EUDR Due Diligence Statement: A Step-by-Step Checklist of What to Include

An EUDR due diligence statement (DDS) is the electronic declaration an operator must submit through the EU Information System before placing cattle, cocoa, coffee, oil palm, rubber, soya or wood products on the EU market or exporting them. Annex II of Regulation (EU) 2023/1115 lists its content: operator identity and EORI number, HS code, description and quantity, country of production and plot geolocation, a fixed compliance declaration and a signature. Traders and downstream operators do not file one, but they must keep the reference numbers.

Step 1: Work out whether you are the operator

Only operators submit a DDS. Under Article 2(15) of the consolidated EUDR, an operator is any person who, in the course of a commercial activity, places relevant products on the market or exports them, excluding downstream operators. "Placing on the market" means the first making available on the EU market. The role is assessed product by product, so one company can be an operator for one product and a trader for another.

For imports, the Commission's guidance of 20 July 2026 says the operator is generally the person acting as importer in the customs declaration for release for free circulation, regardless of who owns the goods under the contract. That is the key point for US exporters: if your company is not the importer, your EU customer files the DDS and will ask you for the data. If a US company is the importer but is not established in the EU, Article 7 also makes the first EU-established person who makes the products available an operator.

The guidance's own example of a downstream operator: a chocolate maker that buys cocoa beans (HS 1801) on the EU market, already covered by a DDS, and sells chocolate bars (HS 1806). It does not file a new DDS; it keeps the upstream reference numbers.

Step 2: Do the due diligence before you write anything

A DDS is the output of due diligence, not a substitute for it. Article 8 requires three steps: collecting the information listed in Article 9, assessing risk under Article 10 and mitigating risk under Article 11. Simplified due diligence under Article 13 lets operators skip the risk assessment and mitigation steps only when everything was produced in low-risk countries and the risk of circumvention or mixing is negligible. The information collection in Article 9 applies to every operator.

• (a) description: trade name and type of product, the relevant commodities or products it contains, and for wood the common and full scientific species names;
• (b) quantity;
• (c) country of production and, where relevant, parts of it;
• (d) geolocation of all plots of land (all establishments for cattle) and the date or time range of production;
• (e) name, postal address and email of suppliers;
• (f) name, postal address and email of the businesses supplied;
• (g) adequately conclusive and verifiable information that the products are deforestation-free;
• (h) adequately conclusive and verifiable information that production complied with the relevant legislation of the country of production.

This file must be kept for five years from placing on the market or export (Article 9(1)). Under Article 4(4), you may not place goods on the market if the products are non-compliant, if due diligence revealed a non-negligible risk, or if you could not complete the process.

Step 3: Fill in the statement (Annex II checklist)

1. Operator's name and address, plus the EORI number for goods entering or leaving the EU market (Annex II, point 1).
2. Harmonized System code, free-text description including the trade name, the full scientific name where applicable, and the quantity (point 2). For imports and exports, quantity is in kilograms of net mass and, where applicable, the supplementary unit of the Combined Nomenclature; otherwise net mass with a percentage estimate or deviation, or volume or number of items.
3. Country of production and the geolocation of all plots where the commodities were produced, or all establishments for cattle (point 3).
4. The fixed declaration: "By submitting this due diligence statement the operator confirms that due diligence in accordance with Regulation (EU) 2023/1115 was carried out and that no or only a negligible risk was found that the relevant products do not comply with Article 3, point (a) or (b), of that Regulation." (point 5).
5. Signature in the format "Signed for and on behalf of / Date / Name and function / Signature" (point 6).

Point 4 of Annex II was deleted by Regulation (EU) 2025/2650, which is why the numbering jumps from 3 to 5. Geolocation has its own rules: one point for plots of up to four hectares, a polygon above that for anything other than cattle.

Step 4: Pass the Information System's validation rules

The Commission's validation rules apply to the web interface and to the API. The ones that matter most for a first filing:

• Activity type is mandatory and cannot be changed when a DDS is amended. If the operator is not from an EU country, the only allowed activity is IMPORT.
• EORI: "The operator must have an EORI identifier if the activity type IMPORT or EXPORT is selected." When an authorized representative fills in the operator, the EORI must be valid.
• At least one commodity per DDS, up to 100, each with a description.
• Quantities: at least one per commodity, all positive; net mass is mandatory for IMPORT and EXPORT. A supplementary unit value needs its unit type.
• Production places: each needs a valid country; a producer postal address needs a street and number.
• Timber: at least one scientific name and common name pair, up to 500 per commodity.
• Referenced statements: up to 2,000 per DDS, each in status Available or Archived; a DDS cannot reference itself. A commodity may omit production places when at least one DDS is referenced.
• Drafts and edits: up to 50 drafts per operator in the web interface; amending or withdrawing is possible only within a set delay, and not at all once the DDS is referenced by another one.

Step 5: After submission, pass on the reference number

The Information System assigns a reference number to each DDS (Article 33(2)(b)). Three things follow:

1. Customs: the reference number must be made available to customs before release for free circulation or export; the person lodging the customs declaration provides it (Article 26(4)).
2. Your customers: operators must pass reference numbers to downstream operators and traders (Article 4(7)), who must hold them before selling on (Article 5).
3. Your records: keep each DDS for five years from submission (Article 4(3)). By submitting it, you assume responsibility for the product's compliance.

Large operators (non-SMEs) have extra duties: a compliance officer at management level and an independent audit function (Article 11(2)), and an annual public report on their due diligence system (Article 12(3)). Every operator must review its due diligence system at least once a year (Article 12(2)).

Mistakes first-time filers make

• Assuming a US supplier can "file for" an EU importer: authorized representatives must be established in the EU (Article 2(22)), and the operator keeps responsibility (Article 6(1)).
• Treating a low-risk origin as "no due diligence": Article 9 information is still required. The United States is listed as low risk in Implementing Regulation (EU) 2025/1093, but that only opens simplified due diligence.
• Forgetting that products made from material placed on the market before the application date can fall outside the rules, provided the operator keeps evidence of that earlier placing (Commission guidance, section 3).
• Filing too late: Article 4(2) requires the DDS before placing on the market or export.

Dates to plan around: the main obligations apply from 30 December 2026, and from 30 June 2027 for operators that were micro or small undertakings by 31 December 2024 (Article 38, as amended by Regulation (EU) 2025/2650). To check your own case, ask the EUDR knowledge base a question such as "What goes into a due diligence statement besides the geolocation of the plots of land?"