Customs authorisation · Related statuses and registrations
EUDR: registering the operator and filing the due diligence statement
This is not a customs authorisation, and yet it is at the border that it stops you. The deadline is 30 December 2026 for large and medium-sized companies, and the piece of data most often missing — the geolocation of the plots — cannot be reconstructed after the fact.
The deadline is a few months away
30 December 2026 is not an administrative filing date. It is the date from which a covered product can no longer be placed on the Union market or exported without a valid statement.
The key item in the file is the geolocation of the production plots. It is collected from producers, sometimes at the far end of a purchasing chain, and sometimes over several seasons. This is not year-end work: it is agricultural-season work.
What the December 2025 postponement changed, and what it did not
Regulation (EU) 2025/2650 did two things. It pushed the deadlines back by a year. And it lightened the load downstream: only those who first place goods on the market file a statement. Operators further down keep the reference number of the upstream statement, without redoing the full risk assessment.
What it did not change: your compliance responsibility. The relief concerns the filing, not the obligation. A downstream operator without the upstream reference number is not exempt: it is in breach.
The reading to avoid is therefore this one: "the text has been postponed and simplified, so it no longer concerns me". It has been postponed and refocused, which is not the same thing.
What you need to assemble
Due diligence runs in three stages: collect, assess, mitigate. The first is the one that takes time.
- The geolocation of the plots where the commodities were produced, and the date or period of production.
- The country of production, the quantities, the description and the nomenclature code.
- The identification of your suppliers and of those you supply.
- The evidence showing the legality of the production under the law of the country of origin: land rights, labour law, third-party rights, taxation, environmental regulation.
- Therisk assessment and, where applicable, the mitigation measures adopted.
- For operators that are not SMEs, an annual due diligence report made public.
Often missed: legality and the absence of deforestation are two cumulative conditions. A perfectly legal product from a plot cleared after 2020 remains non-compliant.
The pitfalls
- Reading the postponement as an exemption. It is the costliest mistake, because it wastes the year that was gained.
- Believing you are out of scope because you are not the first to place goods on the market. Without the upstream reference number, you are in breach.
- Reasoning by finished product rather than by customs code. Leather, chocolate, furniture, printed paper, tyres: scope is judged code by code, as with CBAM.
- Confusing legality with the absence of deforestation. Both are required, and a supplier who proves the first has not proved the second.
- Asking for the geolocation at the last minute. A supplier who itself buys from cooperatives does not have plot coordinates on request.
- Forgetting the annual due diligence report, mandatory and public for operators that are not SMEs.
The cross-check with customs
The EUDR is not a customs procedure, but it interlocks with the declaration: the reference number of the due diligence statement must be traceable to the operation. It is the same pattern as CBAM: a product obligation checked at the moment the goods enter or leave.
The practical consequence is identical: the consistency between your customs data and your EUDR statements is the easiest check for an administration to run, and the one most often overlooked. Nomenclature codes, quantities, countries of origin: they must tell the same story on both sides.
What we do, and what we do not do
Included: determining scope by nomenclature code, mapping the supply chain, a collection protocol with suppliers in their working language, structuring the due diligence file, checking consistency with your customs declarations, and preparing the annual report.
Not included: filing the statement on the client's behalf unless expressly mandated, certification or field audit, verification of plot coordinates by satellite survey, and the lodging of customs declarations.
CTB Group steers customs compliance and governance; the lodging of declarations remains with the representatives appointed by the company.
Frequently asked questions
I am not the first to place goods on the market. Does this concern me?
Yes. You do not file a statement, but you remain responsible for compliance and you must hold the reference number of the upstream statement. The December 2025 relief concerns the filing, not the obligation.
My product is neither wood nor cocoa. Can I ignore this?
Scope is judged by nomenclature code, not by intuition. Leather, chocolate, furniture, printed paper and tyres fall within it, among several hundred codes. That is the first check to make, and it is made on your purchasing portfolio.
Does the postponement give me time to wait and see?
The deadline is 30 December 2026, a few months away. Plot geolocation is collected from producers who do not always hold that data, and sometimes over several growing seasons. The year that was gained is quickly lost.
Do you know which of your purchases are covered?
Thirty minutes, with no commitment, to run your purchasing portfolio through the covered codes and see where the data is missing.
Free first call (30 min)Sheet updated on 14 September 2026, sources checked with the European Commission and national administrations. The timetable has been amended twice since 2024: the applicable rules are revalidated for each file. See also: the authorisations catalogue, agri-food, the authorised CBAM declarant.