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.
Scenario 1 — The Product is Covered by a Due Diligence Statement (DDS)
Primary Downstream Operator Case
This scenario applies when your supplier's product is already covered by an existing Due Diligence Statement (DDS) submitted to the EU TRACES system.
What the supplier does
The supplier provides the DDS reference number and the corresponding verification number.
What happens next
Prewave automatically fetches the DDS status from the EU TRACES system via API to verify that it exists and is active.
If the DDS is found and active → the supplier's DDS is displayed on your platform and the POR is resolved.
If the DDS is not found or is inactive → the submission is rejected, and the supplier is asked to provide a valid, active DDS number.
Platform status: Supplier DDS displayed
When to expect this: Suppliers who have received a DDS reference number from their upstream supplier or who have submitted their own DDS as first importers.
Scenario 2 — The Product is Not Covered by a DDS: Geolocation and Production Information Required
Primary Operator Case
This scenario applies when the product is not yet covered by a DDS, and raw material geolocation and production information needs to be collected directly. This is the typical path for first importers (upstream operators) who are responsible for conducting their own due diligence.
What the supplier does
If yes (2.1a): The supplier provides geolocation coordinates and production information directly in the portal.
If no (2.1b): The supplier forwards the request to their own upstream supplier or producer. This continues until the entity that holds the information is reached.
Sanity checks
Once information is submitted, Prewave runs automatic checks to verify the data meets EU technical requirements. If data fails these checks, the POR remains open and the supplier cannot submit the origins.
Platform status: Origins displayed — once all quantities are accounted for and data has passed validation.
When to expect this: Direct producers or first-tier suppliers / importers who have direct access to origin-level data and have not yet submitted a DDS to TRACES.
Scenario 3 — The Product is Not EUDR-Relevant or the Supplier is Out of Scope
Downstream Operator Case
This scenario covers situations where the product or the supplier is exempt from EUDR requirements.
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 | — |
Evidence review
If the evidence is accepted → the POR is marked as Rejected and the applicable TARIC exemption code is displayed on your platform.
If the evidence does not pass → the supplier is prevented from submitting the Product Origin request.
Platform status: Rejected — the applicable TARIC exemption code or Exemption reason is displayed alongside the entry.
Scenario 4 — Currently Unable to Submit the Required Evidence
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).
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 |