innovation, Science and Trade (BIST) Business Academy webinar on the EU Deforestation Regulation. Our Head of Market Development, Anna Roberts, explained what EUDR means for UK businesses, who it affects, and the practical steps needed to prepare for compliance, along with what similar UK legislation could mean further down the line.
Thank you to BIST for inviting us back, and to everyone who joined on the day and sent through such thoughtful questions - some of which we have pulled out below.
Product Scope Questions
Q1: If the product is made of wood/bamboo in the UK and is shipped to a company for promotional use only of no commercial value, does the IOR still need to provide a Due Diligence Statement prior to delivery in the EU?
A:.Bamboo products are entirely out of scope of EUDR. The Commission's Delegated Act (adopted 13 July 2026) confirms that wood products made entirely from bamboo, rattan, reeds, rushes, osier, raffia, straw or lime bark sit outside Annex I altogether. Therefore no DDS is needed.
For wood-based products which are in scope of EUDR, there are two scenarios:
- If the product is a sample, ‘of negligible value and quantity’, and sent only to solicit orders or for testing, it is exempt from EUDR. There will be a specific TARIC code to include on customs documentation to indicate that the products being imported are exempt.
- If the product is supplied as promotional material in its own right (e.g., point of sale display stands), then it is in scope of EUDR. In this case, the company placing the goods on the market needs to submit a DDS and include the reference numbers on import documentation.
Q2: Could wallpaper samples be excluded? We do charge a nominal fee for each A4 size sample - used to generate sales of the full product.
A: The relevant exemption (FAQ 2.14, now confirmed in the July 2026 delegated act) covers samples of negligible value and quantity, used only to solicit orders, where the presentation and quantity rule out any use beyond seeking orders. That's a reasonably good fit for the scenario you're describing.
It is unclear what the threshold is for ‘negligible value’ and whether your ‘nominal fee’ would be classified as negligible. Our advice is to formally raise a question to the relevant EU Competent Authority in the countries you send the samples to.
Q3: Does the EUDR impact wooden pallets?
A: Wooden pallets are listed in Annex I (CN code 4415), so they are fully in scope of EUDR.
However, there are two exceptions which are really important:
- Pallets used exclusively to support, protect or carry another product are excluded, whether they're new, used, or part of a closed-loop pool. This covers the vast majority of pallet use in practice and means that only new wooden pallets shipped as standalone items, not carrying any products, are in scope.
- Re-used or second hand wooden pallets are exempt from EUDR. Only new pallets (and parts of pallets repaired with new wood which has not previously been placed on the EU market) need to comply.
[Ref: FAQ 2.5 & 2.6]
Q4: Do leased products count? As in if a UK company leases products that include materials in the regulation to companies in the EU?
A: FAQ 2.15 answers this question directly.
“If a relevant product is rented out, or provided under a similar contractual arrangement, the product is not considered to be placed or made available on the market. A supply under the EUDR presupposes an agreement (written or verbal) between two or more legal or natural persons for the transfer of ownership or any other property right concerning the product in Question.” Therefore leasing products within the EU does not fall under EUDR obligations.
However, “any product released for free circulation on the EU market, including where rented out, is considered as being placed on the market and is thus subject to the Regulation.” Implying that the supply into the EU by the UK business would fall in scope when it is release for free circulation, even if the goods are being leased by EU companies.
Timelines & Re-Imported Goods Questions
Q5: What is the timeline for documentation completion before goods are despatched?
A: There isn't a fixed number of days set out in the regulation. The requirement is that a valid DDS reference number must be in place before the goods are placed on, or made available on, the EU market, which in practice means before the customs declaration is lodged. In practice, this means documentation needs to be complete before despatch, not just before arrival, since a shipment without it risks being held up in customs.
The timings of when the Operator needs the documentation need to be agreed between buyers and sellers considering lead order times and fulfillment times.
For businesses who have very short lead times and stable supply chains, it could be beneficial to rely on a ‘predictive DDS mechanism’ whereby the Operator creates a DDS to cover multiple shipments (with identical supply chains), applying the reference numbers over any number of deliveries up to a maximum of a 12 month period.
For more information please refer to our blog post on the topic.
Q6a: How will the conventional reference number be audited for compliance in the case of reimporting goods (e.g. paper made out of woodpulp sourced on the EU market) - and is there likely to be a new TARIC code?
Q6b: I have been asked for a conventional re-import and transition due diligence reference number by our customer who is a downstream operator but am struggling to understand this.
A: Conventional DDS reference numbers exist to allow for the re-importing of products which have previously been placed on the EU market.
We are currently in the EUDR transition period which runs from 30/06/2023 to 30/12/2026.
- For products harvested or placed on the EU market before the transition period, rather than using a conventional reference when products are re-imported, re-importers should use TARIC code Y132 on customs documents.
- For products harvested or placed on the EU market during the transition period, and re-imported after 30/12/2026, the conventional reference number to use on customs documentation is 99EU999999999999.
After the transition period, (from 30/12/2026) to re-import goods which have already been placed on the EU market after 30/12/2026, a different, yet to be published conventional reference number should be used. We expect to see this published by the European Commission in September 2026.
In all scenarios, expect competent authorities to audit transactions which rely on the use of the conventional reference numbers. They will expect the re-importer to be able to evidence that the goods had previously been placed in the EU. Documentation like upstream export declarations, contracts, bills of lading, invoices, etc. are listed in FAQ 5.4 as examples of evidence.
Q7a: We are a UK supplier to businesses who put products onto the EU market. We obtain some products from the EU and some from outside of the EU, so will have DDS refs for some, and our own data for others.
A: Let’s say the product is a door, which has component parts X & Y which have already been placed on the EU market, then exported to the UK where they are combined with component part Z to make the finished (in-scope) door product, which is then shipped into the EU.
In this scenario, component parts X& Y are re-imported by your EU customers, and component parts Z are imported for the first time by your EU customer.
You will need to supply product information to your customer covering all component parts:
- For components X & Y you will need to share either the upstream DDS references associated with the parts or, (more likely), evidence that those parts had previously been placed on the EU market (e.g., invoices, export declarations, packing lists, bills of lading, etc.). Your EU customer can include upstream references on the import declaration as ‘additional information’.
- For component Z you will need to share full traceability information back to source for your EU customer to conduct due diligence on. This includes legality information, geolocations, harvest dates, species, and the chain of custody back to source. Your EU customer will need to specify the geolocations of component Z to the DDS which they submit to TRACES, even though the DDS itself will list the door’s HS codes and product description.
Unfortunately we have received slightly different guidance information from different National Competent Authorities about how to handle the volume element of this scenario. The Swedish and German NCA, for instance, suggests that the volume declared on the DDS should be for component Z, whereas the Belgium NCA suggests that the volume should be for the full door product.
In both cases, if an audit or check is performed by a Competent Authority, the DDS should be presented together with evidence proving that components X & Y have previously been subject to due diligence.
Q7b: How do we pass this information to our customers, and often the information changes (e.g., how to handle geolocation changes when new harvest plots are used, how often to audit ethical considerations, etc)
In terms of how you pass this information to your customers, TRACES is not designed to do that. It’s a system for enforcement to use, not for buyers and sellers to check or share information.
Either you can rely on existing communication methods with your suppliers (often emails, shared drives, etc.). Or a digital platform like Interu which aims to streamline information exchange and improve data quality and structure in order for the buyer and the seller to save time.
A DDS can be submitted to cover products of a specified volume with a given supply chain for up to a maximum of 12 months. That means you could create 1 DDS to cover products delivered over multiple shipments.
As soon as there is a change to the supply chain - a new tier ‘n’ supplier, new harvest dates or geolocations - a new DDS is required.
Q8: What happens if a first downstream operator buys goods after 2027 but the upstream purchases the goods before 2027?
A: The trigger for EUDR obligations is when a product is first placed on, or made available on, the EU market.
If the upstream operator is based in the EU and placed the goods on the EU market before 30/12/2026, and does not sell them onto the first downstream operator until 2027, the goods will already be in the EU in 2027 and will not need to comply with EUDR (since they have already been placed on the EU market).
However, if the upstream supplier is not based in the EU, and the goods (or their raw material components) have never previously been placed on the EU market, then the first company placing the goods in the EU in 2027 will be the Upstream Operator, and will need to ensure they fully comply with EUDR. The only exception to this is if the EU Upstream Operator is an SME not subject to EUTR, in which case there is an extended implementation period to 30/06/2027.
TRACES Questions
Q9: As a Non-EU Operator, I have tried to sign up to TRACES using our EU EORI number but it says the role is being reviewed and I now need to 'contact the administrator in my organisation or responsible authority in order to be validated' - who is the administrator and responsible authority? (We are the business placing products on the EU Market)
A: Recent updates to TRACES have been made to accommodate new roles (MSPO - Micro / Small Primary Producers) and revisions to roles and obligations (for instance, the ‘Trader’ role). So it could be that the role of your organisation might need to be revised.
This sounds like your company already has a TRACES account (which you, as an individual, need to be linked to). The administrator / responsible authority is likely to be the person in your organisation who set up your company’s TRACES account.
There is a TRACES helpdesk that you could ask for guidance on this if you’re unable to get to the bottom of it.
If your company does not already have a TRACES account, then it could be that your company accounts is pending validation. In which case, you should email SANTE support requesting validation, copying in the National Competent Authority of the country of your organisation’s EU (/XI) EORI.
Q10: Is there a charge for use of TRACES?
A: No. TRACES (and the EUDR module within it) is free to use. You'll need a Login account and an EORI number to register, but there's no fee to register on the platform or to submit DDS.
Q11: If the incoterm means that we are not the importer of the goods, do we still need to submit on TRACES as the non-EU operator, or is it only if the incoterm deems us the operator placing the goods on the market?
A: It comes down to who is first placing the goods on the EU market, and incoterms are often the practical way that's determined, since they set out who holds risk and responsibility for the goods at each stage of the journey.
If your incoterm means you are not the importer placing goods on the market, then you do not need to submit a DDS to TRACES. You would be classified as a non-EU supplier, rather than a non-EU operator.
The company placing the goods on the EU market has the obligation to conduct due diligence and submit a DDS to TRACES, so they will rely on you (the supplier) to share information (with them, the customer and EU Operator).
General Questions
Q12: Is there a specified format in which geolocation information must be supplied?
A: There is a specific format required by TRACES when you submit a DDS. It only accepts GeoJSON format, capped at 25MB, so very large or numerous polygons may need splitting up across statements. Coordinates need to use the WGS84 system.
If you manually input coordinates into TRACES, they need to be latitude and longitude in decimal degrees, to at least six decimal places.
Plots of 4 hectares or less can be submitted as a single point. Plots over 4 hectares must be in polygon format, with a complete boundary, at least four non-aligned points and no self-intersecting lines.
Your suppliers may provide you with geolocation information in a variety of different formats (UTM, decimal degrees, degrees / minutes / seconds, etc.) and in geojson files, spreadsheets and PDFs, etc.
It is definitely worth giving yourself time to test out the geocoordinate information you receive from your suppliers well in advance of EUDR deadlines. We’re seeing very large data sets, often with duplicate or incomplete information which TRACES will reject. This is something a system like Interu can help save you time with.
Q13: What happens with EUDR goods landing in the UK and then being moved to NI? Is EUDR going to be applicable in NI?
UK DEFRA recently confirmed that Northern Ireland will be fully in scope of EUDR from 30/12/2026.
Therefore goods will need to comply with EUDR fully when being moved to NI from GB.
EUDR raises a lot of these grey-area questions in practice, and getting them wrong can hold up shipments or trigger penalties. If you're working through your own compliance requirements and want a second opinion, or you'd like to see how Interu helps businesses manage due diligence statements, geolocation data and supplier risk in one place, get in touch with our team. We're always happy to talk through your specific situation.
