EUDR Due Diligence Statement: A Step-by-Step Checklist for UK Businesses Selling into the EU

The EUDR due diligence statement (DDS) is filed in the EU Information System by the operator, the business that first places a relevant product on the EU market or exports it, before that happens. It must contain the operator's details and EORI number, the HS code, description and quantity of the goods, the country of production and the geolocation of every plot, a standard compliance declaration and a signature. Traders and downstream operators do not file one. For a UK business, the first question is therefore not what to write, but who writes it.

This guide covers the EU Deforestation Regulation only, using the sources indexed in the EUDR knowledge base. It does not deal with any UK domestic rules.

Who files: operator, downstream operator or trader?

Regulation (EU) 2025/2650 reshaped the roles in December 2025. The consolidated EUDR now distinguishes four actors, and the Commission guidance of 20 July 2026 stresses that the role is assessed for each product:

• Operator (Article 2(15)): places relevant products on the EU market for the first time, or exports them. Files the DDS.
• Micro or small primary operator (Article 2(15a)): a natural person or micro/small undertaking established in a low-risk country, selling what it has itself grown, harvested or raised there. Files a one-time simplified declaration instead.
• Downstream operator (Article 2(15b)): places on the market or exports products made from products already covered by a DDS or simplified declaration. No DDS.
• Trader (Article 2(17)): anyone else in the chain making products available on the EU market. No DDS.

For goods coming from outside the EU, the guidance identifies the operator as, generally, the person acting as importer in the customs declaration for release for free circulation, independently of ownership changes or contractual arrangements. Products held under other customs procedures, such as customs warehousing or transit, are not placed on the market.

Before the form: the due diligence behind it

Article 4(1) requires due diligence under Article 8 before placing on the market: information gathering (Article 9), risk assessment (Article 10) and risk mitigation (Article 11). Only where everything was produced in low-risk countries, and supply-chain complexity and the risk of mixing or circumvention have been assessed, can an operator skip the Article 10 and 11 steps (Article 13). The United Kingdom appears on the low-risk list in Implementing Regulation (EU) 2025/1093; what matters, though, is the country of production of the commodity, not where the seller is based.

If due diligence reveals a non-negligible risk, or cannot be completed, Article 4(4) forbids placing the goods on the market. The DDS is only the confirmation that this exercise found no or only negligible risk.

The checklist: Annex II, section by section

Identity

• Operator's name and address.
• EORI number for goods entering or leaving the EU market, as established under Article 9 of Regulation (EU) No 952/2013 (Annex II, point 1). The validation rules make it compulsory for IMPORT and EXPORT.

Product

• HS code and a free-text description including the trade name.
• Full scientific name where applicable, which for wood means every species (with the common name, under Article 9(1)(a)).
• Quantity: for imports and exports, kilograms of net mass plus the Combined Nomenclature supplementary unit where applicable; in other cases net mass with a percentage estimate or deviation, or volume or number of items.

Origin

• Country of production.
• Geolocation of every plot where the commodities were produced; for cattle, every establishment where the animals were kept. Plots above four hectares (other than cattle) need polygons.

Declaration and signature

• The fixed text confirming that due diligence under Regulation (EU) 2023/1115 was carried out and that no or only a negligible risk was found of non-compliance with Article 3, point (a) or (b) (Annex II, point 5).
• Signature: "Signed for and on behalf of: Date: Name and function: Signature:" (point 6).

You will notice there is no point 4: Regulation (EU) 2025/2650 deleted it.

Validation rules that cause rejected statements

The Commission's Information System validation rules apply to both the web interface and the API. Check these before submitting:

1. Activity type selected, compatible with your user profile, and not changed on amendment.
2. EORI present (and valid if an authorised representative is completing the operator's details).
3. Between 1 and 100 commodities, each described, each with at least one positive quantity; net mass for IMPORT or EXPORT.
4. Supplementary unit type given whenever a supplementary unit value is.
5. Valid country for every production place; street and number whenever a producer postal address is used.
6. At least one scientific/common name pair for timber (maximum 500).
7. Referenced statements must exist with status Available or Archived (maximum 2,000; no self-reference).
8. Geolocation data no larger than 25 MB per statement.

After submission: reference numbers, customs and records

Each DDS receives a reference number (Article 33(2)(b)). The operator passes it to downstream operators and traders (Article 4(7)), and it must be made available to customs before release for free circulation or export; the person lodging the customs declaration provides it (Article 26(4)). Keep the statement for five years from submission (Article 4(3)).

If your UK business is a trader or downstream operator for EU sales, Article 5(3) still requires you to collect and keep, for at least five years, the name, address, email and (if available) website of your suppliers and of your business customers, plus the DDS reference numbers or declaration identifiers where your supplier is an operator. Non-SME downstream operators and traders must also register in the Information System before trading (Article 5(2)).

Four mistakes to avoid on a first filing

• Reading "low risk" as "no paperwork": the guidance is explicit that all operators, including those using simplified due diligence, must meet the Article 9 information requirements.
• Describing the brand, not the commodity: Article 9(1)(a) asks for the list of relevant commodities or products contained in the product. For a chocolate bar, the guidance limits this to the cocoa products it contains (cocoa powder and cocoa butter), not the palm oil also in the recipe, because chocolate is listed under cocoa in Annex I.
• Assuming certification replaces due diligence: the guidance says certification and third-party schemes can feed the risk assessment but do not create a "green lane"; mass-balance and mixed-origin chains of custody are not acceptable under the EUDR.
• Forgetting the annual review: Article 12(2) requires every operator to review its due diligence system at least once a year and keep records of updates for five years.

Timing: the obligations apply from 30 December 2026, and from 30 June 2027 for operators established as micro or small undertakings by 31 December 2024. For borderline cases, put the question to the EUDR base, for instance: "Is an EORI number mandatory for a company submitting a due diligence statement for imports?"