What a Due Diligence Statement Actually Is
A DDS is a formal declaration, submitted per shipment (or batch), by the "operator" placing a regulated commodity on the EU market for the first time. It confirms that due diligence has been carried out and that the product is both legally produced and deforestation-free — meaning the land it came from wasn't deforested or degraded after December 31, 2020. Without a valid DDS, the shipment doesn't clear.
Step-by-Step: Filing Your DDS
Confirm whether you're the "operator"
EUDR distinguishes between an operator (placing goods on the EU market or exporting them for the first time) and a trader (making already-placed goods available further down the chain). If you're downstream and your supplier already filed a DDS for the batch, you may only need to reference their DDS number rather than filing a new one.
Collect geolocation data
You need the GPS coordinates of every plot of land where the commodity was produced — a single point for plots under 4 hectares, a polygon for larger ones. A regional or county-level pin isn't sufficient; it has to identify the actual production area.
Establish the deforestation-free cutoff
You need to show the land had the same forest status (or was already non-forest) as of December 31, 2020, and wasn't deforested or degraded afterward. In practice, most operators verify this with a satellite imagery cross-check against that date rather than relying on paperwork alone.
Gather legal production documentation
Proof the commodity was produced legally under the laws of the country of production — land tenure, harvest or production permits, and relevant tax, labor, and environmental compliance records, depending on the commodity.
Run the risk assessment
Assess factors including the country or region's official risk classification (the EU rates countries low, standard, or high risk), how prevalent deforestation is in the sourcing area, supply chain complexity, your supplier's compliance history, and any documented concerns such as land tenure disputes or indigenous land rights.
Apply risk mitigation measures if needed
If your assessment doesn't come back as negligible risk, you're required to take further mitigation steps — independent surveys, third-party audits, more precise geolocation, or additional supplier engagement — before you can conclude the risk is negligible and proceed.
Compile the statement
A complete DDS includes: operator identification, the commodity and its HS code, quantity, country of production, geolocation data, supplier information, your risk assessment conclusion, and any mitigation measures applied.
Submit through the EU Information System
DDS submissions are filed electronically through the EU's dedicated Information System for the EUDR, which now runs as a module inside TRACES, the EU's existing trade-control platform.
Get your reference and verification numbers
Once submitted, you receive a DDS reference number and a verification number. This pair is what travels with the shipment and what customs authorities and downstream buyers actually check.
Pass it down the chain — or reference it
If you're a downstream trader making the same batch available further along the chain, you reference the existing DDS number instead of filing a duplicate statement for the same product.
Keep records for 5 years
Operators and competent authorities are required to retain DDS-related records for at least five years, available for inspection on request.
Deadlines You're Working Against
- Large and medium companies: compliant by December 30, 2026
- Micro and small companies: compliant by June 30, 2027
Common Mistakes That Get DDS Statements Rejected
- Using a regional or county-level pin instead of exact plot-level geolocation
- Referencing a supplier's DDS number that has since been withdrawn or corrected
- Treating the December 31, 2020 cutoff as "when I bought it" instead of "when the land was last forested"
- Submitting the checklist without the underlying risk assessment narrative behind it
FAQ
Do I need a new DDS for every shipment?
Generally yes, per shipment or batch — though periodic aggregation is possible for a regular, established supply relationship with the same origin, subject to your competent authority's conditions.
What if my supplier already filed one?
Reference their DDS reference number instead of duplicating it, if you're a downstream trader making the same product available rather than the operator placing it on the market for the first time.
Can I file if my company is outside the EU?
Yes. Non-EU operators placing goods onto the EU market file through the same system as EU-based operators — there's no separate process for exporters.