EUDR DDS Consolidation: How to Simplify Declarations Without Losing Compliance

EUDR DDS consolidation helps businesses streamline declaration management, reduce administrative complexity, and improve supply chain efficiency while maintaining the traceability, due diligence evidence, and regulatory controls required under the EU Deforestation Regulation (EUDR). For businesses sourcing EUDR-regulated products such as coffee, cocoa, rubber, soy, palm oil and wood, managing Due Diligence Statements (DDS) can become complex as supplier, plot and shipment volumes grow. EUDR DDS consolidation can mean organising data from multiple sources for a correctly scoped declaration, or grouping declarations already submitted under Article 8a of the Information System rules.

These are different activities. A larger declaration is not automatically compliant, and grouping does not remove due diligence obligations.

Key Takeaways

• Simplify DDS Management: EUDR DDS consolidation can help reduce administrative complexity and streamline declaration workflows.
• Understand Consolidation Rules: Know when declarations can be grouped or consolidated and ensure the applicable EUDR requirements are met.
• Maintain Traceability: Keep supplier information, product details, geolocation data, and supporting evidence accurate and accessible.
• Preserve Compliance Evidence: Consolidation should not compromise due diligence, risk assessment, or the ability to demonstrate compliance.
• Improve Operational Efficiency: Standardised data and digital workflows can reduce manual effort, minimise errors, and improve coordination across supply chains.
• Use Technology Strategically: EUDR compliance software can help manage supplier data, organise evidence, and streamline DDS-related processes.

What Is EUDR DDS Consolidation?

Operationally, consolidation can mean bringing supplier, production-area, commodity, quantity and evidence data into one controlled workflow. Whether multiple sources can be covered by a single DDS depends on the transaction and applicable requirements. The declaration must accurately represent the products placed on the EU market or exported, with due diligence completed for all sources covered.

Article 8a is a separate capability: users can submit a new DDS or simplified declaration referencing previously submitted declarations by their reference numbers or identifiers. The originals receive a grouped status, and the grouped declaration represents them for EUDR compliance purposes. This manages references; it does not fix incomplete data or bypass due diligence.

What Changed Under Article 8a?

Commission Implementing Regulation (EU) 2026/1565, adopted on 13 July 2026, introduced Article 8a to the EUDR Information System rules. The change addresses technical constraints associated with declaration files and aims to reduce disruption to customs procedures.

Under Article 8a, an Information System user can group previously submitted DDS or simplified declarations by creating a new declaration that references them. The grouping is available for declarations submitted by the same Information System user, or, where applicable, for the same operator or micro or small primary operator by an authorised representative. Once grouped, the original declarations are marked accordingly in the system, and the grouped declaration’s reference number or identifier can be communicated in place of the individual references for the purposes specified in the regulation.

The grouped declaration must still be complete in its own right. Official Information System API documentation explains that the group head must state the relevant products, quantities, HS codes and other required data that reflect what is actually being placed on the market or exported. The system does not automatically reconcile all product and quantity information from the referenced declarations, so operators remain responsible for the accuracy of the group head.

Explore how to streamline compliance processes, manage due diligence requirements, and prepare your supply chain for EUDR implementation.

Read our guide to EUDR simplification requirements and stay prepared for regulatory changes.

When Should Businesses Consider Consolidation or Grouping?

Consider a coffee exporter working with several cooperatives and hundreds of farm plots. The exporter needs to connect supplier records and plot-level geolocation to the coffee lots, processing batches and export consignment. A structured data workflow can bring those records together for a correctly scoped DDS, provided all relevant information and due diligence requirements are satisfied.

Now consider a business that has already submitted several declarations and needs a simpler way to communicate their references. Article 8a grouping may help by creating a grouped declaration that references those prior submissions. This can be useful for high-volume operations, but the grouped declaration still needs accurate product and quantity details, and the referenced records must be tracked carefully.

Ask: “Does this declaration accurately represent the transaction, and can we retrieve evidence for every product and source it covers?”

A Practical EUDR DDS Consolidation Workflow

• 1. Map the transaction. Identify the operator responsible for the declaration, the relevant products, quantities, shipment or consignment, and the supplier and production-area relationships.
• 2. Validate supplier and plot data. Check supplier identities, required geolocation, product information and supporting evidence. Flag missing, inconsistent or invalid coordinates before declaration preparation.
• 3. Complete due diligence. Assess deforestation-free status and legality using appropriate evidence, document risk conclusions and carry out mitigation where required. Consolidation or grouping does not replace these steps.
• 4. Reconcile products and quantities. Match declared products, HS codes and quantities to the actual goods being placed on the market or exported. Keep links between incoming materials, processing batches, finished products and shipments.
• 5. Choose the right declaration action. Prepare a DDS that accurately covers the relevant transaction, or use Article 8a to group previously submitted declarations when the conditions for grouping are met. Do not treat the two actions as interchangeable.
• 6. Track references and status. Maintain a register of individual and grouped declaration references, declaration identifiers, product and shipment links, submission status and supporting records. Because declarations used as references for grouping cannot simply be amended or withdrawn after being used in a grouping, build review and approval controls into the process.
• 7. Retain an audit trail. Keep the evidence and records that support due diligence and make them retrievable for internal reviews, business partners and competent authorities.

How EUDR Software Supports Consolidation

Spreadsheets and email become difficult to manage across hundreds of suppliers, thousands of plots and multiple shipments. An EUDR platform can connect supplier onboarding, geolocation validation, risk assessment, evidence, batch traceability and declaration references.

Look for pre-submission validation, quantity reconciliation, source-to-product links, status tracking and quick evidence retrieval. Procurement, ERP and logistics integrations can reduce duplicate entry, while approval workflows help catch errors.

TraceX connects supplier and farm data, geolocation, traceability, risk and evidence with products, batches and shipments. This can reduce manual reconciliation and improve visibility, while regulatory responsibility remains with the operator.

Explore TraceX EUDR Solutions

Conclusion: Make Declaration Management Scalable

EUDR DDS consolidation works best when efficiency is built on trustworthy data. Article 8a provides a formal way to group eligible submitted declarations, while a well-designed workflow connects each DDS to the products and sources it represents.

Frequently Asked Questions