EUDR DDS: content, submission and retention of the due diligence statement

In brief

• Who produces it: any operator that first places a relevant product on the Union market or exports it.
• What it is not: it does not replace the due diligence process; it formalises its outcome.
• What must be kept: the statement, the information collected and the evidence of risk assessment and risk mitigation.

This guide details the expected content (Annex II), submission in TRACES, transmission of the number and the retention rules.

What is an EUDR DDS and who must produce it?

The EUDR (European Union Deforestation Regulation) refers to Regulation (EU) 2023/1115; in French it is also called the RDUE (the French acronym for the European regulation on deforestation and forest degradation). It aims to prevent products linked to deforestation or forest degradation from entering or leaving the Union market.

Who must produce it?

• The operator: any natural or legal person who, in the course of a commercial activity, first places a relevant product on the Union market or exports it. The operator bears responsibility for compliance and submits the DDS.
• The downstream operator: places on the market products already covered by a DDS. It does not submit a new one, but keeps for five years the information passed on by its supplier, including the DDS number.
• The trader: any person in the supply chain, other than an operator or a downstream operator, who makes relevant products available on the market.

The scope covers seven commodities - coffee, cocoa, rubber, palm oil, soya, cattle and wood - as well as the derived products listed in Annex I to the Regulation, identified by their customs nomenclature code.

Due diligence and DDS: the process and its proof

Many teams confuse the two. Due diligence is a system: a set of procedures and measures. The DDS is the document certifying that this system worked for a given product, at a given time.

Due diligence definition: three steps, one objective

A due diligence system applies before any import, export or first placing on the market, and follows three steps:

1. Information collection: description and quantity of the products, country of production, geolocation of the plots of land, suppliers, evidence of legality and of deforestation-free status.
2. Risk assessment: assessment of the risk of non-compliance against the Regulation's criteria (country of origin, presence of forests and indigenous peoples, complexity of the supply chain, reliability of the information, etc.).
3. Risk mitigation: proportionate measures to reduce the risk to a negligible level, unless it is already zero or negligible.

The system must be reviewed at least once a year, and updated in the event of any significant change.

The definition of due diligence in the Regulation

The definition of due diligence adopted in the European text covers all the procedures the operator implements to ensure that its products are deforestation-free and legally produced. In other words, due diligence is the “how”, and the DDS is the “what” that is submitted.

Comparison: due diligence process and DDS

“Prior to placing relevant products on the market or exporting them, operators shall exercise due diligence with regard to all relevant products.”Regulation (EU) 2023/1115, Article 8(1) · consolidated text, EUR-Lex

What goes into a DDS? The Annex II information

The Regulation provides a single template, identical for all sectors: Annex II for the due diligence statement, Annex III for the simplified declaration. In practice, the statement is entered in the information system, where the fields are guided.

The expected content includes:

• Operator identification: name and address, as well as the EORI number (Economic Operators Registration and Identification) where the product enters or leaves the Union market.
• Product description: Harmonised System (HS) code, description, trade name and, for wood, the common name of the species and its full scientific name.
• Quantity: expressed in kilograms of net mass and, where applicable, in the supplementary unit set for the HS code concerned.
• Origin: country of production and geolocation of all plots of land where the commodities were produced, with the time of production. For products derived from cattle, the geolocation covers the establishments where the cattle were kept.
• Reference to an existing DDS: only where the operator relies on a previous statement, in the cases provided for by the Regulation.
• The statement itself: the wording by which the operator confirms that due diligence has been exercised and that no risk, or only a negligible risk, was found, signed in the required format.

Simplified declaration or full statement: what are the differences?

The simplified declaration is intended for a specific category of players: micro or small primary operators (MSPOs). An MSPO must cumulatively be a micro or small enterprise (or a natural person), be established in a country classified as low risk, and both produce its products and place them on the market itself.

Two related notions must not be confused:

• The simplified declaration is a submission scheme reserved for MSPOs.
• Simplified due diligence lightens the process, not the statement: if all commodities come exclusively from countries or regions classified as low risk and the risk of circumvention or mixing is negligible, risk assessment and risk mitigation may be dispensed with. Information collection and retention of evidence remain mandatory - and the operator must revert to the full process if it obtains information to the contrary.

A “standard” SME (small and medium-sized enterprise) that is not a primary operator established in a low-risk country therefore cannot simply rely on a simplified declaration.

Submitting the DDS in TRACES and obtaining the reference number

Submission takes place in the EUDR information system, a module of the European Commission's TRACES platform - often referred to on the IT side as “TRACES EUDR” or “EUDR-IS”. This system operates on the basis of Implementing Regulation (EU) 2024/3084, as amended by Implementing Regulation (EU) 2026/1565.

The steps:

1. Create an account in the information system (the production environment, which is the one with legal value).
2. Enter the origin: plots drawn on the map, coordinates entered one by one or imported in bulk via a GeoJSON-type file.
3. Describe the products: type, HS code, description, quantity.
4. Complete the Annex II information, including the reference of any existing DDS.
5. Submit the statement, then retrieve the reference number, generated automatically by the system after validation.

Do not confuse this reference number with a free internal reference you choose to file your statements, or with any verification number: these are three distinct identifiers.

Using an authorised representative

In accordance with Article 6 of the Regulation, an operator may appoint an authorised representative established in the Union to submit the DDS on its behalf. This appointment must be formalised in a mandate. The authorised representative under the EUDR must not be confused with the customs representative, who does not perform the same function.

Passing on the reference number: who, when, how

A submitted DDS is not enough: it must be passed along.

• The operator passes on to its first customer - downstream operator or trader - the due diligence statement number corresponding to the products sold.
• It adds its main identification details: name, registered name or trade mark, postal address, email address and, where applicable, website address.
• Subsequent downstream operators and traders in turn pass on their identification details, but are not required to pass on the DDS number to their own customers.
• The first operators and downstream traders keep for five years the information passed on by the first entity placing the product on the market, including the DDS number.

On the customs side: for imports and exports, the DDS reference number (or the simplified declaration identifier) must appear in the customs declaration under document code C716 - C717 for MSPO simplified declarations. A single DDS may cover several shipments as long as the declared quantity has not been used up.

Keeping the DDS and its evidence: the five-year obligation

The retention obligation is a classic audit point. Due diligence documents must be kept for five years from the date on which the product is placed on the market or exported.

Retention does not only concern the DDS:

• the information gathered during the collection step, including geolocation;
• the risk assessment and its justification;
• the mitigation measures applied and their results;
• internal procedures and their updates - the system being reviewed at least once a year;
• the information passed on by suppliers, including the DDS number received.

These items must be available to the competent authority on request. Scattered storage - shared folders, emails, isolated spreadsheets - makes this slow and fragile. Our EUDR audit checklist details the evidence to gather.

In addition, large operators are subject to a public reporting obligation on their due diligence system.

Linking the DDS to lots and internal documents

The DDS lives at the level of the product and the declared quantity, not automatically at the level of the physical lot moving through your logistics. It is up to you to make the link.

Good linking practices:

• One DDS may cover several lots or shipments: track the quantity covered and submit a new DDS when the volume is used up.
• Associate the DDS number with the relevant purchase orders, advance shipping notices, production lots and product sheets, including in your ERP (Enterprise Resource Planning) system.
• Keep proof of transmission: the number sent to the first customer, the date and the channel.
• Group supplier documentation (declarations, certificates, geolocation information) in the same place as the DDS so you can rebuild the file in the event of an inspection.
• Set up a checkpoint at goods receipt: without a valid DDS number, the lot enters a zone of regulatory uncertainty.

This is precisely where the difference lies between “theoretical” compliance and compliance that can be demonstrated in a few minutes.

Common mistakes to avoid

1. Confusing the process with the statement: believing that having collected documents amounts to a submitted DDS.
2. Submitting after placing on the market: the DDS must precede placing on the market and, for imports/exports, the customs declaration.
3. Underestimating geolocation: incomplete coordinates, missing plots, untraced mixing of sources.
4. Confusing identifiers: DDS reference number, internal reference and verification number are not interchangeable.
5. Forgetting to pass on the number to the first customer, or not keeping a record of it.
6. Thinking the simplified declaration is open to everyone: it is reserved for MSPOs.
7. Not reviewing the system every year, or not updating it when new information arises.
8. Discovering an error after submission without knowing how to correct the statement concerned.
9. Not linking the DDS to lots in the ERP, making downstream traceability impossible.
10. Keeping evidence unconnected to the statement, at the risk of being unable to respond to a request from the authorities.

Operational DDS checklist

• Before each placing on the market
• Are the product and its HS code listed in Annex I to the Regulation?
• Is the country of production identified, with its risk classification?
• Has the geolocation of all plots of land been collected and verified?
• Has the company's role been settled: operator, downstream operator or trader?
• Is simplified due diligence justified, and documented as such?
• Was the DDS or the simplified declaration submitted before placing on the market?
• Has the reference number been retrieved and checked?
• Has this number been passed on to the first customer with your identification details?
• Does the number appear in the customs declaration (C716 or C717) where applicable?
• Is the DDS linked to lots, orders and product sheets in the ERP?
• Is the evidence kept for five years and accessible on request?
• Is the due diligence system reviewed at least once a year?

Key takeaways

The DDS is not just another administrative document: it is the point at which your due diligence becomes enforceable. Three decisions to take now:

1. Map who in your organisation submits the DDS, for which flow and at what point in the purchase-to-sale cycle.
2. Make the content reliable: geolocation, HS codes, quantities and the reference of any existing DDS.
3. Industrialise traceability: reference number passed on to the first customer, linked to lots and kept for five years, with its supporting documents.

To place the DDS within the overall framework - scope, roles and obligations by player -, rely on the complete guide to EUDR compliance. As supplier information, statements and deadlines multiply, centralising this supplier and product data in a single platform makes it possible to prepare and retrieve a DDS without rebuilding a file by hand: that is the role Tracklab plays. The next useful step is to check, on your last ten imported lots, that a DDS number exists, that it is linked to the right product and that it is kept in the right place.