EUDR grouped statements: How reference numbers move through product and batch data

The new grouping function in the EUDR Information System creates an additional reference type for supply chains. Companies will be able to combine several previously submitted due diligence statements or simplified declarations in a new submission. For placing goods on the market or exporting them, the reference of the grouped statement then replaces the collection of individual references. This is not a cosmetic change for ERP, inventory and traceability systems: they need to preserve a clear relationship between goods, original references and the current grouped reference.

The new trigger: Article 8a is already in force

Commission Implementing Regulation (EU) 2026/1565 was adopted on 13 July 2026, published in the Official Journal on 14 July and entered into force on the third day following publication. It amends the technical rules for the EUDR Information System and adds the new Article 8a on grouping. The Commission explicitly links this function to statement file-size limitations and the need to avoid disruption to customs procedures.

Grouping is narrowly defined. A user submits a new due diligence statement or simplified declaration that references earlier submissions made by the same user, or for the same operator where an authorised representative is involved. The system then marks the individual submissions as grouped and replaced. The grouped submission represents those individual statements for EUDR compliance and covers the relevant products included in them.

This does not make the earlier references irrelevant. On the contrary, they form the lineage of the grouped reference. What changes is the reference that must be communicated externally. Article 8a(3) requires the grouped statement's reference number or declaration identifier to be communicated down the supply chain and made available for customs purposes instead of the replaced individual references.

Three layers instead of one number on a product

A robust data model separates three layers. The first is the company's internal identity for the goods: product, lot, batch, delivery line or export consignment. It must remain stable independently of the EU system. The second layer contains the original EUDR statements, including their references, status, quantities and related goods. The third is the grouping that connects several originals and becomes the current compliance reference to communicate.

This separation prevents a common modelling error: using an EUDR reference as the primary identifier for a batch. An individual statement can later be grouped and therefore replaced for communication. Conversely, one grouped statement can cover products from several individual submissions. The relationship cannot reliably be treated as one-to-one.

In practice, each goods line should keep an immutable internal identifier. The system should also record which original statement covered it and which reference currently applies externally. The grouping relation needs a timestamp, responsible user and status. This allows a company to explain later why an invoice, customs declaration or delivery notice contains a different EUDR reference from the one first recorded at goods receipt.

How the reference moves through the process

Preserve the original reference at receipt

When goods are imported or purchased, the reference number or declaration identifier received from the supplier is assigned to the affected goods. The consolidated EUDR text requires operators to communicate statement references or declaration identifiers further down the supply chain. Downstream operators and traders must also collect supplier and customer information and retain it for at least five years.

The assignment should be made at the finest operationally reliable level. That may be a batch, delivery line or ring-fenced quantity. The essential point is that the business can later determine which quantity was covered by which statement. Saving one reference only against a supplier master record or an entire product is insufficient when inventory contains multiple origins and statements at the same time.

Add a new edge when statements are grouped

When grouping occurs, the original references should not be deleted or overwritten. Instead, the system adds a relation from every original statement to the new grouped statement. At the same time, it sets the grouped reference as the current reference for external communication. The historical originals remain available for audit, troubleshooting and internal quantity reconciliation.

The regulation requires the EU system to mark individual statements as grouped and replaced. Companies should mirror that status internally. Otherwise, one interface may continue sending an old individual reference even though the grouped reference already applies to the products concerned. The status change is therefore a master-data event, not a free-text note.

Resolve the current reference at dispatch

When goods are sold, exported or entered into a customs procedure, the application resolves the current communication reference from the goods line. If there is no grouping, the individual reference remains valid for this purpose. If the statement has been grouped, the grouped reference is emitted. The original chain remains accessible internally.

An event-driven pattern helps with automated processes: a successful grouping updates every affected assignment and triggers synchronisation to ERP, customs software or a partner portal. The technical pattern resembles the event-based updating of product data, although an EUDR statement and a Digital Product Passport are legally different artefacts.

Keep reference and verification numbers separate

The Implementing Regulation explicitly distinguishes the reference number from the verification number. The reference number identifies a due diligence statement. The verification number is a security number intended to provide additional protection for the data in that statement. The Information System makes both available after risk profiling; access to associated statements can require the corresponding reference and verification number.

Interfaces and databases should therefore store the values in separate fields with different access rules. The reference number is relevant to the communication required along the supply chain. The verification number is not label content and should not flow indiscriminately into invoices, QR codes or public product data. The same applies to risk status: under the new rules it is visible only to Information System actors, meaning authorities and the Commission, not to users.

API integration: prepare for status and version changes

The new Regulation requires the Commission to provide web services for submitting, managing and grouping statements. The official EUDR Information System page also warns that API specifications are being updated and tells integrators to check the CIRCABC area regularly for new versions. The Commission announcement of 13 July 2026 says further functionality will arrive later in the summer.

An integration should therefore distinguish legal effect from technical availability. Article 8a is in force, but a production client should enable grouping only after the feature is documented and tested in the access channel it uses. Versioned assignments, idempotent transmission and validation of the returned status are prudent controls. A successful HTTP call alone does not prove that all originals were marked as replaced or that the new reference reached downstream systems.

The outage path also belongs in the design. By 30 December 2026, the Commission must publish information on contingency measures for unplanned Information System outages exceeding 60 minutes. The Regulation provides for contingency reference numbers and contingency declaration identifiers. These values should not be treated as ordinary references; they need their own status and later reconciliation with the Information System.

What should be ready before application starts

The Commission identifies 30 December 2026 as the application date for large and medium-sized operators and for micro and small operators already covered by the EU Timber Regulation. Other micro and small operators follow on 30 June 2027. Before those dates, testing only the submission of a statement is not enough. The entire lifecycle matters: capture an individual reference, assign goods unambiguously, ingest a grouping, emit the current reference and retain an intelligible five-year history.

A useful acceptance test therefore begins with several receipts and individual references, groups them, and then checks the views presented to sales, export and audit processes. Operational documents must use the new grouped reference. Internal review must still reveal the individual references and quantities behind it. That dual view is what makes grouping manageable: one compact reference externally and a complete lineage internally.