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EUDR: FAQs

Find answers to common EUDR compliance questions and learn how Prewave streamlines due diligence and risk management.

Sabine avatar
Written by Sabine
Updated over 2 weeks ago

About the Regulation

How is the source, reliability, validity, and links to other available documentation of the information referred to in Article 9(1) represented in Prewave?

Prewave provides full visibility into where information is coming from including the source.

Prewave enables the collection of information from Art. 9 para. 1 lit. a, b, and e through various processes, such as (i) manual implementation within the platform by the user, (ii) uploading information by the user into an Excel document provided by Prewave, or (iii) automatically via an API to the customer’s ERP system.

Prewave allows the collection of information from Art. 9 para. 1 lit. c, d, and e fully automated by contacting the relevant suppliers and/or producers. The user can manually or automatically contact one or more suppliers via the Prewave platform with a product origin inquiry. If the contacted supplier is not the producer of a relevant product and does not have the necessary information on the product’s origin, the supplier is prompted to forward the inquiry to their relevant suppliers down to the producer. The supplier is supported with predefined formulations, texts, and illustrations from Prewave to facilitate the information gathering. If the supplier forwards the inquiry to other suppliers in the supply chain, they must register via an included link, making it traceable which company provided the necessary information. Besides manual input of production- and geolocation-specific information by suppliers/producers, Prewave also allows the corresponding due diligence statement to be uploaded into the system.

Regarding the entry of geolocations into the system, Prewave has embedded various validation steps to ensure that the data complies with EUDR requirements, specifically that polygons (i) do not contain holes, (ii) do not have intersecting lines (e.g., in the shape of an ""8""), (iii) form closed shapes, and (iv) are located in the specified production country.

For determining the information on deforestation-free status according to Art. 9 para. 1 lit. g, Prewave offers a process where increasingly advanced/complex analyses are performed: First, the collected geolocations are transferred to the EU Forest Observatory map to check if there was forest in the specific areas as of the cut-off date. If confirmed, the next step is a check using an open-source satellite imagery analysis tool to determine whether deforestation occurred between the cut-off date and the production time. If this is also confirmed, the solution from Prewave's partner Satelligence is offered to reduce ""false positives"" (geolocation data where deforestation is detected using open source tools, although deforestation per EUDR criteria may not have occurred).

For determining compliance with the relevant laws in the producer country (Art. 9 para. 1 lit. h), Prewave uses the following sources, which are further detailed under the ""Risk Assessment"" section:

• Compilation of various EUDR-relevant indices and public sources (country risk and industry risk)

• Web screenings of pre-selected producers

Optionally

• Self-assessments filled out by suppliers/producers

• Information provided by the company about specific risks

How does Prewave demonstrate deforestation-free production in the country of origin and therefore compliance with the EUDR?

Prewave has a complete module for assessing deforestation risks based on precise geographic locations - the provided polygons. The process follows a step-by-step approach to ensure efficiency in the due diligence process.

  1. In a first step, plausibility checks are carried out to validate geometry and geographical locations of the polygons

  2. In a second step, open-source satellite data is used to verify that geolocations fulfil the requirement of negligible risk for deforestation

  3. Lastly, geolocations that have indications for deforestation can be escalated to the advanced satellite checks with Satelligence, where more granular Satellite data with best in class accuracy rate of above 95% ensures reduction of false positives.

- Additionally, Satelligence has the ability to verify that relevant commodity is produced at the location provided, thus adding an additional level of granularity and risk assessment

Is it correct to state that we need to report any purchase orders for goods within the EUDR scope into the EUDR system of information?

Due Diligence Statements (DDS), which certify product compliance, must be submitted electronically to the EU Traces System. While the system supports the use of purchase orders (POs) as reference information for Product Origin Requests and for managing quantities in the Quantity Accounting Module, the core requirement is to ensure that products within EUDR scope are compliant and have a DDS. The emphasis is on product compliance and reporting through the DDS, rather than directly reporting all purchase orders.

How does Prewave address EUDR Art. 3's requirement for risk control regarding legality (production compliant with country-specific laws)?

Each supplier is automatically evaluated and assigned a specific risk level based on country risk, industry risk and actual incidents at the suppliers based on media screening with Prewave’s AI for EUDR relevant risks. The country risk is determined based on 23 publicly available indices and classified into no risk, low risk, mid risk, high risk, and critical risk. Additionally, country-specific alerts related to the respective event types are considered. These indices cover, where evident, the human rights and environmental risks mentioned in the EUDR and are adjusted as necessary. A specific risk set for EUDR is used for screening each supplier, including risks, such as land grabbing or conflict, indigenous people, environmental issues or human rights violations.

How does Prewave data represent the presence of indigenous peoples and their rights, existence of duly reasoned claims, consultation and cooperation in good faith with indigenous peoples?

Prewave incorporates the perspectives of Indigenous communities through trusted external data sources such as LandMark and the Indigenous Navigator. These sources provide information on the presence of Indigenous peoples, their land rights, duly reasoned claims, and the extent of consultation and cooperation in good faith. This data is embedded into Prewave’s risk model to identify regions with known Indigenous claims or potential conflicts.

Is the legal right of the check of ownership for that land and commodity produced in accordance with local laws and regulations represented in your data?

As part of its producer risk assessment, Prewave evaluates whether a producer operates in areas associated with indigenous communities or regions with a known risk of land theft violations. When such risks are identified, Prewave recommends specific mitigation measures (including requesting documentation or certificates of land ownership) to ensure the commodity is produced in accordance with applicable local laws and land rights.

How long is EUDR-relevant data stored within Prewave?

Data will be stored and maintained for at least 5 years in order to be compliant with EUDR requirements.


Data Requirements

Are there format specifications for the address line, how does that work with international addresses?

The address must be written in Latin Characters to be verifiable. Prewave compares the customer's data against its existing data. If Prewave is confident that the customer is referring to a site already in the system, the customer's targets are validated. If the site is unknown, other databases are checked for recognition, and if found, the site's existence is also validated.

For additional details, please visit EUDR Discovery Template

Discovery Template: What does address mean: ship from or ship to? For EUDR, which location of HQ or site is needed?

The address refers to the origin site, specifically the ship-from address. It must be the location of the production site, such as a factory, paper mill, or sawmill.

What happens if there are discrepancies in addresses, but the postcode is the same? Can Prewave recognise and flag this?

Prewave's system validates customer targets by comparing them against existing data and checking other databases. If Prewave can identify the supplier at the provided location, this supplier target will be validated.

Is the data collection / need the same for low-risk countries?

To properly address the risk tier of any supplier, the information needs to be complete. This is regardless of the country.

The EUDR establishes a three-tier system for assessing countries: high risk, low risk, and standard risk, based on their risk of producing non-compliant commodities. Operators are always required to collect information demonstrating that relevant products are deforestation-free and have been produced in accordance with the relevant legislation of the country of production.

Is the detailed information needed at item level (versus a product group, for example)?

For Due Diligence Statements, granular traceability down to the specific plot of land where commodities were produced is a strict compliance requirement. This necessitates detailed information beyond just product groups. Prewave's Quantity Accounting Module also enables granular DDS referencing by linking outbound and inbound DDS via product IDs, serial numbers, timestamps, quantities, and purchase order (PO) numbers, which creates a verifiable chain of custody.

If a supplier claims that their products are not subject to EUDR and our own assessment shows that we need to deal with it as subject to EUDR, is there a way to clarify?

The Supplier Maturity Assessment emphasizes that operators must be able to provide DDS for EUDR-relevant products. If a supplier cannot provide the necessary information, such as geolocation data, their products would be considered non-compliant, and you would not be permitted to place them on the EU market.


Setup Prewave Platform

What is the purpose of the Prewave EUDR solution, and what are its main modules?

The Prewave EUDR solution is designed to help companies achieve full compliance with the European Union Deforestation Regulation (EUDR) by providing an end-to-end platform for tracking and managing products and suppliers. It offers flexibility and automation to align with EUDR requirements.

The solution consists of three primary modules:

  • Inbound Module: This module tracks all products entering your company's supply chain. It's crucial for collecting initial product and supplier information to meet EUDR compliance criteria. Data can be uploaded manually or via API.

  • Outbound Module: This module monitors products that are exported or sold on the EU market. It links directly to inbound products to ensure accurate transfer of due diligence information.

  • Due Diligence Statement (DDS) Module: This central repository stores, manages, and generates Due Diligence Statements (DDS), ensuring compliance with EUDR's regulatory framework. DDS are stored for a minimum of five years.

These modules are integrated to create a seamless process from product intake, through due diligence, and ultimately to export.

What does the "EUDR Perspective" in Prewave entail, and what types of risks does it monitor?

The "EUDR Perspective" in Prewave is designed to help companies monitor events related to the EU Deforestation Regulation. It focuses on identifying and highlighting risks in the supply chain that could be linked to deforestation or forest degradation, thereby supporting companies in meeting regulatory requirements and improving supply chain visibility.

It categorizes and monitors various event types across different risk areas, assessing their severity at both "Direct Level" (immediate impact) and "Company Level" (broader organizational impact):

  • EUDR Business Practices: Monitors for issues like accounting fraud, collusion, corporate investigation, corporate liability, corruption, customs issues, fraud, insider trading, lawsuits, legal procedures, regulatory shutdown, sanctions, scandal, smuggling, and tax evasion.

  • EUDR-Community Rights: Focuses on violations related to Indigenous Right to Lands and Indigenous Self Determination.

  • EUDR-Environmental Protection: Tracks concerns such as biodiversity degradation, chemical leakage, general environmental issues, pollution, toxication, and waste disposal problems.

  • EUDR-Forest Related Rules: Specifically monitors for instances of deforestation.

  • EUDR-Human Rights: Covers violations including freedom of religion/thought, general human rights violations, human trafficking, military action, military conflict, and military occupation.

  • EUDR-Labor Rights: Looks for issues like child exploitation, child labor, discrimination, health & safety issues, illegal employment, general labor rights violations, modern slavery, unethical labor, wage theft, and workplace safety.

  • EUDR-Land Use Rights: Monitors land conflict and land grabbing.

By providing alerts and risk scores based on these event types and integrating NGO indices for country risk assessment, the EUDR Perspective helps companies proactively identify and address potential non-compliance issues within their supply chains.

How does Prewave’s solution support sustainability and ESG goals beyond compliance?

Prewave goes beyond regulatory compliance by providing a holistic view of sustainability and ESG (Environmental, Social, Governance) performance across your supply chain. The platform’s continuous monitoring includes social risk factors (e.g., labour violations, community impacts), environmental sustainability (e.g., carbon footprint, biodiversity impact), and corporate governance (e.g., anti-corruption measures). By integrating EUDR compliance with broader ESG criteria, Prewave helps companies develop more sustainable supply chains and achieve long-term ESG targets.

How many datasets can be imported at once?

Prewave offers both manual entry for individual products and suppliers via its user interface, and API integration for continuous, real-time data updates. The API integration is designed to enable a more automated and seamless process for handling large volumes of product and supplier data.

Regarding industry mapping: If a company has its own industry mapping, does it need to equate that with Prewave mapping?

For complete functionality, the industry mapping must align with Prewave's mapping. The Discovery Templates offers a tab with all available industries.

How do you deal with suppliers who are active in different industries?

Suppliers who are active in various industries have a combined risk score based on all assigned industries.

How is the import and Export quantity transmitted to Prewave? Can this be transmitted via API?

Movement data, such as quantities for import or export, must be submitted manually in the platform or via API when the request for the respective EUDR information (geolocations or DDS) is sent to the supplier. API integration is available for continuous, real-time updates of all product and supplier data.

Important to note: API Integration is an add-on feature. Please talk to your Customer Success contact person for more information.

What are the benefits of using Prewave’s API integration?

The API integration allows for real-time data synchronisation between Prewave and your internal systems, ensuring seamless workflows. Key benefits include:

  • Automated Data Updates: New products, suppliers, and risk assessments are automatically reflected in the platform.

  • Seamless DDS Submission: Direct integration with the EU Traces system for faster, error-free DDS submissions.

  • Custom Reporting: The API can pull data from Prewave into your internal systems, enabling custom compliance dashboards, KPI tracking, and audit trails.

This integration significantly reduces manual effort, improves data accuracy, and enhances visibility across your entire compliance process.

Will the quantity we report automatically be noted in the "Quantity" field?

Yes, the most recently requested quantity will be displayed in the "Quantity" field.

Where is the reference number stored in your system?

All reference numbers generated by the EU Traces System after DDS submission are displayed in the "DDS" module within Prewave.

Example: wooden part A (article number 123456) comes from both supplier B and C. Do we have to create the article twice in your system?

Yes. Each supplier must have their origins for the article and also prove that they are EUDR compliant. While the article has the same number in your system, each supplier has its own production, and it is considered as a separate combination (e.g., Supplier B + Product A) and (Supplier C + Product A).


Suppliers

Do you offer a supplier portal for data submission (questionnaires, certificates)? Are standard supplier questionnaire templates provided?
What are the supplier requirements for using the portal?

A designated supplier engagement module designed for efficient EUDR compliance ensures seamless collaboration and communication with suppliers for information gathering. Important features of the module include:

Key Features:

  • Supplier Access & Collaboration:

    • Suppliers access the system for free via their own user account, requiring a simple registration with name and email.

    • Collaboration is free of charge, and suppliers can access their interface with information restricted to their specific products.

  • DDS & Producer Information:

    • For suppliers not providing a DDS: Allows input of producer information and geolocation.

    • For suppliers providing a DDS: Enables continuous input of DDS information.

    • DDS reference and verification numbers are automatically checked against TRACES, and error messages are returned for inaccuracies.

  • Exemption Documentation:

    • For suppliers with non-EUDR relevant products (due to material composition, company size, production timing, or other exemptions): Provides the ability to inform and document these reasons.

  • Information Submission Flexibility:

    • Offers flexibility in formats for providing information. GeoJSON can be directly uploaded, or an interactive map can be used for generation. Invalid polygons (due to geometry or geographical location) are automatically blocked.

  • Automated Processes & Quality Enhancement:

    • Automated processes with clear indications for missing information.

    • Missing information is clearly indicated, and automatic reminders can be set.

    • All information requests to the supplier can be triggered via an API.

    • Enhances information quality.

  • Referencing Opportunities:

    • A wide range of referencing opportunities are available, including PO, SN, Ref., and Timestamp.

How does Prewave handle suppliers operating in multiple industries or providing the same product from different sources?

Prewave addresses the complexities of suppliers operating in multiple industries and managing products sourced from various suppliers through specific functionalities:

  • Suppliers in Different Industries: If a supplier is active in various industries, Prewave assigns them a combined risk score. This means their overall risk profile, influenced by activities across all industries they operate in, contributes to a single aggregated score.

  • Same Product from Multiple Suppliers: If the same wooden part (e.g., "wooden part A, article number 123456") is sourced from both Supplier B and Supplier C, you must create the article twice in Prewave's system, or rather, treat each supplier-product combination as unique. Even though the article number might be the same in your internal system, each supplier has its own production process and origin data. Therefore, Prewave considers "Supplier B + Product A" and "Supplier C + Product A" as separate combinations. Each combination requires its own "origins" information and proof of EUDR compliance.

    This granular approach ensures that the specific origin and compliance status related to each supplier's production are accurately documented and verified, even for identical products, maintaining full traceability and adherence to EUDR requirements. Prewave collects and stores all EUDR evidence during the inbound process for automated DDS creation during outbound processes.


Supplier Maturity Assessment

How does the Supplier Due Diligence work in Prewave? What is the process to confirm EUDR readiness of suppliers?

Prewave reduces the risk of non-compliance penalties by providing a legally aligned platform that ensures companies meet all EUDR requirements. Supply chain disruptions are reduced by a highly automated process.

For suppliers expected to generate DDS, Prewave recommends utilizing the Maturity Assessment to confirm the supplier is ready to implement EUDR.

  • The assessment is developed in collaboration with the expert law firm Taylor Wessing

  • Assesses the maturity of the supplier’s EUDR due diligence process

  • Many industries will benefit from network effects with Prewave - for example more than 1000 Tier 1 automotive suppliers are already engaged on EUDR on Prewave

  • Results from completed assessments will be immediately visible, contributing to an accelerated EUDR due diligence process

For suppliers not generating DDS, the supplier engagement module is available to gather all relevant information required to complete a successful EUDR due diligence.

  • The module is intuitive and easy to use and additional educational material and guides are available for suppliers, as well as Prewave’s multilingual supplier success team

  • After receiving relevant information, risk assessments follow automatically, ensuring an unbroken due diligence process

When the supplier assessment shows that they are compliant, should we still report all information the same way?

If a supplier passes the Supplier Maturity Assessment and their maturity level is deemed satisfactory, the platform allows for fast-tracking their due diligence.

This means their compliance information can be reused across multiple products and transactions, thereby reducing the need for repeated assessments. However, for compliant products, the Due Diligence Statement (DDS) is still generated and submitted to the EU Traces System.

Once a valid "Supplier Due Diligence Statement" is stored and valid with you, it will be displayed as green. In what case will it be red?

A supplier's Due Diligence Statement will be displayed as red if the answers in their Supplier Maturity Assessment are critical. This could occur if the supplier, for example, does not use a satellite analysis tool or cannot provide information on how they verified the producers' compliance. If the assessment indicates that the supplier is not ready or lacks necessary compliance measures, they will need to take corrective steps before being able to import or export relevant products within or from the EU. If any of the "red flag" questions within the assessment are answered negatively, the entire assessment is considered critical, which then prompts a full due diligence process, including deforestation and legality checks.

How often do you check suppliers – once a year or when you receive information from us that, for example, the geodata has changed?

The Due Diligence Statements of suppliers are checked once a year. However, the geodata is checked as soon as it is necessary for the generation of a new DDS. The Supplier Maturity Assessment itself is sent out by the system to evaluate the supplier’s compliance level.


Product Origin Requests

What information is understood behind "origins" on the platform?

Under "origins" on the platform, the geolocation-specific information about the products that has been submitted by the supplier or producer is displayed. For example, for floor markings, this would include the specific rubber plantations. Information about DDS (Due Diligence Statements) is found in a separate column labeled "Supplier DDS". If a supplier fails to provide adequate origin details, the platform allows you to issue a Product Origin Request, prompting them to submit the necessary information about the product’s origin and production geolocation.

It is possible that certain countries will not agree to provide coordinates. Does it mean that we can no longer import from these countries in this case?

To conduct deforestation checks and verify that a product complies with EUDR, it is essential to provide the geolocation data for all plots of land where the relevant commodities used in the product were grown or produced. If a supplier cannot provide plot numbers or coordinates as required, this indicates non-compliance. The EUDR explicitly states that operators shall not place relevant products on the market or export them if they are non-compliant, or if the risk assessment reveals a non-negligible risk of non-compliance. Therefore, the inability to provide required geolocation data would indeed impact the ability to import from such countries under EUDR.


Deforestation Checks

Example: We want to import 100 kg of a product in Q1 2026. The supplier has no DDS or "Origins" before the first import. Does Prewave conduct deforestation checks via the satellite partner?

At Prewave two levels of deforestation checks are offered:

Basic checks and extended (detailed) checks, to assess the deforestation risk in your product's supply chain. These assessments evaluate geolocation data to determine whether the product comes from an area at risk of deforestation.

Satellite data providers (such as Satelligence) are used for these checks, verifying whether products come from land that has not been subject to deforestation after 31 December 2020. If a supplier has no DDS or "Origins" initially, a Product Origin Request would typically be issued to gather this essential data.

More information in this article: EUDR Deforestation Check.


Legality Assessment

Does Prewave use AI and risk scores to verify local legislation?

Prewave's AI scans suppliers for incidents reported in digital media and documents these as alerts. For assessing country risks (which are part of the 360 Score), Prewave utilizes various NGO indices that also cover regulatory aspects. Prewave uses the EUDR perspective to display the Risk Score, which details all event types relevant for EUDR compliance, including those related to legality. The Legality Assessment within the platform specifically checks the supplier’s Country Risk and Industry Risk based on these external data sources, providing a legality score.

How does Prewave assess supplier compliance with EUDR, particularly regarding deforestation and legality?

Prewave employs a multi-step process for assessing supplier compliance:

  • Supplier Maturity Assessment: This is the initial step, evaluating a supplier's readiness to meet EUDR obligations. It covers areas like the supplier's Due Diligence System (DDS) responsibility, compliance and legislation adherence, risk assessment, and risk mitigation. If a supplier provides critical answers to key questions (flagged with a red flag icon), they fail the assessment, necessitating a full due diligence process.

  • Product Origin Request: If product origin details are missing, the platform allows you to issue a "Product Origin Request" to the supplier, prompting them to submit necessary geolocation and production information.

  • Deforestation Assessment: For products with potential deforestation risk, Prewave conducts checks using geolocation data and satellite partners (like Satelligence) to determine if the product originates from an area affected by deforestation after 31 December 2020. This assessment provides "basic" and "extended (detailed)" checks.

  • Legality Assessment: This assessment verifies compliance with legality requirements, including legal harvesting of raw materials. It checks the supplier's Country Risk and Industry Risk based on external data sources, assigning a legality score. Prewave's AI also scans for incidents in digital media and uses NGO indices to assess country risks.

    If all assessments are passed, the product is deemed compliant, leading to the generation of a Due Diligence Statement (DDS). Supplier Due Diligence Systems are checked annually, and geodata is reviewed when a new DDS is needed.


Risk Mitigation

Should we assume that ordering or importing from a non-compliant supplier is not possible (e.g., a supplier who fails to provide the plot number of the land where the trees originate)?

Yes. If a risk assessment reveals a non-negligible risk of non-compliance, operators must implement appropriate risk mitigation procedures and measures before placing relevant products on the market or exporting them, aiming to reduce the risk to a negligible level. Operators are explicitly not permitted to place relevant products on the market or export them unless the risk assessment reveals no or only a negligible risk that the products are non-compliant. The inability of a supplier to communicate essential information like the plot number of land is a critical missing data point required for EUDR compliance.

How are risk mitigation actions determined? What is the workflow for risk mitigation actions?

Prewave automatically recommends questionnaires tailored to EUDR-specific topics based on the risk detected at the producer level. Each risk type monitored under the EUDR is addressed through a dedicated, customized questionnaire — for example, Labour Rights SAQ, Environmental Protection SAQ, etc. This targeted approach helps prioritize appropriate mitigation actions and significantly reduces the time required by internal teams to develop an effective mitigation plan.

Prewave allows defining mitigation tasks for identified risks, including the selection of action types or measures, setting a timeline, and assigning responsibilities. This is integrated into a clear workflow to guide users step by step through the mitigation planning process.


Quantity Accounting Module

How does the physical separation of goods impact EUDR traceability and compliance?

The physical separation of goods significantly impacts traceability and compliance under EUDR, directly influencing the extent of "contamination" if a non-compliant Due Diligence Statement (DDS) is identified. Prewave outlines three scenarios:

  • No Physical Separation (Low Granularity): In this scenario (e.g., commingled pile storage of o-rings), products from different origins or batches are mixed without physical distinction. Traceability relies on mass balance methods (FIFO/LIFO). If a single negative DDS is found, the entire commingled stock is considered "contaminated," as compliant and non-compliant goods cannot be differentiated. This leads to all outbound products being treated as non-compliant, potentially requiring recalls and disposals, posing significant financial and reputational risks.

  • Broad Physical Separation (Medium Granularity): Here, some separation is maintained (e.g., tires stored separately by purchase orders or delivery times), but batches within these units might still be mixed. Traceability involves aggregating DDS for these separated units. A negative DDS is limited to the affected segment, reducing widespread contamination. Outbound batches typically rely on aggregated DDS, making accurate quantity tracking essential.

  • Stringent Physical Separation (High/Perfect Granularity): This ideal scenario involves complete physical separation of products by individual batch or supplier DDS throughout storage. Traceability is based on tracking distinct, isolated batches. This offers optimal risk containment, as a negative DDS is strictly isolated to that specific batch, not affecting others. Outbound DDS can confidently reference specific, compliant inbound shipments. However, the integrity of this system relies heavily on accurate initial data for each batch, including supplier DDS and geolocation.

In essence, the more granular the physical separation, the better a company's ability to isolate non-compliant goods and maintain overall EUDR compliance, mitigating risks effectively.

As EUDR reporting is based on HS codes and quantity, should we check suppliers' DDS for this information to match the deliveries - batch by batch / by sampling process?

The Prewave platform requires HS codes and commodity codes for each product. The Quantity Accounting Module is designed to simplify EUDR compliance by managing aggregated DDS, tracking quantities in real-time, and ensuring continuous alignment between supplier data and outbound reporting. It supports any referencing scheme provided by customers, including shipment basis, purchase order (PO) basis, or generic patterns such as FIFO or LIFO. The effectiveness of granular traceability, which includes linking outbound and inbound DDS via various identifiers, depends on high-quality input data, such as accurate supplier DDS, quantities, and geolocations. This underscores the need for strong supplier collaboration and upstream data validation.

What is the definition for inbound & outbound quantity? Should it both be a forecasted quantity or actuals?

Movement data such as quantities (for import or export) must be submitted manually or via API when requesting EUDR information (geolocations or DDS) from the supplier. Prewave's Quantity Accounting Module continuously tracks incoming supplier quantities and compares them with existing DDS coverage. It accurately deducts quantities when outbound DDS are issued and records incoming supplier DDS. This continuous monitoring and reconciliation of quantities is essential for maintaining a compliant inventory ledger and ensuring sufficient DDS coverage, implying a focus on actual or available quantities for compliance purposes.

How does Prewave manage import and export quantities and distinguish between inbound and outbound processes?

The customer is deciding whether it is an inbound or outbound process through filling in the “Activity” field.

Prewave manages import and export quantities through its dedicated Inbound and Outbound modules, utilizing both manual entry and API integration for data submission.

  • Inbound Quantity: Import quantities are transmitted to Prewave via the Inbound module. This can be done manually through the platform's user interface or automatically via API integration with existing internal systems. The most recently requested quantity will be displayed in the "Quantity" field.

  • Outbound Quantity: For exports, quantities are managed through the Outbound module, similarly allowing for manual upload, Excel template, or API integration.

  • Distinguishing Inbound vs. Outbound: The customer must explicitly communicate whether a transaction is an inbound or outbound process via API, using the "Activity" property.

  • DDS and Quantity Alignment: The Quantity Accounting Module continuously tracks incoming supplier quantities and compares them with the coverage provided by existing DDS. This module uses systems like a "traffic light" display to visualize stock levels and DDS coverage percentages, ensuring continuous DDS coverage and alignment.

  • Reference Numbers: A unique reference number is created for each import transaction and is stored in the "DDS" module. For outbound processes, Prewave can reuse a specific import DDS if communicated, or it will use standardized methods like FIFO (First-In, First-Out) based on the article number and quantity.

This comprehensive approach ensures precise tracking of quantities, continuous DDS coverage, and seamless compliance across all import and export operations.


Due Diligence Statements (DDS)

What is a Due Diligence Statement (DDS) in the context of Prewave and EUDR, and how is it generated?

A Due Diligence Statement (DDS), in Prewave's terminology, is a formal document that certifies a product's compliance with all EUDR regulations, including standards for deforestation risk and legality. It is a declaration submitted to the EU Traces System.

The steps for creating a DDS are:

  • Data Collection: Prewave's platform gathers all necessary information, including product origin, supplier details, deforestation and legality assessment results, and any additional compliance documents.

  • DDS Creation: The platform automatically generates a DDS for each compliant product.

  • Submission to EU Traces System: The DDS is electronically submitted to the EU Traces System, which is the official EU portal for tracking and verifying deforestation compliance.

  • EU Reference Number: Upon successful submission, the EU Traces System generates a unique reference number, which is automatically retrieved and displayed in the Prewave platform. This number serves as proof of compliance and can be integrated with internal systems.

The DDS is then stored in the Prewave platform's DDS module for future reference and can be reused for subsequent transactions involving the same supplier and product, as long as the quantities of incoming and outgoing DDS match.

What information is considered essential for a Due Diligence Statement (DDS) according to EUDR, and how does Prewave facilitate its collection?

To create a Due Diligence Statement (DDS) and ensure EUDR compliance, operators are required to collect specific, verifiable information as outlined in Article 9 EUDR. Prewave facilitates the collection of this critical data:

  • Product Description: This includes the product's name, scientific name (for wood/rubber), HS codes, and commodity codes.

  • Quantity: The net mass of the product in kilograms and its Harmonised System (HS) code.

  • Country/Countries of Production: Essential for risk assessment based on the EU benchmarking system.

  • Geolocation of all Plots of Land: Precise coordinates for all areas where commodities were produced (e.g., rubber plantations, cattle grazing land). This is vital for deforestation checks.

  • Date/Time Ranges of Production: To verify that commodities were not produced on land deforested after 31 December 2020.

  • Supplier Information: Name, postal address, and email addresses of any business or person from whom the products were supplied. This is crucial for legality assessments and risk scores.

  • Recipient Information: Name, postal address, and email addresses of any business, operator, or trader to whom the products were supplied, necessary for generating outbound DDS.

  • Proof of Deforestation-Free Status: Adequately conclusive and verifiable information, including geolocation data and legality assessments.

  • Proof of Legality: Verifiable information that commodities were produced in accordance with the relevant legislation of the country of production, covering aspects like land use rights, environmental protection, forest-related rules, third parties' rights, labor rights, human rights (including FPIC), and tax/anti-corruption/trade/customs regulations.

Prewave's Inbound module is designed to capture this data, offering manual input or API integration for continuous updates. If information is missing, it can prompt suppliers to provide it via a "Product Origin Request."

How long is the Supplier DDS valid?

Supplier DDS are valid indefinitely for referencing. Prewave only checks that Supplier DDS are not referenced "too often," meaning it verifies whether the quantities of incoming and outgoing DDS match. The DDS generated by Prewave for an operator is stored in the platform's DDS module for a minimum of five years, as required by EUDR regulations. It is also noted that a DDS can be valid for up to one year, and compliance depends on the DDS aligning with both quantity and validity throughout the product's lifecycle.

How do you create the Due Diligence Statement? Do you always check all stored Due Diligence Systems of the respective suppliers?

Prewave collects all EUDR evidence during the inbound process and stores it. This stored information is then used for the outbound process so that the respective DDS can be created automatically. The platform gathers all relevant data, including product origin, supplier information, deforestation and legality assessments, and any additional compliance documentation, to generate a DDS. While Supplier Due Diligence Systems are checked once a year, Prewave also verifies that the quantities referenced by Supplier DDS match incoming and outgoing quantities. The DDS can be reused for subsequent transactions with the same supplier and product. Generally, an outbound request would be similar to an import request, requiring the article number + quantity.

Should all information concerning in-scope products be reported/uploaded to the EU Traces system before shipment?

The Due Diligence Statement (DDS) is submitted electronically to the EU Traces System. The EU Traces system then generates a reference number that serves as proof of compliance. The Due Diligence Process, including DDS generation, happens after all necessary product, supplier, and origin data has been added to the Prewave platform.

While movement data (quantities) must be submitted when requesting EUDR information, this process implies that information must be gathered and processed to generate the DDS before the product can be shipped as compliant.

If a batch reported as compliant is found to be non-compliant during an EC check, will we need to block goods usage based on identification of batch & item or just to block respective quantities?

The impact of a non-compliant batch depends on your physical separation strategy.

  • With stringent physical separation (e.g., by individual batch or supplier DDS), non-compliance is strictly isolated to that specific batch, not affecting unrelated, separately stored batches.

  • With broad physical separation, the impact of a negative DDS is limited to the affected segment (e.g., a specific shipment or PO).

  • With no physical separation (e.g., commingled stock), a single negative DDS can "contaminate" the entire commingled stock, meaning all outbound products from that stock must be treated as non-compliant. Prewave’s Quantity Accounting Module enables detailed linking between outbound and inbound DDS via various identifiers (product IDs, serial numbers, timestamps, quantities, PO numbers), supporting precise impact assessment in case of non-compliant DDS. This suggests the ability to block usage would depend on the level of traceability and physical separation implemented, potentially allowing for blocking specific batches or quantities based on your system's granularity.

If goods were bought compliantly from a parent company, can we use the original DDS or must they issue a new one?

A DDS can be reused for subsequent transactions with the same supplier and product. This suggests that if the mother group company has a valid and compliant DDS for the goods, it may be reusable. However, the EUDR mandates that the operator placing the product on the market is responsible for its compliance and must establish and implement their own Due Diligence System, which includes the ability to provide Due Diligence Statements.

How does the integration with the EU TRACES system work?

Prewave can act as an authorized representative for the customer and its entities, provided a valid mandate is in place.

Prewave is directly integrated with the EU TRACES system and supports automated creation, modification, and submission of Due Diligence Statements (DDS). Through seamless API integration with the EU TRACES system, Prewave can submit DDS on behalf of the customer, ensuring efficient and compliant reporting. Before generating a DDS in TRACES, all provided information can be reviewed for accuracy. DDS numbers and verification numbers can be transferred back to customer systems through the API.

  • DDS provided by suppliers are automatically checked against TRACES

  • The outbound module links due diligence statements received for efficient management of outbound products

  • Prewave's end-to-end solution allows complete risk assessment of producers and plots where the supplier is not generating DDS

  • The supplier engagement module can be used for receiving reference numbers from suppliers

If a DDS is issued: what information is automatically sent back to internal systems? Can you share the detailed API existing?

Important to note: The API Integration to any customer chosen system is an add-on feature. Please talk to your Customer Success advisor for more information.

Prewave provides a REST API endpoint to programmatically retrieve DDS (Due Diligence Statement) information for a specific product once it has been successfully submitted to TRACES.

Endpoint:

GET /public/v2/eudr/products/{productId}/customer-dds

Once a DDS is validated and accepted, the response includes:

  • Reference Number (from TRACES)

  • Verification Number (from TRACES)

  • Product details: HS code, net weight, quantity

  • Geolocation & origin information: Country, producer, plot data, coordinates

  • DDS metadata: Date, status, operator type, activity type

  • Linked references: e.g., Purchase Orders

  • Submission feedback: Errors or status messages, if any.

This API enables automated retrieval of DDS data for integration with internal systems, including customs clearance, reporting, or audit trail purposes.

For full technical documentation, please refer to: dev.prewave.com

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