EUDR and customs: what is code C716 and when does the obligation arise, at purchase or at clearance?

Short answer: for imports, the EUDR obligation arises at release for free circulation, not at purchase: the due diligence statement must be submitted, and its reference number available, before the customs declaration is lodged. C716 is the TARIC document code under which the declarant enters that reference number. If the goods go into customs warehousing, inward processing or transit, they have not yet been placed on the market and the obligation is not yet triggered.

When does the obligation arise: at purchase or at customs clearance?

At clearance. Regulation (EU) 2023/1115 defines "placing on the market" as the first making available of a product on the EU market (Art. 2(16)). For an imported product, that happens when it is declared for the release for free circulation procedure and intended for the market (Art. 2(38)). The Commission's guidance is unequivocal: "only products released for free circulation by customs are considered placed on the Union market" (Guidance C/2026/3896, section 1).

The purchase does not count. Signing an FOB contract at origin or paying for the goods triggers nothing. According to the guidance, for imports the definition of operator "is independent of the change of ownership of the product and of other contractual arrangements".
Who the operator is: as a general rule, the person listed as importer in the customs declaration (data element 13 04 000 000). How to tell whether you are an operator or a downstream operator is explained in this other answer.
Own use included: importing for your own use, for example office furniture, is also placing on the market (FAQ 2.10, example 4).
Practical deadline: the due diligence statement is submitted and the reference number obtained before the customs declaration is lodged (Art. 26(4) and FAQ 5.20, version 5).

For products produced within the EU, placing on the market happens when the product exists, there is a supply agreement with another person and, if there is physical delivery, loading begins (FAQ 5.20).

What is code C716 and who declares it?

C716 is the TARIC document code for the due diligence statement. The declarant uses it to tell customs that the statement exists and enters its reference number. Art. 26(4) of the Regulation requires "the person lodging the customs declaration" to make that number available to customs before release or export. In practice, the customs representative enters it using the details provided by the operator.

One due diligence statement can be used for several customs declarations, and one customs declaration can carry several numbers (FAQ 5.20). If the operator has grouped statements, the number of the grouped statement is entered.

Which TARIC codes does the EUDR use?

DG TAXUD updated the codes in its Revision 1 of the TARIC document of 23 September 2026, to reflect Regulation (EU) 2025/2650 and Delegated Regulation (EU) 2026/2102.

Code	When it is used
C716	Reference number of the due diligence statement (import or export)
C717	Identifier of the simplified declaration of a micro or small primary operator (Art. 4a). Note: until September 2026 this code had a different meaning, now repealed
C718	Export or re-import of a product placed on the EU market during the transitional period, with the conventional number 99EU9999999999 (FAQ 9.2)
C720 / C725	Re-import by a non-SME / SME downstream operator, with the number received from the supplier or the conventional 22EU2222222222 (FAQ 5.4)
Y196 / Y188	Export by a non-SME / SME downstream operator, without a reference number
Y129	"Ex" code in Annex I: the specific goods are out of scope
Y132	Product produced before 29 June 2023 (Art. 1(2))
Y133	Recycled, used or second-hand, waste or recovered
Y141	Operator that is a natural person or a micro or small enterprise established by 31-12-2024, until 29-6-2027. Not valid for products listed in the annex of the former EU Timber Regulation
Y142	Non-commercial activity
Y187 / Y190 / Y191	Samples and testing / packaging / medicinal products and marketing material, only under the codes where Annex I provides for it

If a statement is required, is not provided and no exemption applies, TARIC provides that the import or export is not allowed. TAXUD has defined measures 776 (import) and 777 (export) for the EUDR (Revision 1, 23-9-2026). Before declaring, check in the TARIC consultation that they already appear against your CN code. MITECO, Spain's Ministry for the Ecological Transition, has reminded operators that misusing these codes could lead to penalties under Ley Orgánica 12/1995 de Represión del Contrabando, Spain's law on smuggling offences. Its note refers to "Y718"; the correct code, according to TAXUD, is C718.

What happens under customs warehousing, inward processing or transit?

Procedure	Does it trigger the EUDR?	When the obligation arises
Release for free circulation	Yes	Before the customs declaration is lodged
Customs warehousing	Not while in the warehouse	When it leaves the warehouse released for free circulation
Inward processing	Not while the procedure lasts	If the product is later released for free circulation; if it is re-exported, it does not apply
Transit / temporary admission	No	Only if it is later released for free circulation
Export	Yes	Before the export declaration is lodged
Re-export (Art. 270 UCC)	No	The goods were never Union goods

Sources: Guidance C/2026/3896, section 1 ("customs warehousing, inward processing, temporary admission, transit" are not placing on the market; re-export falls outside the scope) and FAQ 5.5. The table applies the general rule: the obligation arises when the product is released for free circulation.

And for exports?

The EUDR also applies to goods leaving the EU under the export procedure (Art. 2(37) and 2(39)). An exporter is one of two things (FAQ 5.6.1):

Operator, if the product had not previously been placed on the EU market: for example, an EU producer exporting its own wood or a farmer exporting its animals. It needs a due diligence statement and declares its number with C716 (or the identifier with C717, if it is a micro or small primary operator).
Downstream operator, if someone else already placed the product on the market, or it was made from products already covered: for example, a company that buys green coffee in the EU and exports it, or a manufacturer exporting chocolate made from imported cocoa. It does not provide a reference number (Art. 26(4), last sentence) and uses Y196 (non-SME) or Y188 (SME).

You do not need a statement per destination country: an export statement does not state the destination (FAQ 7.20).

Frequently asked questions

If I buy at origin before 30 December 2026, am I exempt?

No. What counts is the date of release for free circulation, not the purchase date. If you clear goods from 30 December 2026, you need a statement (unless an exemption applies, such as for products produced before 29 June 2023).

Is the freight forwarder or the customs representative the operator?

No. Logistics service providers and customs representatives are not operators if they do not place products on the market or export them (Guidance, section 2; FAQ 3.15).

Does the reference number have to appear on the invoice or delivery note?

The Regulation only requires it in the customs declaration (FAQ 7.21). It is passed on to the customer by whatever means is agreed.

Can I use C717 if I am an importing SME?

No. C717 is only for micro or small primary operators, which are producers in low-risk countries. An importing SME uses C716.

What if the EUDR Information System is down on the day of clearance?

Before 30 December 2026 the Commission must publish measures for outages of more than 60 minutes, with a contingency reference number (Implementing Regulation (EU) 2026/1565).

Keep reading: what is the EUDR: the complete guide · am I an operator or a downstream operator?.

Coolx generates the due diligence statement and delivers the reference number ready for the customs representative to enter at clearance.