What is an EUDR due diligence statement?

September 12, 2025
8
min read
Key takeaways:
  • The DDS is the legal declaration proving EUDR due diligence was carried out.
  • It must include product details and the geolocation data 
  • Operators and non-SME traders must file a DDS via TRACES before market access.
  • Coolset’s EUDR solution streamlines DDS preparation with audit-ready, TRACES-compatible submissions.

What is a due diligence statement under the EUDR?

The Due Diligence Statement (DDS) is the formal declaration every operator or trader 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.

Compliance deadlines:

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

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?

The obligation falls on operators (importers, manufacturers, and exporters) as well as non-SME traders, who are treated as operators under the regulation. SME traders are exempt from filing themselves but must be able to provide references to the DDS submitted by their upstream suppliers when requested.

When must the DDS be filed?

The DDS must be filed before the product is placed on the EU market or exported outside of it. The first compliance deadlines are 30 December 2025 for large and medium-sized companies and 30 June 2026 for SMEs.

Can SMEs avoid submitting a DDS?

Yes. SME traders are not required to submit their own DDS through TRACES. However, they must collect and retain their suppliers’ DDS reference numbers (or equivalent verification info) and keep supplier details for at least five years, to be provided to authorities if requested.

For SME operators (those importing or placing products on the EU market) due diligence must be carried out, and a DDS submitted via TRACES unless an upstream DDS already exists. In that case, they may rely on the existing DDS reference instead of submitting a new one.

Watch our webinar - Submitting your due diligence statement

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

Updated on March 24, 2025 - This article reflects the latest EU Omnibus regulatory changes and is accurate as of March 24, 2025. Its content has been reviewed to provide the most up-to-date guidance on ESG reporting in Europe.

Updated on July 25, 2025 - This article references a previous version of the EUDR country risk benchmarking system. On July 9, the European Parliament rejected the proposed classification. We are actively monitoring the latest developments. For the most up-to-date guidance, read our updated article on the EUDR benchmarking vote. In the meantime, assume full due diligence applies across all regions.

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