EUDR: What to do when the Information System is down
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📌 ESG researcher Rosaida Brahim summarizes the latest EUDR publication: the Information System Contingency Arrangement.
On November 9, 2026, the EU Commission published The Contingency Arrangement for Unplanned Unavailability of the EUDR Information System. This article summarizes the arrangement and what resources businesses should consult in case of prolonged issues.
What is the Information System?
The Information System is a module on the European Commission's TRACES NT platform dedicated to the EU Deforestation Regulation (EUDR).
We recently published an article, "All you need to know about TRACES before your EUDR deadline", giving an overview of what the platform does, who needs to register and what steps they have to take to successfully start using the platform.
A quick refresher for the purpose of this article: the Information System is where Upstream Operators will submit Due Diligence Statements (DDS) and Simplified Declarations (SD), and where the rest of the EUDR supply chain can collect the reference numbers of these documents.
This means The Information System a core component in making sure EUDR compliance and monitoring runs smoothly. It also means that, if the platform ever encounters issues, the flow of trade can be severely impacted.
To minimize the fallout of such a scenario, the European Commission has published The Contingency Arrangement for Unplanned Unavailability of the EUDR Information System. This document provides strict instructions on the measures to be followed if the platform becomes unavailable after the EUDR implementation deadline of 30 December 2026.
When does the Contingency Arrangement come into play?
The measures outlined in the Contingency Arrangement can only be taken if both of the following circumstances are met:
| i) | If the unplanned unavailability of the Information System takes longer than 60 minutes |
| Emphasis is placed on unplanned unavailability; the contingency measures are NOT valid if the platform is down for scheduled maintenance. | |
| ii) | If the duration is confirmed on the Public Status Page |
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The Commission has developed a Public Status Page for the EUDR. If this page indicates that the Information System has been unexpectedly unavailable for 60 minutes or more, then the Contingency Measures can be taken. |
The Public Status Page is currently under construction, but when it goes live it will indicate if the Information System is unexpectedly unavailable, and it will give specific time data. It will also let users know what Contingency Measures they're expected to take. It will also let users know when the Information System is back online.
Contingency Reference Numbers and Contingency Declaration Identifiers
Just because the Information System is down does not mean that EUDR compliance is given a wave.
If you have to enter a product on the domestic market, or lodge a customs declaration for import or export, you need a reference number. If you couldn't get a reference number before the Information System went down, and the Public Status Page has confirmed that the unavailability was unexpected and has been going on for over 60 minutes, you can use a Contingency Reference Number or a Contingency Declaration Identifier.
The Contingency Reference Number or Contingency Declaration are clearly different from DDS and SD Reference Numbers.
In this scenario, not only would you have to keep all the same documentation as you would for a regular DDS or SD, but you'd also have to keep evidence that the Contingency Measures were justified.
After the issues with the Information System have been resolved, and the Public Status Page indicates that everything is back in working order, there is no need to retrospectively submit a DDS or SD for shipments that were already placed on the market or exported using a Contingency Reference Number or Contingency Declaration Identifier. However, any shipment placed on the market or exported after the system is back online must be covered by a standard DDS or SD.
How MasterSustainability.today can help you navigate issues with the Information System
MasterSustainability.today supports organizations in the digitization of their EUDR process, from data collection and supply-chain collaboration to audit preparation and submission to the Information System.
Your company will still have to register with TRACES, but after you've given us authorization we will be able to submit all the data necessary for a successful DDS or SD.
The European Commission has set up a protocol that ultimately adds another layer of documentation to your EUDR compliance.
By streamlining your compliance process with MasterSustainability.today you mitigate the risk of incomplete or incompatible data, giving you the space to focus on the beautiful aspects of ESG management.
Interested in our EUDR solution? Check out our brochure.