What is an EUDR due diligence statement? (Updated Dec 2025)

December 5, 2025
8
min read

Disclaimer: Latest EUDR developments

On 21 October, the European Commission proposed targeted changes to the EU Deforestation Regulation (EUDR). These adjustments aim to make the rollout smoother without changing the regulation’s overall goals.

Key points from the proposal:

  • The 30 December 2025 compliance deadline for large and medium operators remains unchanged.
  • Small and micro primary producers (such as farmers and foresters) may receive an extension until 30 December 2026.
  • A transition period from January to June 2026 is planned for large and medium companies, giving them time to adapt before formal checks and penalties begin.
  • New, simplified obligations are introduced for two groups: small and micro primary producers, and downstream operators (e.g. manufacturers, retailers).

We're closely monitoring the development and will update our content accordingly. In the meantime, read the full explainer here.

Key takeaways:
  • A DDS is required before placing or exporting EUDR-regulated products.
  • It must include product details and the geolocation data 
  • Common errors include missing geolocation, wrong HS codes, or late submissions - these can block shipments.
  • Coolset helps you prepare, validate, and submit DDSs with confidence - automating data collection, risk checks, and EU-compliant formatting.

What is a due diligence statement under the EUDR?

The Due Diligence Statement (DDS) is the formal declaration operators or traders must file under the EU Deforestation Regulation (EUDR) before placing, making available or exporting regulated goods on the EU market. It is the official proof point that all required checks have been completed and that the company stands behind its compliance.

By submitting a DDS, a company confirms that:

  • Due diligence has been carried out in accordance with Articles 9-11 of the regulation.
  • The risk of deforestation, forest degradation, or illegality in the supply chain is assessed as no more than negligible.
  • The operator or trader takes full legal responsibility for the accuracy of the assessment and the products being placed on the market.

In other words, the DDS is the final step of the due diligence process: without it, products in scope of the regulation cannot legally enter or exit the EU market. It acts as both a compliance safeguard and a legal commitment, making it one of the most important obligations for companies trading in EUDR-regulated goods.

What information must a DDS contain?

Every DDS must include specific information required under Annex II of Regulation (EU) 2023/1115. This ensures that authorities can trace products back to their origin and verify that no deforestation or illegality is linked to the supply chain.

The DDS must cover:

  • Product information: Harmonised System (HS) or Combined Nomenclature (CN) codes, as well as the common and scientific names (optional and only for wood) of the commodity or product, and the quantity being traded.
  • Country of production: The country (or countries) where the commodity was grown, harvested, or produced.
  • Geolocation data: Exact coordinates for all plots of land where production took place:
    • As point data if the plot is smaller than 4 hectares.
    • As polygon data if the plot is 4 hectares or larger.
  • Production dates: The time window of harvest or production to verify compliance with the cut-off date.
  • Contact details: Name and contact details of the operator or non-SME traders.
  • Reference number(s): For operators referring to an existing due diligence statement, the reference number(s) of such due diligence statement(s)

All of this information is consolidated into a single digital declaration, which becomes the official DDS submitted to the EU system.

Who is responsible for submitting the DDS and when?

The duty to submit a DDS depends on the company’s role in the supply chain and its size:

  • Operators (importers, manufacturers, exporters) must submit a DDS before placing products on the EU market or exporting them.
  • Non-SME traders are treated as operators and therefore required to file a DDS.
  • SME traders are exempt from filing themselves, but must keep records of the DDS provided by their suppliers.

Currently binding deadlines:

  • Large and medium-sized companies: 30 December 2025
  • SMEs: 30 June 2026

Important: In November 2025, the European Parliament backed a delay of EUDR deadlines to 30 December 2026 for large and medium operators and 30 June 2027 for small and micro operators. The proposal also removes DDS obligations for non-SME traders and redefines downstream responsibilities. These updates are not yet legally binding. Final confirmation is expected after trilogue negotiations. Until then, current deadlines and roles remain in force.

In all cases, the DDS must be filed before the product enters or leaves the EU market.

How do companies submit a DDS in practice?

The European Commission requires DDS submission through the TRACES platform, the official EU certification system.

Steps:

  1. Register with TRACES (Information System for EUDR).
  2. Enter shipment details, HS/CN codes, and quantities.
  3. Upload the geolocation.
  4. Confirm negligible risk.
  5. Submit and receive a DDS reference number and a verification number.

This reference number must be attached to customs declarations and shared with downstream customers.

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What are common mistakes when preparing a DDS?

Companies frequently run into problems when preparing their DDS. Here are some of the most common pitfalls to be aware of:

  • Incomplete geolocation data: For example, missing or inaccurate polygon files for plots over 4 hectares.
  • Incorrect HS codes: Misreporting product codes from Annex I, which can lead to false or invalid declarations.
  • Poor record-keeping: Not versioning or updating files, making it difficult to trace changes or prove compliance during audits.
  • Late submission: Filing the DDS too close to shipment, which can trigger customs delays or outright rejection.

Avoiding these mistakes requires a structured compliance process with audit-ready documentation at every step.

How Coolset helps companies prepare compliant DDS submissions

To overcome the common pitfalls in due diligence, many companies are moving away from manual processes and adopting dedicated EUDR software

Coolset’s platform is designed to make DDS preparation both faster and more reliable. It brings supplier data, such as geolocation coordinates, legal documents, and production records, into a single system, automatically checking for gaps or risks before a statement is filed.

Instead of relying on spreadsheets or scattered email trails, sustainability teams can work within one platform that generates an audit-ready DDS, complete with version control, digital signatures, and integration with TRACES so submissions meet EU format requirements. 

Records are retained for five years, giving companies confidence that they can respond to inspections at any time.

With this structured approach, teams spend less time chasing information and more time ensuring their products meet compliance standards (without the risk of shipment delays or blocked customs clearance).

Download our Due Diligence Statement guide for step-by-step support.

FAQ - Due diligence statement under EUDR

Still have questions about how the DDS works in practice? Below we answer the most common points companies raise when preparing for EUDR compliance.

What is a due diligence statement under the EUDR?

A Due Diligence Statement (DDS) is the formal legal declaration required under the EU Deforestation Regulation (Regulation (EU) 2023/1115). It must be submitted via the TRACES system before regulated products can be placed on or exported from the EU market. 

By submitting a DDS, the company confirms that the goods are deforestation-free, legally produced, and that the risk of non-compliance has been assessed as no more than negligible.

What information must a DDS contain?

According to Annex II of the regulation, a DDS must include:

  • Product details, including HS/CN codes, scientific (optional and only for wood) and common names, and quantities.
  • Country of production and geolocation data for all plots of land, provided as point or polygon data depending on size.
  • Proof that the land has not been subject to deforestation after 31 December 2020.

Who must submit a DDS?

Under the currently binding regulation, the obligation to submit EUDR due diligence statementfalls on operators (importers, manufacturers, and exporters) as well as non-SME traders, who are treated as operators under the regulation.

Note: In November 2025, the European Parliament proposed removing DDS obligations for non-SME traders and narrowing responsibilities for downstream actors. Under this proposal, only operators placing products on the EU market would be required to submit a DDS. These changes are not yet legally binding. A final decision is expected after trilogue negotiations. Until then, the current rules and obligations remain in force.

When must the DDS be filed?

The DDS must be filed in TRACES before placing products on or exporting them from the EU market. Current legal deadlines are 30 Dec 2025 (large/medium companies) and 30 June 2026 (SMEs). A 12-month delay has been proposed but is not yet law. Until adopted, current deadlines remain in force.

Watch our webinar - Submitting your due diligence statement

An Introduction to TRACES, DDS submissions, changing compliance procedures and more.

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