How to EUDR for Returns processes?

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