EUDR TRACES NT updates: What's Changed and What It Means for You - Q&A

Recently we hosted the latest instalment of our EUDR Lunchtime Series, with Anna Roberts, Head of Market Development, and David Coleman, Chief Product and Technology Officer, walking through the recent Implementing Act and what it means for TRACES NT. If you missed the session, here's a round-up of the questions attendees asked us, live.

The conversation covered some of the trickiest parts of EUDR in practice: how Authorised Representatives work, EORI numbers for non-EU exporters, handling mixed EU and non-EU raw materials in TRACES, and the practicalities of the 3-day SLA for reference numbers. We've grouped the questions below, with our answers as given on the day.

Non-EU to EU supply chains:

1. If we are using a third party to help with Due Diligence, (we are a non-EU operator and have a sister EU-based company) do we use the third party or sister company as our Authorised Representative?

There are a few things to be aware of when it comes to Authorised Representatives (AR) for EUDR: 

1. The AR must be an EU entity, and can act on behalf of companies with their own TRACES accounts already. If you do not have a TRACES account, the AR cannot submit DDS on your behalf.
2. Your sister company AND the 3rd party could both operate as your AR depending on point 1 above and your preferences. You are not limited to having one AR. 
3. An EU Operator cannot ‘outsource’ due diligence to a 3rd party entirely. If investigated by a Competent Authority, the EU Operator will be expected to describe how they came to the conclusions they did, what their methodology is, how their due diligence system works. They cannot outsource this entirely to a 3rd party platform or due diligence provider. Any non-compliance (i.e., if the due diligence was found to be lacking), will result in the EU Operator, and not the 3rd party, being held liable. The AR role is purely an administrative one to help companies who might not have the resources to submit DDS based on the volume of goods they clear into the EU.

In answer to your question, it would be your sister company (in the EU) who is more likely to rely on the AR when they import.

2. FAQ 3.7 states that Non EU Companies will need to access Traces and produce a DDS if exporting into the EU free circulation. Our understanding is that only Non EU companies that have an XI EORI number can produce a DDS. What happens for the rest of the world who can't get an XI EORI number ?

The requirement to submit a DDS rests with the company first placing the goods on the EU market. Often this is the ‘Importer of Record’ on customs declarations. 

We understand that non-EU companies can have EORIs from a range of different EU member states and are not limited to an XI (Northern Irish) EORI. The XI EORI is suggested for UK companies who are operating in Northern Ireland in particular. 

Non-EU businesses can apply for EORI numbers if they act as the importer of record or files customs declarations directly within the European Union. Typically the non-EU business would register for an EORI in the member state where it first clears goods into the EU. E.g., an American business clearing goods into Germany can apply for a German EORI. 

The European Commission has a good resource on this topic available here. 

3. A non-EU supplier buys pulp from the EU, then produces paper rolls and sells them back to the EU with a reference and verification number. The EU importer receives these numbers instead of GeoJSON files. How should the importer handle this in TRACES, and where should these numbers be entered?

Good question. In this case the re-importer does not need to submit a DDS into TRACES or conduct due diligence. Instead, on the customs declaration, they use a 'conventional reference number' (yet to be announced). This is permitted so long as the paper is only produced with EU pulp, and non mixed with non-EU pulp (in which case the non-EU pulp will need a new DDS). The re-importer will need adequate evidence that the goods had previously been placed on the EU market (e.g., export declarations, waybills, packing lists, contracts detailing the export of the pulp from the EU to the non-EU supplier). 

4. In case we have a mix of reference number/verification number and GeoJSON files, should we submit in TRACES only the GeoJSON files? 

In this second scenario, where the paper is produced with a mix of pulp from EU and non-EU suppliers, the non-EU components of the paper need a DDS submitted for them, and full due diligence on the raw material inputs back to forest origin. The EU pulp is already covered by upstream DDS (or, if produced during the transition period, there won’t be a DDS). 

So what do you include in TRACES? The TRACES submission only needs to cover the non-EU components. In which case, you would upload the geojson files, and will need to include information about the product HS codes (of the paper, since that’s the product being re-imported), the species (of the non-EU pulp), the geocoordinates (of the non-EU pulp) and the volume (of the non-EU pulp). This means that there will be a volume discrepancy between the volume of the paper imported into the EU, and the volume of the pulp declared in TRACES. 

The reference number of the non-EU pulp components should be included on customs declarations, and it is advisable to note the re-imported ‘conventional reference number’ as well, to indicate that part of the product has previously been placed on the EU market.

5. When a producer exports goods to the EU, is the importer responsible for uploading the required information to the TRACES system?

The obligation to produce a DDS into TRACES rests on the company first placing the goods on the EU market. The definition of this per Article 2 (18) implies that:

1. The relevant product must be physically in the EU market, having either been harvested or produced in the EU, or imported and released ‘for free circulation’... and…
2. It needs to be in a commercial context (which can include when goods are exchanged for free, but not when they are for personal or private consumption)

Therefore it is important to determine whether this is the producer who is exporting goods, or the importer (customer). Inco terms often play a big role here. 

In some situations, a non-EU producer will place the goods on the EU market. In this case, they have the obligations of a ‘non-EU Operator’ and there are two Upstream Operators - the non-EU company, and their customer, the EU business. In this case, both companies have to submit a DDS to TRACES and will be held responsible for conducting due diligence back to source. This is because there must always be an EU-based Operator. 

6. I'm not sure how a Non EU company can import into the EU, thought that was export. Perhaps I need to know more about customs procedures!

Customs procedures are indeed a very important part of determining EUDR responsibilities. We are scheduling a short webinar on this topic because it is quite specific and has implications for businesses facing EUDR, particularly non-EU companies. 

Timings:

7. When should we expect TARIC code and standard reference numbers to be published?

We understand that the European Commission is aiming to publish these in September. We will monitor this closely and provide our own guidance relating to revised and new coding shortly afterwards.

8. Is the training platform available again? 

Yes, the live and acceptance (training) platforms of TRACES went live on 29th June 2026. The European Commission is conducting training over the course of the summer on how to use it. You can register here, and the same URL has links to training materials. 

9. Given the 3 day SLA, does that mean that RORO shipments from UK to ROI will be delayed by 3 day ?

The 3 day SLA, or longer with exceptional circumstances, could indeed imply a delay between submitting a DDS and receiving the reference numbers in return, which will be needed for import into the Republic of Ireland.  

A number of our customers are managing the risk of this delay disrupting their own ability to ship quickly by using a mechanism we refer to as a ‘predictive DDS’. It is described in a number of FAQs and the European Commission itself encourages people to use it to lighten the load on TRACES. 

A predictive DDS can be created for a known supply chain, with a know product and harvest date, covering a specific volume (a ‘balance’). The associated reference and verification numbers from the predictive DDS can be useful for multiple transactions being shipped into the EU, rather than having to submit a new DDS each time, up to the ‘balance’ of volume. 

There are some conditions to using this mechanism:

• The DDS can only be used for up to 12 months, after which a new DDS is required.
• As soon as there are any changes to the products or supply chain (e.g., different species, harvest dates, suppliers, geolocations), a new DDS must be created. 
• The DDS can only be used to cover up to the balance of the volume. E.g., you create a DDS covering 10,000KG of goods and cannot use the DDS to import more than 10,000KG of goods.

We have experienced a delay of 2-3 minutes from submission to receiving references, so the 72 limit is hopefully an exception, not the norm.

10. Do you think EUDR will be delayed once again?

We have not had any indications about the EUDR being delayed again. So far they have met their own deadlines in terms of publishing updates and re-opening TRACES.

These questions are a good reminder that EUDR compliance rarely comes down to a single rule. It usually hinges on the detail of your supply chain, your customs procedures and how your business sits within it.

If any of this raised questions of your own, or you'd like to talk through what it means for your operations, get in touch with our team. We're always happy to help you work through the specifics.