Due Diligence Statement EUDR: The Complete Guide to Filing, Requirements & Compliance in 2026

A Due Diligence Statement (DDS) under EUDR is a mandatory digital declaration that operators importers, exporters, and manufacturers must submit via the EU TRACES system before placing regulated commodities (cocoa, coffee, soy, palm oil, timber, cattle, rubber) on the EU market. It must include: (1) plot-level geolocation data (GeoJSON polygon for plots ≥4 ha), (2) proof the land was not deforested after December 31, 2020, (3) supplier and HS code details, (4) a documented risk assessment rated as ‘negligible risk,’ and (5) a signed legal compliance statement. Without a valid DDS reference number, shipments are legally blocked at EU customs. Deadline: December 30, 2026 for large operators.

Due diligence statement EUDR compliance is now a legal prerequisite for any company placing regulated commodities on the EU market. Under Regulation (EU) 2023/1115 the EU Deforestation Regulation operators who fail to submit a valid DDS before shipment face blocked imports, fines, and reputational damage. This guide breaks down exactly what the due diligence statement requires, how to file it correctly through EU TRACES, and how TraceX automates the entire process.

Experience smarter compliance with TraceX. Start your free trial today and see how our AI-powered platform simplifies traceability, supplier collaboration, and regulatory compliance.

Key Takeaways

• A due diligence statement EUDR is legally binding not a voluntary ESG report

• Non-compliance penalties can reach 4% of your annual EU turnover

• Incomplete geolocation is the #1 cause of DDS rejection

• Manual filing via spreadsheets will not scale automation is essential

• Both importers (large/medium) and SME operators face hard compliance deadlines in 2026–2027

Due Diligence Statement EUDR: What It Is and Why It Matters

A due diligence statement EUDR (DDS) is a legally binding digital declaration submitted through the EU TRACES system (Trade Control and Expert System) confirming that a regulated commodity is deforestation-free, legally produced, and fully traceable to the plot of land where it was grown.

The DDS is not an ESG report or a sustainability pledge. It is an enforceable regulatory requirement under Article 9 of EUDR, with named executive accountability and submission before goods can legally enter the EU market.

Due Diligence Statement EUDR: Who Must File

• Non-SME operators (importers, manufacturers, exporters of regulated commodities): Full DDS per shipment — Deadline: December 30, 2026
• Small and micro primary operators: Simplified declarations — Deadline: June 30, 2027
• Downstream operators/traders: No separate DDS required but must register in EU TRACES and pass DDS reference identifiers down the chain
• SME traders: Exempt from filing but must retain DDS reference records from upstream suppliers

A DDS can cover multiple shipments ONLY if they all trace to the same declared quantity, geolocated plots, and verified supply chain. If your supply chain changes mid-season, a new DDS is required.

EUDR compliance starts with due diligence.

Read our blog: “EUDR Due Diligence Explained: A Practical Guide for Businesses.”

Due Diligence Statement EUDR: 7 Mandatory Elements You Cannot Skip

According to Annex II of Regulation (EU) 2023/1115, every due diligence statement EUDR submission must contain the following verified data. Missing even one element can trigger rejection and shipment blockage at EU customs.

Due Diligence Statement EUDR Element 1: Operator Identification

• Legal entity name, address, and country of registration
• EORI number (EU customs identification)
• ISO country code
• Named signatory (responsible senior executive) legally accountable for all claims

The named signatory requirement is not administrative. The individual who signs the DDS bears personal legal accountability for the accuracy of the underlying compliance data.

Due Diligence Statement EUDR Element 2: Product and Commodity Details

• HS/CN codes and full product description
• Scientific name (mandatory for wood and timber products)
• Declared quantity — must exactly match customs and shipping documentation
• Country of production (where the commodity was grown, not where it was exported from)

HS code misclassification is one of the most common DDS rejection triggers. Always cross-verify with your customs broker before filing. Even a single-digit error can invalidate your submission.

Unsure which HSN codes fall under the scope of EUDR?

Read our blog: “EUDR HSN Codes Explained: Understanding Product Classification Under EUDR.”

Due Diligence Statement EUDR Element 3: Geolocation Data (Highest-Stakes Requirement)

Geolocation is the most technically demanding component of a due diligence statement EUDR submission. Incomplete or inaccurate coordinates are the leading cause of DDS rejections by EU authorities.

Submitting an EUDR Due Diligence Statement (DDS)? Small errors can lead to big compliance risks.

Read our blog: “Common EUDR DDS Filing Errors and How to Avoid Them.”

Due Diligence Statement EUDR Element 4: Proof of Deforestation-Free Status

• Confirmation that land was not deforested after December 31, 2020 (EUDR cut-off date)
• Evidence from JRC Global Forest Watch or Hansen satellite datasets
• Time-stamped satellite analysis showing no forest cover change post-2020
• For high-risk countries: stronger independent verification is required

How do you determine whether your supply chain is exposed to deforestation risk?

Read our blog: “EUDR Deforestation Risk Assessment Explained: How to Identify and Mitigate Supply Chain Risks.”

Due Diligence Statement EUDR Element 5: Legal Compliance Documentation

• Proof of legal land tenure or land-use rights in country of production
• Evidence of compliance with local labor laws, human rights, and environmental regulations
• Permits, certifications, or licenses (supporting evidence — not substitutes for due diligence)

Due Diligence Statement EUDR Element 6: Risk Assessment & Mitigation

• Documented risk scoring per EUDR Article 10: deforestation risk, legality risk, supply chain transparency risk
• Mitigation measures taken where risks were identified (per EUDR Article 11)
• Final classification: residual risk must be rated ‘negligible’ to proceed

Is your EUDR risk assessment process strong enough to withstand regulatory scrutiny?

Read our blog: “EUDR Risk Assessment Explained: How to Identify and Manage Supply Chain Risks.”

Due Diligence Statement EUDR Element 7: Legal Compliance Statement (Signatory)

The formal executive sign-off confirming all EUDR Article 9 obligations have been met: geolocation verified, legality confirmed, risk assessed and mitigated. This transforms the DDS from a data form into a legally binding declaration with named accountability.

Due Diligence Statement EUDR: How to File Step-by-Step via EU TRACES

Filing a due diligence statement EUDR via the EU TRACES NT system involves six structured steps. Each step has specific data requirements and validation checks. Errors at any stage can result in rejection.

Due Diligence Statement EUDR Filing Step 1: Register on EU TRACES NT

• Create an account at the EU TRACES NT portal (traces.ec.europa.eu)
• Provide your EORI number and legal entity details
• Assign user roles: compliance lead, field data manager, signatory
• Downstream operators: register to receive and pass DDS reference numbers (no full DDS required)

Due Diligence Statement EUDR Filing Step 2: Collect and Validate Supply Chain Data

• Onboard suppliers with KYC documentation, land-use records, and GPS plot data
• Validate geolocation coordinates (GeoJSON polygon for ≥4ha plots)
• Confirm HS codes against actual commodity classification
• Ensure declared quantities match purchase orders and shipping manifests

Due Diligence Statement EUDR Filing Step 3: Run Deforestation Risk Assessment

• Screen plots against JRC and Hansen satellite datasets for post-2020 forest cover change
• Assign country-level and plot-level risk scores
• Document risk mitigation steps for any medium or high-risk findings
• Achieve a ‘negligible risk’ classification before proceeding to submission

Due Diligence Statement EUDR Filing Step 4: Generate the DDS

• Compile all 7 mandatory elements into the structured DDS format (JSON or XML required by TRACES)
• Auto-generate using a compliance platform to eliminate manual errors
• Validate all fields before submission: geolocation, HS codes, quantities, signatory details

Due Diligence Statement EUDR Filing Step 5: Submit and Obtain Reference Number

• Submit via EU TRACES NT before goods are shipped
• Obtain the DDS reference number — this is your proof of compliance for customs
• Without a valid reference number, goods are legally blocked at EU border
• Pass reference numbers to downstream traders and buyers

Due Diligence Statement EUDR Filing Step 6: Retain Records for 5 Years

• Store all supporting documentation: geolocation files, deforestation screening reports, legal docs
• Ensure records are retrievable within 24 hours for competent authority audits
• Update records if supply chain or supplier information changes

Due Diligence Statement EUDR: 5 Most Common Filing Errors (and How to Avoid Them)

Due Diligence Statement EUDR: Manual vs Automated Compliance — What the Data Shows

Manual DDS preparation can take days to weeks per shipment. Supply chains sourcing from thousands of smallholder plots face a near-impossible manual data management challenge. Automated platforms change this equation fundamentally.

Companies using autonomous compliance agentic AI solutions from TraceX can reduce DDS preparation time by 80–90% compared to manual workflows, while significantly reducing the risk of rejection due to data gaps or formatting errors.

Due Diligence Statement EUDR Compliance with TraceX: From Farm Plot to Filed DDS

TraceX EUDR Solutions is purpose-built for the operational realities of emerging-market agri supply chains smallholder farmers, low connectivity, multilingual field agents, and fragmented documentation. Here is how TraceX closes the gap between regulatory requirements and operational reality.

Due Diligence Statement EUDR Data Collection: Mobile-First Field Capture

• Offline-first mobile app for field agents to onboard smallholders in low-connectivity areas
• GPS-verified plot boundary mapping (point or polygon) synced to central system automatically
• Multilingual support for field agents across India, Africa, and Southeast Asia
• KYC documentation and land-use declarations captured digitally at source

Due Diligence Statement EUDR Risk Assessment: AI-Backed Satellite Screening

• Integrated satellite imagery from JRC and Hansen datasets
• Automatic plot screening against December 31, 2020 deforestation cut-off
• Risk engine mapped to EUDR Article 9 and 10 obligations
• Auto-generated risk scores with mitigation workflow for high-risk plots

Due Diligence Statement EUDR Generation: Auto-Fill and Validate

• Rule-based auto-generation of DDS forms from verified supply chain data
• Pre-submission validation: geolocation, HS codes, quantities, signatory, all checked
• DDS generated in EU-compliant JSON/XML format no manual conversion required
• Blockchain timestamping for all compliance records (5-year audit trail)

Due Diligence Statement EUDR Submission: Direct TRACES API Integration

• Direct API connection to EU TRACES NT portal
• One-click DDS submission no manual login, no file format conversion
• Instant DDS reference number retrieval upon successful submission
• Reference number distribution to downstream buyers and traders

Due Diligence Statement EUDR Deadlines and Penalties: What’s at Stake in 2026

Due Diligence Statement EUDR Non-Compliance Penalties

• Fines up to 4% of total annual EU turnover
• Shipment seizure and destruction at EU entry points
• Exclusion from EU public procurement contracts
• Public naming of non-compliant operators by competent authorities
• Criminal liability in severe or repeat cases

Deadline Reality Check

December 30, 2026 is less than 6 months away. Onboarding thousands of smallholder suppliers, mapping plot boundaries, running satellite screening, and building a TRACES-ready workflow cannot be done in the final weeks. Companies that start now will file confidently. Companies that wait will face blocked shipments.

Frequently Asked Questions (FAQ’s)