TRACES and the EUDR: submitting and tracking your due diligence statements

This page covers submission and tracking: what TRACES is and what it is not, who submits and when, the content of a statement, obtaining the reference number, passing on the number, retention, alignment with your internal systems, the tool's limits and the mistakes to avoid.

In brief

TRACES, TRACES NT and the EUDR information system: what it is, what it is not

TRACES in three key points

TRACES stands for TRAde Control and Expert System. It is the European Commission's online platform, historically managed by DG SANTE (Directorate-General for Health and Food Safety), dedicated to sanitary and phytosanitary certification and to official trade-related documents. It hosts, for example, certificates and documents for imports, intra-EU movements and certain exports.

TRACES NT is the “new technology” version of this platform, which replaced the first generation. The same platform now hosts modules run by several Directorates-General: animal and plant health, but also other areas (FLEGT timber licences, waste shipment documents, CITES permits, catch certificates for fisheries, organic certificates). This coexistence explains a frequent confusion in companies: “being on TRACES” does not mean “having submitted a DDS”.

A specialised module: the EUDR information system

The EUDR information system is the specialised online tool created to receive DDS and simplified declarations and submit them to the competent authorities. It operates under Implementing Regulation (EU) 2024/3084, since amended.

Three operational clarifications:

• Access is via an EU Login account, on a so-called production server where statements have legal value and can be checked by the competent authorities.
• There is a second environment, called ACCEPTANCE, a replica of the first, reserved for training, testing and familiarisation. A statement submitted on ACCEPTANCE has no legal value. Registration is done separately on each environment.
• Importers and exporters must have an EORI number (Economic Operators Registration and Identification) and be registered in the system.

What TRACES does not do

This is the most useful distinction to make from the outset: the submission system is not the upstream collection system.

In other words: TRACES is the cash register, not the workshop. What you submit there must have been produced and checked upstream, in-house.

Who must submit a DDS, for what and when

The roles at a glance

A nuance not to be missed: submission does not move up the chain. A downstream operator does not resubmit a statement for a product already covered upstream; it keeps the number passed on to it. The entry point for submission remains the first party placing the product on the EU market.

When to submit

The rule is simple and leaves no margin: the DDS must have been submitted and accepted by the system before placing on the market or export. For an import, the reference number must be available before the customs declaration is lodged.

Practical consequence: submission is not done “when you have time”, nor at the end of the month. It fits into the product release process, on the same level as a blocking quality check.

The key timeline

“Operators shall not place relevant products on the market or export them without prior submission of a due diligence statement.”Regulation (EU) 2023/1115, Article 4(2) · consolidated text, EUR-Lex

Content and format of a due diligence statement

The information to gather

The DDS template is set out in Annex II of Regulation (EU) 2023/1115; Annex III provides the simplified declaration template. These templates are identical for all supply chains. The statement contains the information collected during due diligence, in particular:

• the product description and its HS/CN code (Harmonized System / Combined Nomenclature), with the scientific name of the species for wood;
• the quantity, expressed in kilograms of net mass and, where applicable, in the supplementary unit;
• the country of production and, where applicable, its regions;
• the geolocation of all plots of land of production, and the date or time range of production;
• the identity and contact details of the supplier and the business recipient;
• the elements demonstrating the absence of deforestation and compliance with the legislation of the country of production.

Geolocation, the main reason for rejection

For large volumes, coordinates can be imported in bulk in a GeoJSON file (Geography JavaScript Object Notation). Prepare this file and check it before opening the submission session: it is the main cause of back-and-forth.

Three submission methods

1. Manual entry in the form, statement by statement - suitable for low volumes.
2. Import of geographic files (GeoJSON) combined with entry of the product data.
3. API connection (Application Programming Interface), machine to machine, for bulk submission and management. The operator API reference and the GeoJSON file description are published by the Commission.

Obtaining the reference number and what it proves downstream

Reference number and verification number: do not confuse them

Once the statement has been submitted and accepted, the system assigns a unique reference number for that statement, as well as a verification number. The former identifies the statement and travels along the chain; the latter is a means of verification and must be treated confidentially.

Two classic mistakes at this stage:

• believing that registering in TRACES creates a reference number: registration gives access, it is not a statement;
• using the verification number as the number to pass on to the customer or customs: it is not the expected identifier.

What the number proves

The reference number attests that a statement has been submitted and accepted for a given product and quantity. It makes it possible to link a product placed on the market to an existing statement, and it can be verified by downstream actors and by the competent authorities. It does not, in itself, “prove” the quality of your risk analysis: that proof remains your due diligence file, which you must be able to produce.

Customs document codes

For the operations concerned (release for free circulation, export), the operator enters the document code corresponding to its situation in the customs declaration:

Waiver codes also exist where the customs code is listed in Annex I but the goods fall outside the scope of the regulation (for example Y129 for goods not concerned, Y190 for packaging used exclusively to support another product). This point should be handled with your customs and classification teams.

Passing on the number to customers and keeping it

Who passes what to whom

• The operator passes on to its first customer (downstream operator or trader) the DDS number corresponding to the products sold, together with its main identification details: name, registered name or trademark, postal address, email address and, where applicable, website.
• The first downstream buyer collects and keeps this number. It is not required to pass it on to its own customers: it passes on its identification details, not the upstream reference.
• An authorised representative may submit the statement on behalf of the operator, on the basis of a formal mandate and established in the Union. Not to be confused with the customs representative, who performs a different function.

Retention

Documents relating to due diligence are kept for five years from the date of placing on the market or export. This includes the statement itself, its reference number and the supporting documents collected. Downstream operators and traders likewise keep information on their suppliers and customers for five years.

What “keeping” means in practice for a Quality or Regulatory manager:

• an identifiable location for each DDS (not a shared mailbox);
• linking the number to the batch or logistics batch, not just to the product;
• successive versions kept when a statement is replaced;
• the ability to retrieve the complete file in a few minutes, not in a few days.

Aligning TRACES with the ERP, the supplier portal and document management

The EUDR information system knows neither your item codes nor your batch numbers. It is therefore up to you to maintain the correspondence between the world of the statement and the world of physical flows.

The five requirements to define before industrialising:

1. A common identifier between ERP item, product and Annex I commodity.
2. A batch → geographic origin → DDS link, on which all the evidence depends.
3. A geographic master data repository able to store points and polygons and export a valid GeoJSON.
4. Versioned document management, with an owner and a due date.
5. A connection point to the information system: supervised manual submission or a documented API.

The API is the route to industrialisation for high volumes, but it does not remove the need for internal control: the specifications change, and the release notes published by the Commission must be consulted regularly.

The tool's limits: what TRACES will not do for you

It is healthy to name the limits, if only to size the project:

1. It is not a supplier data collection tool. No campaigns, no questionnaires, no supplier reminders.
2. It is not a document management system. It does not store your evidence file, does not track expiry dates and does not alert you to an expired document.
3. It is not a risk assessment engine. Analysing the risk criteria remains entirely your responsibility.
4. It is not a product master data system. The correspondence between your items and the Annex I codes is managed in-house.
5. It does not rule on the accuracy of the information. You declare, under your own responsibility, data that you have collected and checked.
6. It does not guarantee compliance on its own. A successful submission is just one step: compliance relies on the quality of the due diligence system.
7. It has two environments that must not be mixed up. A submission on ACCEPTANCE is a test, never evidence.

Frequent mistakes when submitting and tracking a DDS

1. Confusing registration with a statement. Creating a TRACES account does not produce any reference number.
2. Submitting after placing on the market or export. Submission must precede the operation; for imports, it precedes the customs declaration.
3. Passing on an internal reference (order number, batch number, commercial reference) instead of the DDS reference number.
4. Communicating the verification number as if it were the reference number, or sharing it without precautions.
5. Working on the ACCEPTANCE server while believing you are submitting a valid statement.
6. Forgetting to pass on the number to the first buyer, which blocks downstream traceability.
7. Not linking the number to batches. Without this link, it is impossible to show during an inspection that the goods sold are actually covered.
8. Exceeding the quantity covered without submitting a new statement.
9. Resubmitting a DDS downstream when the product is already covered upstream.
10. Not archiving the statement and its supporting documents for five years, or leaving them in individual mailboxes.

Operational checklist: submitting and tracking a DDS

• Before the first submission
• Role (operator, downstream operator, trader, MSPO) documented per product.
• Size of the entity and application date confirmed.
• Products classified: CN code checked against Annex I, with written justification.
• EORI number available and EU Login accounts created.
• Accounts created separately on the production server and on ACCEPTANCE.
• A full test carried out on ACCEPTANCE, then cleared of any confusion with production.
• GeoJSON file prepared and checked (format, closure of polygons, order of coordinates).

• At submission
• Annex II information gathered and proofread (product, quantity in net mass, origin, dates, supplier).
• Geolocation consistent with the size of the plots of land (polygon or point).
• Statement submitted and accepted by the system.
• Reference number noted and recorded, with the verification number stored separately.
• Number linked to the product and to the batch in the internal master data.

• After submission
• Number passed on to the first downstream buyer, with the identification details.
• Document code entered in the customs declaration (C716, C717 or other applicable code).
• Statement, number and supporting documents archived for five years, in an identifiable location.
• Quantities used tracked: new DDS as soon as the quantity covered is exhausted.
• Monitoring of new information: in case of doubt about a product already placed on the market, competent authorities and downstream actors informed.

Going further

To place submission within the overall scheme - product classification, geolocation, risk assessment, audit readiness - our complete guide covers EUDR compliance end to end.

Submission in TRACES is never the starting point: it comes at the end of the chain, once the supplier and product data are complete, consistent and linked to the right batches.