From 30 December 2026, things will become concrete for many companies: Anyone importing or exporting EUDR-relevant goods must provide evidence of this in the customs declaration. The point where EUDR and customs meet is TARIC. The commodity code is used to determine whether a product is covered by the regulation at all. A TARIC document code indicates whether a Due Diligence Statement (DDS) exists or why one is not required. Since the revision of 23 September 2026, there are 15 codes, including new ones for re-imports, exports by downstream operators, and transitional goods.
This affects all companies dealing with EUDR-relevant products, whether cocoa, coffee, rubber, soy or palm oil. However, the questions arise particularly frequently in the wood and paper industries. Product variety is extensive in these sectors, and customs classification is often highly detailed. That is why we use examples from these areas throughout this article.
Would you first like to understand the basics of the EUDR? Here you can find our EUDR overview.
HS, CN, TARIC: Three Levels of One Number
In everyday use, people often simply refer to the “HS code.” However, this actually refers to different levels of the same customs tariff number. Using a wooden clothes hanger, 4421 10 00 00 0, as an example, the structure looks like this:
Important in practice: For imports, the 10-digit TARIC code is declared; for exports, the 8-digit CN code is used. The Commission has therefore created two separate TARIC measures: 776 for import controls and 777 for export controls. Companies that maintain their master data only at 10-digit level also need an 8-digit view for exports.
Two of these levels are important for the EUDR. Annex I of the EUDR identifies the covered goods using their HS or CN headings. In the customs declaration, TARIC then indicates which document code must be entered for the goods. The applicable codes for a specific commodity code can be found in the Electronic Customs Tariff (EZT).
The commodity code tells you what the goods are. The document code (e.g. C716) is a TARIC document code, referred to as Unterlagencodierung in ATLAS. It is entered additionally in the documents section of the customs declaration, usually together with a reference number — in the case of C716, the reference number of the DDS.
Commodity Codes and the DDS Requirement
The first step is always to determine whether the commodity code is listed in Annex I. However, this does not automatically mean that a DDS must be submitted. There are three reasons for this:
- “ex” headings: Some headings in Annex I are only partially covered. In these cases, it is the specific goods that determine whether they are covered, not the code itself.
- Exceptions despite a relevant commodity code: These include, for example, goods made from recycled material. Since September 2026, Annex I also explicitly clarifies that, among other things, waste, used goods, samples, and packaging and promotional materials are not covered. TARIC provides separate Y-codes for these cases (see table below).
- Your role within the company: Whether you submit a DDS depends on whether you are an operator, meaning that you are the first to place the goods on the EU market or export them, or whether you operate downstream. Downstream operators and traders do not submit a DDS. They collect and store information about suppliers and customers, including reference numbers (Article 5). Non-SMEs must also register in the Information System. There are separate codes for re-imports and exports. More on the different roles
The reverse is also true: What is referred to as “MDF,” “cardboard” or “accessories” in purchasing may be classified very differently for customs purposes. A wood-based panel (Chapter 44), a furniture component and a finished piece of furniture (Chapter 94) are classified differently, and this determines whether and under which heading the EUDR applies.
The commodity code, product description and actual product must correspond to one another. A reliable EUDR classification requires reliable customs classification. Companies that have not reviewed their master data for years should do so now.
Special Considerations for Paper and Pulp
- Pulp (Chapter 47) and paper and paperboard (Chapter 48) are generally covered, but since September 2026 they are listed as “ex” headings with clearly defined exceptions.
- Printed products (Chapter 49) were removed from Annex I in the December 2025 amendment.
- Waste paper and recycling: In Chapters 47 and 48, waste paper and other recovered products (waste and scrap), as well as products made from them, are not covered. This is indicated using Y133. By contrast, by-products of a processing operation in which material that was not waste was used are not exempt. The treatment of mixtures containing virgin fibre should be assessed on a case-by-case basis.
- Packaging: Packaging material that exclusively supports, protects or carries another product and is supplied together with that product is not covered (Y190). This applies to paper and paperboard (Chapter 48) as well as to the wood headings 4401, 4405, 4415 and 4416, including reusable packaging from the moment it is used for packaging. Packaging that is itself sold as a product is covered.
- Labels, promotional and informational material that merely accompanies a product are exempt where Annex I explicitly provides for this (Y191).
From the DDS to the Customs Declaration
The link between the EUDR and customs is the reference number. This is only generated once the operator has submitted its Due Diligence Statement in the EU Information System. The system then assigns it a reference number and an associated verification number. The reference number therefore cannot be applied for or “ordered.”
The chain is:
Commodity code → Scope check → Due diligence → DDS → Reference number → TARIC document code + reference number in the customs declaration
The reference number is entered in the customs declaration. This is done by the customs declarant, i.e. your freight forwarder or customs agent. They must provide it to the customs authorities before the goods are released for free circulation or before export (Article 26(4)).
Three points are important for customs clearance:
- Register in advance: Anyone required to submit a DDS needs access to the EU Information System before the first shipment arrives.
- Do not wait until the day of customs clearance for the reference number: Authorities may delay the provision of the reference number in order to check the declaration. The DDS should therefore be prepared between shipment and arrival of the goods, rather than on the day of customs clearance.
- Flexible combination: A customs declaration can contain several DDS references, and one DDS can be used for several customs declarations. What matters is that the allocation to the respective goods item is correct.
The EUDR Document Codes in the Customs Declaration
The reference number is entered in the documents section of the customs declaration together with a four-digit TARIC document code. With C716, the declarant confirms to the national customs authority that the required Due Diligence Statement is available.
The codes apply equally to imports and exports, with four exceptions: C720 and C725 apply to re-imports, while Y188 and Y196 apply to exports.
Special Cases for Exports and Re-Imports
- Transitional goods: If goods were first placed on the EU market between 30 June 2023 and the date of application, they may subsequently be exported or re-imported without their own DDS. In this case, C718 is entered together with the number 99EU9999999999. Evidence of the date on which the goods were placed on the market should be retained.
- Re-import without a reference number: If the re-importer has not received a reference number from its supplier, the Commission specifies the conventional number 22EU2222222222. This applies to re-imports (C720/C725), not to exports.
- Exports by downstream operators: A company that purchases goods in the EU and exports them without itself being an operator does not provide a reference number. Instead, it uses Y196 (non-SME) or Y188 (SME).
- Re-export of own imported goods: Anyone who re-exports goods that they themselves imported without modification remains an operator and provides the reference number of their DDS (C716).
Important: Do not simply use “C716” across all master data. The applicable code depends on the goods, your role and the size of your company. The code also does not replace due diligence. It only documents to customs that the due diligence requirement has been fulfilled or why it does not apply. If the appropriate code or reference number is missing and no exception applies, the goods may not be imported or exported following the customs check.
Which Code Applies? The Four-Question Decision Logic
- Is the commodity code listed in Annex I?
No → No EUDR information is required. - Are the specific goods actually covered?
No → Use the appropriate Y-code (Y129, Y133, Y187, Y190, Y191, Y132, Y142). - Are you a micro or small enterprise benefiting from the deferral until June 2027?
In that case, Y141 may apply until 29 June 2027, provided the goods are not already covered by the EU Timber Regulation. - What is your role?
- Operator with its own DDS → C716
- Micro or small primary operator with a simplified declaration → C717
- Downstream, re-import → C720 (non-SME) or C725 (SME)
- Downstream, export → Y196 (non-SME) or Y188 (SME)
- Does this involve transitional goods being exported or re-imported?
Then use C718 with 99EU9999999999.
Who Does What? Purchasing, EUDR and Customs Need to Connect
Much of the data required for the EUDR is already available: item number, product description, customs tariff number, supplier and country of origin. The main task is to connect this data.
The most important lever is to store the EUDR indicator in the product master data. This means that you do not have to determine the applicable code again for every shipment.
Checklist for Your Discussion with Your Customs Agent
- Which commodity codes do we use, and have they been checked against Annex I, including the changes from 2025 and 2026?
- How do we transmit the reference numbers: via an interface, ERP field or email? And how far in advance of customs clearance?
- How do we allocate multiple DDSs to a declaration containing multiple items?
- How do we handle exports, particularly transitional goods, re-imports and goods purchased within the EU?
- Should our customs agent submit the DDS on our behalf? This requires written authorization as a representative(Article 6). Responsibility remains with us.
Documentation: The Reference Number Alone Is Not Enough
The reference number only proves that a declaration has been submitted. In the event of an inspection, the entire chain must be traceable:
Goods → Commodity code → Supplier → Production plot → Evidence → Risk assessment → DDS → Reference number → TARIC code used → Customs declaration
Keep these documents for five years, in a way that allows you to retrieve them by shipment or item.
When Does It Apply?
- 30 December 2026: General rule for large and medium-sized companies. This also applies to all companies, including micro and small enterprises, for products that were already covered by the EU Timber Regulation (EUTR), as well as to downstream operators and traders.
- 30 June 2027: Micro and small enterprises that operate as operators and were already established as such on 31 December 2024, for all other products.
For most companies in the wood and paper industries, this leaves around three months. Given typical delivery times, this already affects goods being ordered today.
Conclusion
The EUDR ends with the customs declaration, but it starts much earlier: in the product master data. Companies that classify their commodity codes correctly, assign the appropriate EUDR indicator to each item and provide the reference numbers to customs in good time have resolved the most critical part of the interface. This does not require a new system. It is sufficient to supplement existing purchasing and customs data with a few EUDR fields and clearly allocate responsibilities.