Here you will find frequently asked questions with answers about EUDR from cubemos.
Yes, cubemos also offers content-related advice on EUDR, sustainability and supply chain compliance. These services are part of our support and service packages and are provided to the extent agreed in advance.
Our experts provide you with practical support in interpreting regulatory requirements, designing effective implementation strategies and integrating your suppliers. This ensures that your organization is not only technically sound, but also legally compliant in terms of content.
cubemos enables the seamless integration of EUDR-relevant information into existing communication processes with customers - in particular through the connection to ERP systems.
The DDS reference numbers can be automatically integrated into existing business documents such as delivery bills, invoices or shipping documents. This means that they are passed on to customers in a standardized way and without any additional manual effort.
In addition, the cubemos makes the article master data publicly available - both in human-readable form via a web view and machine-readable as a JSON data set. This allows customer systems to retrieve the information automatically, which is particularly advantageous for audits, import controls or internal inspection processes.
The suppliers' due diligence declarations (DDS) are automatically checked by cubemos . The information stored there is accessed directly via an interface to the EU portal TRACES using the reference numbers provided.
The platform compares the DDS data with the information in TRACES, checks its completeness, plausibility and validity (e.g. expiration date) and then stores it in an audit-proof manner until it expires. This ensures that only valid and up-to-date DDS are included in the EUDR-compliant supply chain documentation.
Thanks to the TRACES connection, this comparison is fully automatic and requires no additional manual effort - which saves time, avoids errors and increases compliance security.
Suppliers receive an e-mail with a personalized access link that takes them to a protected entry platform. The use of this platform is free of charge for suppliers and does not require registration.
The EUDR-relevant content is queried using standardized questionnaire formats. Suppliers are specifically requested to provide information on products, origin, geo-coordinates and legal evidence - in accordance with the requirements of the EUDR. They can enter specific production sites, for example in the form of polygons on a map.
If required, the questionnaires can be forwarded within the supplier's own supply chain so that upstream players are also involved in a structured manner. After submitting the information, suppliers receive immediate feedback on the completeness and plausibility of their information.
Sales displays that are used, for example, in supermarkets or in retail for product presentation are generally considered to be packaging material and are therefore not covered by the EUDR. As long as these displays are only used for the transportation, presentation or sale of other products and are not themselves placed on the market as commercial goods, they are considered exempt - in the same way as lifting, supporting or carrying packaging.
The conclusions of the expert groups referred to in Art. 10 (2) (k) EUDR are not accessible. What is publicly accessible are the results derived from them - the country benchmarking list published by the EU Commission. This contains the classification of countries as low, normal or high risk and is the central result of this committee's work. The list can be found in the Annex to the EUDR Implementing Regulation, available at the following link: https://environment.ec.europa.eu/publications/commission-implementing-regulation-laying-down-rules-application-deforestation-regulation_en
No. The EUDR does not require companies to use special Software . The digital due diligence declaration (DDS) is mandatory and must be submitted via the EU portal TRACES - this is the European Commission's central system for implementing the EUDR.
Data can be entered manually directly in the TRACES portal. However, digital solutions such as cubemos offer a significant advantage: they support companies in structured data collection, systematic risk analysis and the automated creation of legally compliant DDSs, which can then be transferred directly to TRACES. This saves time, reduces errors and improves traceability during internal and external audits.
If you purchase finished products abroad, you need a valid digital DDS for the entire product. This must be provided by the manufacturer or the distributor and include all relevant information on the raw materials contained. You do not need to request a separate DDS for each individual raw material as long as the DDS for the entire product is complete and meets the requirements of the EUDR. In this case, the manufacturer is obliged to properly check and prove the entire supply chain - including the origin of the raw materials. As a distributor, you would be responsible for checking this DDS and ensuring that it is complete and plausible in order to fulfill your own EUDR responsibility.
No, not all deforestation in a region of origin automatically has an impact on your product. The EUDR requires a clear and traceable link between the specific area on which the raw material in question was grown or harvested and the product that is placed on the EU market. Only the area that can actually be allocated to the product is taken into account.
Corresponding geodata must be provided for these areas - in the form of a polygon for areas over four hectares and latitude and longitude for smaller areas. Only if deforestation has been detected on these clearly identified areas after the cut-off date of December 31, 2020, will the product be considered non-compliant with EUDR. The satellite data used to validate this information must be relevant and verifiable.
No. Synthetic rubber is not affected by the EUDR, as the regulation only mentions natural rubber as a relevant raw material.
Background: The EUDR targets raw materials with a direct link to deforestation or forest degradation - synthetically produced materials do not fall within this scope.
If you can prove that you only use synthetic rubber, you are not obliged to submit a DDS in accordance with EUDR.
Yes, downstream market participants may rely on a valid Due Diligence Statement (DDS) from their direct supplier - as long as it is complete, plausible and legally compliant.
A separate traceability back to the origin, including customs tariff numbers (HS codes) and geolocation data, is not required if the DDS contains all legally required information and there are no indications of increased risks.
Important: As a company, you remain responsible for the appropriateness and plausibility of the DDS. In the event of suspicious circumstances, changes in the supply chain or new suppliers, a new or more in-depth review is required - including access to the original data if necessary.
Currently, DDS reference numbers are often documented manually via delivery bills, emails or Excel lists. Batch-specific allocation to products is often not guaranteed - especially as many suppliers do not yet provide their DDS in a standardized way. This leads to a high level of effort and increased risk when it comes to verification.
cubemos offers a structured solution for this:
- Automated recording of DDS reference numbers via digital interfaces
- Batch-related linking with incoming goods and products
- Integration into existing ERP/merchandise management systems
- Standardized supplier assessments that digitally support the DDS process
- Real-time monitoring, audit trail and audit-proof reporting options
This creates transparency and reduces manual sources of error in the EUDR process.
The EUDR comes into force on December 30, 2025 - from this date, large companies will be obliged to comply with due diligence obligations.
Small and medium-sized enterprises (SMEs) - i.e. with up to 250 employees, a balance sheet total ≤ €25 million or a turnover ≤ €50 million - have a transitional period until June 30, 2026, provided that the company meets at least two of the three thresholds on the balance sheet date of December 31, 2020.
From the end of the transition period, SMEs that place EUDR-relevant products on the market or export them must also submit a full due diligence declaration (DDS).
Exception: The extended transitional period of Art. 38 para. 3 EUDR does not apply to operators who import timber or timber products within the meaning of the Annex to the EUTR (Regulation (EU) No. 995/2010), make them available on the Union market or export them from the Union market.
Not mandatory. If you purchase rubber-based products such as NBR (nitrile rubber) from a supplier within the EU who has imported or manufactured these products themselves in the EU, the EUDR responsibility lies with this supplier.
The prerequisite is that the supplier provides a valid and complete due diligence declaration (DDS). In this case, no separate risk analysis is required.
A separate DDS or analysis is necessary if no DDS is available, the existing DDS is incomplete or untrustworthy, or the product is further processed and placed on the market again as a new EUDR-relevant product.
No, the EUDR is not applied retroactively. The relevant date is the date of "placing on the market", i.e. when the product is first made available or used on the EU market.
Examples:
- If advertising material is procured in 2025 but not distributed at a trade fair until 2026, the date of first use or distribution counts.
- If the product is placed on the market after December 30, 2025 (for large companies) or June 30, 2026 (for SMEs), the full EUDR obligations apply, including DDS.
The decisive factor is therefore not the time of purchase, but the moment when the product is actually used for the first time or passed on.
The decisive factor for the application of the regulation is who places the coffee on the market in the EU. If an external service provider supplies the coffee and fills the vending machines, this provider is responsible for EUDR compliance and must present a valid DDS. If your company procures the coffee itself, the responsibility for EUDR-compliant procurement lies with you.
The same principle also applies to canteens and catering services: If the food is provided by an external caterer, the caterer is responsible for the EUDR conformity of the raw materials used.
Yes, the EUDR applies exclusively to the product groups whose customs tariff numbers (HS codes) are listed in Annex I of the Regulation; products whose HS codes are not listed there are not covered by the Regulation and do not require a due diligence statement (DDS).
Annex I is currently being further developed by the EU - it is therefore advisable to regularly check the product groups concerned.
If you manufacture a product such as wooden furniture (e.g. HS code 9403 30) and place it on the EU market for the first time, you as a manufacturer are obliged to draw up your own due diligence declaration and enter it in the EU TRACES system.
Our AI provides well-founded and up-to-date suggestions based on the applicable EUDR regulations and HS codes and thus supports an efficient and structured classification.
However, the final legal assessment is always carried out by our experienced advisory team, which carefully checks and documents each classification. In this way, we ensure that our recommendations also meet legal requirements.
If your supplier has already placed the chocolate on the EU market with a valid due diligence declaration and you merely process it further (e.g. as a coating), you can rely on the supplier's declaration. The prerequisite is that you act as a downstream market participant and the supplier bears the actual responsibility as a market participant.
Nevertheless, you are obliged to check the supplier's information for plausibility - for example, with regard to the completeness of the geodata, supplier data and risk assessment.
As a downstream market participant, it is not sufficient to rely solely on a questionnaire. You are obliged to check the received due diligence declaration for completeness and plausibility. This includes, in particular, the geolocation data, the date of production, legal compliance and proof that no deforestation or forest degradation has occurred since the cut-off date.
Careful checking is important, as you can also be held liable in the event of a breach.
As due diligence declarations are usually submitted digitally and in a structured form, the check can be automated - for example by comparing the coordinates with publicly available deforestation maps.
There is currently no conclusive, reliable database that clearly clarifies whether a product falls under the EUDR based on a product name or description. The HS code descriptions in Annex I are sometimes vaguely formulated, which is why the classification of some products can be complex. The list is currently being further specified at EU level.
A useful, if not error-free, source is the TRACES user interface, which is used to enter due diligence declarations.
The most important reference for checking whether a product falls under the EUDR is the list of HS codes in Annex I of the Regulation. This lists the affected product categories.
The list is currently being further specified at EU level.
Essential oils, such as pine oil or fir oil, are not listed in Annex I of the EUDR and are therefore not affected by the regulation.
As Switzerland is not an EU member state, exports to Switzerland are an independent placing on the market process. In this case, passing on an existing reference number is not sufficient - the exporter himself is obliged to submit a due diligence declaration.
Reference to an existing reference number can only be made for shipments within the EU.
Timber is generally covered by the EUDR if it falls under one of the HS codes concerned.
If a construction company purchases processed timber (e.g. beams, glued laminated timber, OSB panels) from an upstream supplier who has already placed the material on the market with a valid declaration of due diligence, the construction company is a downstream market participant. It does not have to submit its own DDS, but must check and document the validity and completeness of the reference number.
If the construction company itself imports timber or uses raw materials without a valid reference number, it is obliged as a market participant to submit its own due diligence declaration.
The obligations of the EUDR also apply to wood used for non-structural or temporary purposes (e.g. formwork panels) - provided the material falls under an affected HS code and is placed on the market as a product.
The decisive factor for the application of the EUDR is not the group structure, but the process of "placing on the market". If a relevant product is transferred from one group company to another subsidiary within the same group of companies - for further processing or distribution, for example - this constitutes placing on the market within the meaning of the EUDR. In this case, a declaration of due diligence is required.
Imports from high-risk countries such as Myanmar are not ruled out in principle, but are in fact only possible under very strict conditions. As a high-risk country, the EUDR requires a well-founded risk analysis. If the risk cannot be effectively mitigated - for example due to a lack of traceability, a lack of transparency or incomplete data - the product in question may not be placed on the market.
In practice, it is currently almost impossible to achieve sufficient risk mitigation in the case of Myanmar. Our recommendation: Companies should carefully examine whether it is possible to switch to alternative sources of supply with a lower risk.
Packaging only falls under the EUDR if it is placed on the market or exported as an independent product - for example as empty cardboard boxes, crates or pallets. In this case, the due diligence obligations of the EUDR apply, as the packaging is considered an independent product.
However, if the packaging is used exclusively to protect, carry or present another product - for example when shipping or selling your own goods - it is not considered to be placed on the market independently. In this case, there is no obligation to provide evidence under the EUDR, even if a relevant HS code applies.
Not mandatory. Assembly and operating instructions that are supplied together with the main product - for example as part of the packaging or the scope of delivery - are not considered to be separate products and therefore do not fall within the scope of the EUDR.
The situation is different if such manuals are sold or imported separately. For example, if they are sold independently of the main product, cleared through customs under a separate HS code (e.g. Chapter 49 - Printed matter) or exported, they are considered to be separate products. In this case, the due diligence obligations of the EUDR must be complied with - analogous to other printed products such as catalogs or brochures.
The EUDR can also be relevant for the cosmetics industry - especially if an affected raw material such as palm oil, cocoa butter or soy is a component of the product, even in processed form. Although cosmetics are not explicitly listed in Annex I of the EUDR, manufacturers and retailers are generally considered to be downstream market players. In principle, they can rely on the due diligence declarations of their upstream suppliers, but must ensure that these are correct and complete - for example by checking the reference number and the accompanying documentation.
As soon as a company places paper products - such as flyers, brochures or catalogs - on the market, it is considered to be the first distributor within the meaning of the EUDR. It is therefore obliged to either submit a declaration of due diligence itself or to use an existing reference number and check its validity and the underlying documentation.
If the printing company places the finished end product - such as newspapers including inserts - on the market, it is subject to the obligations of the EUDR. Newspapers are explicitly covered by Annex I ("ex 49 - books, newspapers, pictorial prints...") of the Regulation.
Market participants are obliged to ensure that the paper used complies with the requirements set out in Article 3.
