Under the EUDR, import means an import from outside the EU, and export refers to an export to a country outside the EU. An import company has the role of an operator within the meaning of the Regulation.
In the EUDR, an operator means a natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them, except for downstream operators.
The measures required under the EUDR should be carried out before making procurement decisions.
Measures in imports
- Establish a due diligence system (a so-called DD system) to ensure, by applying it, that the products comply with the EUDR.
- Collect the required information about the products by applying your DD system. See Article 9 of the EUDR.
- Carry out a risk assessment and, where necessary, risk mitigation measures for the products by applying your DD system.
- Submit a due diligence statement (DDS) in the Commission’s EUDR Information System well in advance of the import.
Please note: Customs clearance cannot take place until the DDS has been submitted.
Measures in exports (the Finnish Food Authority’s preliminary interpretation of the amending Regulation, February 2026)
- Downstream operators are not required to indicate the DDS reference number or the declaration identifier in the export declaration.
- If you are an operator, indicate the DDS reference number related to the products in the export declaration, or, in the case of a micro or small primary operator, the declaration identifier. A new DDS does not need to be submitted for the products.
- Please note: The impact of the amending Regulation on exporters’ obligations is still under discussion at EU level. We will update our interpretation as necessary.
Measures in re-imports
Guidance from the Commission is awaited regarding measures related to re-imports.
When re-importing a product that was originally placed on the EU market during the transitional period, the ‘universal reference number’ communicated by the Commission must be indicated in the customs declaration. For more information, see the Commission’s FAQ, Implementation of the EU Deforestation Regulation, Version 4, Questions 9.1 and 9.2.