compliance e AEO

How to fill out Customs Declaration of commodities eligible for EUDR

Ottobre 2, 2026 /

In order to ensure that its import and export operations are carried out in full compliance, the economic operator must include the following codes in its customs declarations:

  • C716 – Reference of the due diligence statement for import or export

  • C717 – Identifier of the simplified declaration submitted by primary micro or small operators

  • Y129 – Goods classified under “ex” codes but not falling within the scope of the EUDR

  • Y132 – Products manufactured before 29 June 2023

  • C718 – Products already placed on the EU market during the transitional period and subsequently exported or re-imported

  • Y133 – Used or second-hand products, waste, recovered materials, or products derived from recovered materials

  • Y141 – Transitional regime for natural persons, micro-enterprises and small enterprises until 29 June 2027

  • Y142 – Non-commercial shipments between consumers

  • Y187 – Samples of negligible value and quantity and products intended for examination, analysis or testing

  • Y190 – Single-use or reusable packaging used exclusively to accompany, protect or transport other products

  • Y191 – Products used in the manufacture of medicinal products and certain informational or correspondence materials

  • C720 – Re-importation by non-SME downstream operators registered in the information system

  • C725 – Re-importation by SME downstream operators not registered in the information system

  • Y188 – Export by unregistered SME downstream operators

  • Y196 – Export by registered non-SME downstream operators

These are the codes indicated in the TAXUD note of 30 September 2024, Ares(2024)6896255. However, the codes are only the final link in a complex process.

Indeed, it is worth considering that the EUDR is a form of compliance based on a supply-chain management framework that affects how companies identify, document and control the origin of the products they handle: cattle, cocoa, coffee, oil palm, rubber, soy and wood. In other words, the EUDR transforms regulatory obligations into a stable, verifiable and genuinely sustainable compliance system for businesses.

For this reason, it will only be possible to import, export and make available within the EU products that meet the following requirements:

(a) They are deforestation-free;

(b) They have been produced in compliance with the legislation in force in the country of production; and

(c) They are covered by a due diligence statement (DDS).

These three requirements presuppose a risk-management process, which is further analysed in the Commission Communication containing the “Guidance Document for Regulation (EU) 2023/1115 on deforestation-free products” (C/2026/3896). This document specifies that:

  • First placing on the EU market: the first time a product is placed on the EU market;

  • Making available on the market: this requires the product to be supplied and both of the following conditions to be met:

    1. the product is supplied for distribution, consumption or use on the Union market. This means that the commodity or product concerned must be physically present in the EU, either because it was harvested or produced in the EU, or because it was imported into the EU and placed under the customs procedure of “release for free circulation”;

    2. the supply takes place in the course of a commercial activity, i.e. an activity carried out in a commercial context;

  • “Relevant products entering the market”: these are products that simultaneously meet the following characteristics: they are declared for placement under the customs procedure of “release for free circulation”, thereby being intended to be placed on the Union market. Only products released for free circulation by the customs authorities are considered to have been placed on the Union market; and they are intended to be placed on the Union market, i.e. supplied in the course of a commercial activity.

It is worth recalling that, according to the Communication under consideration, products intended directly for private use or consumption (consumer-to-consumer) within the customs territory of the Union — for example, products brought back by individuals from a trip outside the EU for their own private use or consumption — are not subject to the EUDR.

Finally, export should be understood as the customs procedure involving the actual removal of the goods from the European customs territory. In this regard, Article 269 of Regulation (EU) No 952/2013 provides that the export procedure does not apply to:

(a) goods placed under the outward processing procedure;

(b) goods leaving the customs territory of the Union after having been placed under the end-use procedure;

(c) goods supplied, exempt from VAT or excise duty, as supplies for aircraft or vessels, irrespective of the destination of the aircraft or vessel, for which proof of such supply is required;

(d) goods placed under the internal transit procedure; and

(e) goods temporarily moved outside the customs territory of the Union.

In the forthcoming issues, Dogana Sostenibile will provide further clarification on:

  1. the definitions of “operator”, “downstream operator”, “primary micro or small operator” and “trader”;

  2. the date of entry into force and the timeline for application;

  3. due diligence;

  4. clarification of the concept of “complexity of the supply chain”;

  5. legality;

  6. the product scope;

  7. the regular maintenance of a due diligence system; and

  8. the role of certifications and third-party verification systems in risk assessment and risk mitigation.