Hi Oliver,

Here is my take on the matter:

• • By definition, a EUDR product made of a relevant EUDR commodity can’t be placed on the EU market without a DDS. There is no specific exemption for returns in the legislation. Thus, as soon as a returned item is replaced on the market a DDS needs to be available for the product.
    • Some regulatory context:
    • A similar question was placed in the FAQs asking what would happen if information can’t be gathered from a supplier. The answer to FAQ 1.27 was the following: “If an operator (or trader that is not an SME) placing a commodity on the EU market is unable to obtain the information required by the Regulation from its suppliers, they must refrain from placing the relevant products on the EU market or exporting them from the EU as that would result in a violation of the Regulation.”
    • Another question in the FAQs (5.4) asked about re-importing products (even as part of a return) to which the answer was: “Where an operator (or trader that is not an SME) re-imports a product that was previously exported and places it under the customs procedure ‘release for free circulation’, the same obligations apply as if the product was placed for the first time on the EU market. When exported, the relevant product loses its customs status of ‘Union good’ and that relevant product is considered to be a new product when subsequently re-placed or re-made available on the EU market. Already existing due diligence statements can help the operator to exercise due diligence.”

With all this in mind, if you can’t link a returned product to a DDS, you cannot place it on the market since you do not have the required information for the EUDR and if you decide to proceed regardless, you are violating the regulation and could be subject to penalties. Thus, you should ensure traceability on product level through, e.g. improved internal traceability and return management process with product specific identifiers, to be able to trace back returns to the original product

Great question — returns and reverse logistics are a grey area under the EUDR and not yet covered in detail by official guidance. But based on the regulation’s logic and industry best practices, here’s a structured answer you can use in the discussion forum:

How to handle EUDR for Return Processes?

Returns (e.g., damaged goods, wrong delivery, excess material) create special challenges in EUDR compliance, especially when products were already placed on the EU market and now flow back into the supply chain.

1. Returns that are destroyed or scrapped

• If a returned item is destroyed, recycled, or scrapped, no further DDS action is needed.
• The original DDS remains valid, and no new DDS is created.
• Best Practice: Keep internal documentation (credit note, scrap report) as audit trail.

2. Returns that are resold or reused

If the returned product (e.g., melamine-faced fibreboard) is still functional and will be resold, then:

• It is considered placed on the market again.
• → A new DDS must be submitted, referencing the original DDS and material traceability.

Example:

A customer returns 100 m² of fibreboard due to overstock. You verify the material and resell it to another customer → create a new DDS (even if raw material data stays the same).

3. Internal transfers or returns between sites

• If goods are returned from a customer site to another site within the same legal entity for internal use or reprocessing, no DDS is needed, unless the product is again placed on the market.

4. Returned material used in new production (e.g., remanufacturing)

• If returned goods are reprocessed or used in new manufacturing, then:
  • Treat them like new input material.
  • Track their origin (if possible).
  • Create a new DDS for the output product with reference to both the returned material and new inputs.

Documentation Tip

Keep a returns ledger linked to:

• Original invoice & DDS
• Reason for return
• Internal inspection outcome
• Follow-up action (scrap, resale, reuse)
• New DDS (if applicable)

Open points (awaiting further guidance)

• What happens if the return crosses an EU border (e.g., export → return from outside EU)?
• Are returns tracked differently under the Operator vs. Trader status?

Until further clarification from the EU Commission, it’s recommended to follow a risk-based and traceability-first approach.

Summary (TL;DR)

Return Scenario                              DDS Required?                                          Notes

Destroyed/scrapped                                  No                                       Keep internal record

Resold to another customer                       Yes                                     Create new DDS, reference original batch + quantities

Returned between internal sites                   No                                    Unless product is resold again

Returned material used in new product       Yes                                  Treat as input, include in new DDS for final product