The EUDR Information System: What Operators Must Register

Your shipment is ready. Your supplier says everything is compliant. But without a valid Due Diligence Statement (DDS) reference number from the EU Information System TRACES NT, your goods are legally blocked at customs. No exceptions.

That’s the reality operators, traders, and downstream businesses face right now under EU Regulation 2023/1115 (EUDR). The regulation doesn’t just ask you to source deforestation-free products. It requires you to prove it digitally, verifiably, and before goods cross the border by interacting with a specific information system that most compliance teams are still figuring out.

If you’re struggling with any of the following, this guide was written for you:

• Fragmented supplier data scattered across ERPs, spreadsheets, and email threads
• Uncertainty about exactly what you need to register, upload, and submit in the EU system
• Manual DDS workflows that create errors, delays, and customs holds
• Smallholder geolocation gaps that block your DDS submission entirely
• Downstream operators are unsure of their new obligations under the 2025 amendment

Key Takeaways

• The EUDR Information System (via EU TRACES) is mandatory for all operators and traders placing regulated commodities on the EU market.
• Companies must register, submit due diligence statements (DDS), and upload geolocation data (GPS polygons).
• Required data includes supplier details, country of origin, risk assessment, and deforestation-free verification.
• Each shipment must be backed by traceable, verifiable, and audit-ready documentation.
• Without proper registration and data submission, products cannot legally enter or be exported from the EU market.

What Is the EU EUDR Information System (TRACES NT)?

The EU EUDR Information System, officially TRACES NT (Trade Control and Expert System New Technology), is the European Commission’s centralized digital platform where all compliance actions under EUDR are recorded and validated.

Think of it as the regulatory passport system for every commodity shipment touching the EU market. Without an active record in this system, you do not have legal market access. It is not optional, and it cannot be substituted by internal certifications, FSC labels, or supplier declarations alone.

Who Must Interact with the System

The system has four primary user types, each with distinct roles:

Regulatory Update

An amending regulation published in December 2025 extended the DDS deadline: large/medium operators now have until December 30, 2026; small and micro operators until June 30, 2027. However, core obligations, geolocation data, risk assessment, and TRACES submission remain fully intact. Use this window to build audit-ready systems now.

What Operators Must Register in the EU System

Before you can submit a single DDS, you must be registered as an operator in TRACES NT. This is not a one-time check: registration creates your legal identity within the system, and every DDS you file will be tied to it.

Step 1: EU Login Account

Every operator, trader, and downstream entity must create an EU Login account (formerly ECAS). This is the single sign-on gateway for all EU Commission systems, including TRACES. Teams managing multi-entity or multi-country compliance can use delegation features, allowing EU-based representatives to file on behalf of non-EU exporters under a single account.

Step 2: TRACES NT Operator Profile

Within TRACES, you register your operator profile, including:

• Legal entity name and registered address
• EORI number (Economic Operators Registration and Identification, mandatory for EU customs interactions)
• The commodity categories you handle (cocoa, coffee, soy, palm oil, rubber, timber, cattle, or derived products)
• Country or countries of sourcing
• Authorized users within your organization

Step 3: Downstream Operator Registration (New Requirement, 2025)

Under the October 2025 amendment, a new category, Downstream Operators, must now register in the system. These are manufacturers and retailers placing products on the EU market that are made from commodities already covered by an upstream DDS. While they don’t file a full DDS, their registration creates the traceability link that competent authorities can audit.

Pain Point: Registration Delays Blocking DDS Submission

Many operators report that EORI validation and TRACES account setup take 1-3 weeks. Without pre-registration, you cannot submit DDS even if all your supplier data is ready. Start registration immediately, don’t wait for compliance deadlines.

Understand the role of downstream operators under EUDR. Read the blog to learn your responsibilities and compliance requirements.

What Operators Must Upload: Building Your Due Diligence Statement (DDS)

The DDS is your legal declaration, the official proof that every product you’re placing on the EU market is deforestation-free and legally sourced. It is not a form you fill in manually. At scale, it must be generated from verified, validated data. Here’s exactly what goes into it.

Learn how to submit your DDS through EU TRACES step by step. Read the blog to ensure an accurate, compliant submission without delays.

1. Product Information

• Product type and description (e.g., green coffee beans, palm kernel oil)
• HS commodity code, incorrect codes are one of the most common DDS rejection reasons
• Country of production
• Quantity and unit of measurement
• Batch or lot identifiers for traceability

2. Geolocation Data – The Hardest Requirement to Get Right

EUDR mandates plot-level geolocation data for every plot of land where regulated commodities were produced. This is the requirement most operators struggle with the most and the one most likely to block your DDS submission.

Acceptable formats include GeoJSON polygons (preferred) or GPS point data. The data must confirm that the plot did not contribute to deforestation after December 31, 2020.

The challenge here is severe:

• Most tropical commodity supply chains run through thousands of smallholder farmers who lack digital literacy, formal land records, or GPS devices
• Hand-drawn maps, GPS screenshots, and outdated land surveys do not meet EUDR standards
• A single invalid GeoJSON polygon can get your entire shipment’s DDS rejected

How TraceX Solves the Geolocation Gap

TraceX’s mobile-first field app supports GPS-enabled polygon and point mapping, offline data capture, and multilingual onboarding specifically designed for smallholder farmer networks. AI validates and corrects polygon geometries before DDS submission, eliminating the rejection risk at source.

Invalid GeoJSON Can Block Your Shipment. Validate Now – Check polygons, fix errors, and ensure your data meets EUDR requirements before submission.

3. Legal Compliance Documentation

• Evidence of compliance with local land-use laws in the country of production
• Labor law compliance documentation
• Environmental protection certificates were required
• In high-risk countries, additional due diligence documentation at each sourcing step

4. Supplier Verification Data

• KYC (Know Your Customer) records for each supplier in the chain
• Supplier declarations confirming deforestation-free status
• Audit trail showing the chain of custody from the farm to the point of EU market entry

5. Risk Assessment Documentation

The EUDR benchmarking system classifies every country of production as low, standard, or high risk. Your uploaded DDS must include evidence of a risk assessment proportional to the country classification:

• Low-risk countries: simplified due diligence; lighter documentation burden
• Standard-risk countries: full due diligence required
• High-risk countries: enhanced due diligence, more granular evidence, more stringent supplier checks

The Real Cost of Getting This Wrong

A rejected DDS means your shipment cannot enter the EU market. Common rejection reasons: invalid GeoJSON polygons, incorrect HS codes, missing supplier information, and batch traceability gaps. Each rejection means delayed shipments, customs holds, and mounting operational costs before you’ve sold a single unit.

What Operators Must Track: Ongoing Compliance After DDS Submission

Submitting a DDS is not the end of your compliance obligation; it’s the beginning of an ongoing tracking and record-keeping requirement. Here’s what operators must maintain after submission.

1. DDS Reference Number Management

Every approved DDS generates a unique reference number in TRACES. This number must:

• Be passed downstream to traders and downstream operators in your supply chain
• Be referenced at customs entry; without it, shipments are blocked
• Be stored in your compliance records and linked to the specific shipment batch it covers
• Be updated within 72 hours if shipment details change after submission

2. Five-Year Record Retention

All DDS filings and supporting documentation, geolocation data, supplier KYC, risk assessments, and legal compliance evidence must be retained for five years and made available on demand to competent authorities during regulatory inspection.

The most common pain point here: ERP systems, traceability platforms, and TRACES hold fragmented pieces of this data. When they don’t integrate, compliance teams spend hours re-entering data and risk creating audit gaps.

3. Ongoing Deforestation Monitoring

EUDR compliance is not a point-in-time check. The deforestation cut-off date is December 31, 2020, but operators must continue monitoring their supply chains for emerging deforestation risk. If a previously compliant supplier’s plots are flagged for post-2020 deforestation, your next DDS submission for that supplier will fail.

Leading compliance platforms use real-time satellite datasets, GRC and Hansen, to continuously monitor forest cover across your supplier network, alerting teams to risk before it becomes a customs problem.

4. Downstream Operator Reference Passing

Under the 2025 amendment, if you are an upstream operator, you are required to pass your DDS reference number and declaration identifiers to every downstream operator, trader, and retailer in your chain. This is a new legal obligation, not a courtesy. Downstream operators must then maintain these identifiers in their own TRACES registration.

5. Audit Readiness: The 5-Year Window

The EU’s first consolidated EUDR review will occur by June 30, 2030. That means every DDS you file, every supplier you onboard, and every geolocation dataset you upload between now and then needs to be audit-ready. Competent authorities can trigger inspections at any point and a fragmented, manually managed compliance record is the highest-risk posture you can have.

Explore EUDR solutions built for end-to-end compliance.

The 5 Biggest Challenges Operators Face with the EU Information System

These aren’t edge cases. They’re the operational realities that compliance directors, procurement leads, and supply chain managers encounter every week and the ones most likely to result in blocked shipments or failed audits.

Challenge 1: Data Fragmentation Across Systems

ERP systems hold procurement data. Traceability platforms hold farm data. TRACES holds compliance records. When these three don’t communicate, your team manually re-enters data across platforms, multiplying error risk and submission delay at exactly the moment when shipments are on the water.

Who feels it most: IT Directors, Procurement Leads, and CFOs managing compliance infrastructure costs.

Challenge 2: Smallholder Geolocation at Scale

A large percentage of tropical commodity supply chains run through smallholder farmers who lack GPS devices, formal land titles, or digital infrastructure. Onboarding thousands of smallholders with verified, plot-level polygon data is operationally complex. One gap in this data means your DDS cannot be submitted or will be rejected.

Who feels it most: Field Data Teams, Supplier Managers, Cooperative Coordinators.

See how a leading tire company achieved EUDR compliance at scale. Explore the case study to learn how large-scale polygon mapping enabled traceability and audit-ready supply chains.

Challenge 3: Manual DDS Generation

Most operators lack automated workflows to create, update, and submit DDS for each consignment. Manually filling forms, cross-checking documents, and uploading to TRACES creates submission delays, errors, and audit exposure, especially for businesses managing hundreds of shipments per quarter.

Who feels it most: Compliance Officers, Operations Managers, Logistics Teams.

Challenge 4: Country Risk Reclassification

The EU benchmarking system continuously reassesses country risk levels. A sourcing region that is standard-risk today may become high-risk tomorrow, requiring immediate changes to due diligence depth, documentation requirements, and supplier verification workflows. Companies without dynamic monitoring systems are always reacting rather than anticipating.

Who feels it most: Chief Compliance Officers, Head of Sustainability, Legal Teams.

Challenge 5: Downstream Operator Obligations (New)

The 2025 amendment expanded EUDR obligations to downstream operators, manufacturers, and retailers who previously had no direct compliance role. These businesses now need to register in TRACES, maintain traceability records, and pass DDS reference identifiers through their supply chains. Many are only beginning to realize the scope of what this requires.

Who feels it most: Procurement Directors at Retailers, In-House Legal, and Sustainability Leads at Manufacturing Groups.

How TraceX Makes EUDR Information System Compliance Scalable

TraceX is built specifically to close the gap between your operational data and what the EUDR Information System requires. Here’s how it maps to the exact obligations outlined above.

Automated DDS Generation

TraceX pulls supplier data, geolocation inputs, and risk assessment scores directly from your connected systems and generates TRACES-ready DDS automatically, tied to procurement events, not manual triggers. Compliance happens before coffee is on the water, not at the border.

Plot-Level Geolocation with AI Validation

The platform supports polygon and point-based mapping validated against satellite imagery and official deforestation datasets. Built-in AI corrects polygon geometries and flags invalid data before submission, eliminating the most common DDS rejection trigger.

Direct TRACES Integration via API

TraceX connects directly to TRACES NT via API, eliminating manual re-entry of data between your internal systems and the EU platform. DDS submissions, amendments within the 72-hour window, and audit trail maintenance all happen inside the same workflow.

Continuous Satellite Monitoring

Real-time integration with GRC and Hansen datasets means your sourcing plots are continuously monitored for deforestation risk, not just checked once at onboarding. Emerging risks surface as alerts before they become compliance failures.

Downstream Operator Traceability

For operators passing DDS references downstream, TraceX manages the full chain of custody automatically, distributing reference identifiers to downstream operators and traders in your network, creating the documented traceability chain that EUDR requires.

The Deadline Is Real. The System Is Live. Is Your Compliance Infrastructure Ready?

The EU Information System is not a future obligation. TRACES NT is operational now. Competent authorities are beginning enforcement. And large operators who miss the December 30, 2026 deadline face shipment rejection, financial penalties, and loss of EU market access.

The operators who are building audit-ready systems today, automating DDS generation, validating geolocation at source, and integrating with TRACES directly, are not just meeting compliance. They are creating the operational infrastructure that will sustain EU market access for the next decade.

Frequently Asked Questions (FAQ’s)