Overview
When your supplier receives a Product Origin Request (POR) from Prewave, they are asked to provide information about the origin of the products they supply to you. Depending on their situation, they will select one of 3 possibilities given by Prewave, including 4 scenarios to respond to the request.
This article explains each scenario, what it means for your compliance process, and what you will see in the Prewave platform as a result. It also provides background on the three key supply chain roles defined under the EUDR: the First Importer (upstream operator), the First Downstream Operator, and the Downstream Operator.
Understanding Your Role in the EUDR Supply Chain
The EUDR distinguishes between two main categories of company:
Upstream operators, who are responsible for exercising due diligence before placing relevant products on the EU market
Downstream operators and Traders, whose obligations focus on maintaining traceability for products already covered by due diligence exercised upstream.
Understanding which role applies to you is the first step in determining your EUDR obligations.
First Importer (Upstream Operator)
A first importer is a company that places a relevant product listed in Annex I of the EUDR on the EU market for the first time, typically by importing it from a third country under the customs procedure 'release for free circulation'. This makes them an upstream operator under the Regulation (Art. 2(15) EUDR).
Key obligations
Exercise full due diligence before placing the product on the EU market or exporting it (Art. 4(1)).
Submit a Due Diligence Statement (DDS) to the EU Information System (TRACES) prior to import, including geolocation data for all plots where the relevant commodity was produced (Art. 4(2), Annex II).
Include the DDS reference number in the customs declaration for 'release for free circulation'.
Assume full responsibility for the compliance of relevant products with Article 3 — i.e., that they are deforestation-free and produced in accordance with the relevant legislation of the country of production (Art. 4(3)).
Communicate the DDS reference number to the first downstream operator or trader in the supply chain (Art. 4(7)).
Notify competent authorities and inform downstream operators if new information suggests products may be non-compliant (Art. 4(5)).
Keep records of all DDS for five years from the date of submission.
💡 Note on multiple shipments
A single DDS can cover multiple batches or shipments from the same origin for up to one year, provided due diligence has been carried out for all intended quantities and all geolocations have been declared (Art. 4(4)).
How this connects to the Prewave POR
When Prewave sends a Product Origin Request to a first importer, they will typically respond by referencing an existing DDS already submitted to TRACES (Scenario 1 below), or by providing geolocation and production information directly (Scenario 2 below).
First Downstream Operator
A first downstream operator is a company that places relevant products on the EU market where those products are made entirely from other relevant products already covered by a valid DDS or simplified declaration. They are the first entity in the supply chain after the upstream operator (Art. 2(15b) EUDR).
Importantly, a company that imports relevant products from a third country and places them on the EU market for the first time is always an upstream operator, not a downstream operator — even if those products are made from other relevant products. This is because the products are not yet covered by a DDS at the point of import.
Key obligations
Does NOT need to exercise due diligence or submit a DDS — this responsibility lies with the upstream operator.
Non-SMEs must register in the EU Information System prior to placing or making relevant products available on the market or exporting them (Art. 5(2)).
Must collect and keep DDS reference numbers (or simplified declaration identifiers) received from their upstream suppliers (Art. 5(3)(a)).
Must notify the relevant competent authority if they become aware of information suggesting non-compliance risk (Art. 5(5)).
Non-SMEs must verify that due diligence was exercised if there are substantiated concerns about a product's compliance before placing it on the market (Art. 5(6)).
💡 SME vs non-SME
SME first downstream operators have reduced obligations: they are not required to register in the Information System or verify due diligence in case of substantiated concerns. However, they are still required to collect and keep DDS reference numbers or declaration identifiers, and notify authorities of potential non-compliance.
Note on the one-time simplified declaration: This is not an obligation for downstream operators. It is issued by a specific subcategory of upstream operator called a Micro or Small Primary Operator (MSPO) — a small producer in a low-risk country who grows or harvests the product themselves. Instead of submitting a full DDS, an MSPO submits a one-time simplified declaration and receives a declaration identifier. When a first downstream operator sources products from an MSPO, they must collect and keep that declaration identifier (not a DDS reference number).
How this connects to the Prewave POR
A first downstream operator receiving a POR will typically respond using Scenario 1 (providing the DDS reference number from their upstream supplier) or Scenario 3 (if the product or supplier is out of EUDR scope).
Downstream Operator (Subsequent)
A subsequent downstream operator is any company further along the supply chain that places or makes available relevant products already covered by a DDS on the EU market — after the first downstream operator has already handled them.
Key obligations
Does NOT need to exercise due diligence or submit a DDS.
Non-SMEs must register in the EU Information System (Art. 5(2)).
Must collect and keep basic traceability information: details of their suppliers and the downstream operators or traders to whom they have supplied relevant products (Art. 5(3)(4)).
Must notify the relevant competent authority if they become aware of information suggesting non-compliance risk (Art. 5(5)).
Non-SMEs must verify due diligence was exercised if substantiated concerns arise (Art. 5(6)).
In practice, subsequent downstream operators generally already hold most of this information as part of their regular business operations.
💡 Key difference from the first downstream operator
Unlike the first downstream operator, subsequent downstream operators are not required to collect and keep DDS reference numbers specifically. They only need to maintain basic supplier and customer traceability records.
How this connects to the Prewave POR
A subsequent downstream operator will typically respond to a POR using Scenario 3, sub-case 3.1f ('Product delivered by a downstream operator'), which does not require further documentation. Alternatively, they may use Scenario 1 if a DDS reference is available from their own upstream supplier.
How the Product Origin Request Works
Once a POR is sent, your supplier receives an email and logs in to the Prewave Supplier Portal to respond. Based on their product and supply chain situation, they choose the scenario that best applies for that specific product. Each scenario leads to a different status visible on your Customer Platform.
💡 Tip
The POR remains open until all quantities specified in the request have been accounted for. Once fully answered, the POR is automatically closed.
Scenarios available
We offer 3 Scenarios to answer Product Origin Requests:
Scenario 1: Data Ready
Scenario 2: Out of Scope (Exemptions)
Scenario 3: Data Pending
Below you can find further details on which scenario to chose based on the product and data available.
Scenario 1 - Data Ready
The supplier selects this option in case they are:
the primary operator
a direct non-EU supplier and can provide specific coordination of production.
The supplier can choose how to submit the data available among these 3 categories:
Upload a Due Diligence Statement
(Simplified) One-time Declaration
Geolocation Entry
Option 1: Upload a Due Diligence Statement
If the product is covered by a DDS, the supplier provides the DDS information and verification number.
Prewave verifies via API call to TRACES if the DDS provided exists in TRACES and if this has a valid status.
If valid, the DDS is available to TRACES and the Supplier DDS is displayed on the Customer Platform.
If the DDS is rejected, the supplier is requested to provide an active DDS. Information is rejected and the supplier is requested to provide accurate data.
Platform status: The Supplier DDS is shown on the Customer Platform.
Option 2: (Simplified) One-time Declaration
Not available yet. We are waiting for the EU to implement the one time declaration workflow.
Option 3: Geolocation Entry
If the product is not covered by a DDS and geolocations/production information of the origins are required, the supplier is asked to provide this information on the product.
The supplier provides geolocation and production information according to the requirements and geoJASON formatting required by the regulation.
If the supplier does not have this information, the request can be forwarded to the supplier’s own supplier/producer. The process is forwarded until the entity with the required information is identified.
The request is completed with the required information and submitted. The Origins are now displayed on the Customer Platform.
Once origins are submitted and available and the quantity requested has been fully provided, the process proceeds to Phase 4 (Deforestation Checks) and Phase 5 (Legality Assessment).
Platform status: Origins displayed — once all quantities are accounted for and data has passed validation.
Scenario 2 - Out of Scope (Exemptions)
If the product is not EUDR-relevant or in case the supplier is a downstream operator, the supplier must select one of the following exemption reasons:
Available sub-cases
Description | TARIC Code |
Product is entirely made of recycled goods | Y133 |
Product composition not subject to the Regulation | Y129 |
Product was produced before June 29, 2023 | Y132 |
Product delivered by a micro or small-sized enterprise | Y141 |
Product made of a commodity placed on EU market during transitional period | C716 |
Product delivered by a downstream operator (no further info required) | — |
Other | — |
For exemption claims, the supplier is asked to describe the case and upload evidence in one of the following formats: .pdf, .doc, .docx.
The regulation does not provide specific examples of what constitutes as evidence but the suppliers can access the following evidence guidance.
Platform Status: Once exemption reason, comment and evidence is uploaded, the product is marked as rejected (displaying the respective TARIC code) on the Customer Platform.
Scenario 3 - Data Pending
This scenario applies when a supplier acknowledges they cannot yet provide the required documentation, but intends to do so at a later date.
Available reasons
A legally binding DDS is not planned before 2027, in line with the company's strategy.
Lack of information from upstream suppliers due to insufficient supply chain transparency.
Product complexity: full traceability across the supply chain is not currently feasible.
Other (free-text field for additional context).
In all cases above the supplier is asked to select the expected submission date for compliant documentation.
The POR remains open and can still be answered by the supplier.
Platform status: Delayed — the expected submission date provided by the supplier is displayed.
Summary of Platform Statuses
Scenario | Platform Status |
Scenario 1 — DDS verified in EU TRACES | Supplier DDS displayed |
Scenario 2 — Geolocation and production data provided | Origins displayed |
Scenario 3 — Product exempt or out of scope | Rejected (with TARIC code or Exemption code) |
Scenario 4 — Evidence not yet available | Delayed |
POR sent but not yet answered by the supplier | Requested |