EUDR Due Diligence: Requirements, Steps and DDS Filing

EUDR due diligence is the legally required process an operator must complete before placing regulated commodities such as coffee, cocoa, soy, palm oil, timber, rubber and cattle on the EU market. It means collecting plot-level geolocation data, proving no deforestation occurred after 31 December 2020, gathering legal production documents, assessing risk, and filing a Due Diligence Statement (DDS) in the EU Information System. Without a valid DDS reference number, goods cannot legally enter the EU.

Key Takeaways

• EUDR due diligence is more than submitting a DDS.
• Start with product and scope assessment.
• Collect complete Article 9 information
• Geolocation is a core EUDR requirement.
• Conduct a documented risk assessment under Article 10.
• Mitigate non-negligible risks under Article 11.
• Maintain an evidence trail.
• Connect source data to the physical product.
• DDS filing is the regulatory submission step.
• The DDS is the output of the due-diligence process, not the complete compliance record.
• Reference and verification numbers should be connected to the shipment/product records.
• Transitional products need separate treatment.
• Digital systems can reduce manual compliance work.

What is EUDR due diligence?

EUDR due diligence is the structured legal process by which an operator proves that a commodity placed on the EU market is deforestation-free, legally produced and traceable to the exact plot of land where it was grown. Under the EU Deforestation Regulation it is not a voluntary best practice, it is the condition for market access.

This is a shift from traditional sustainability reporting. Voluntary certificates and self-declarations are no longer enough on their own. EUDR due diligence is data-driven and tied directly to customs clearance: an operator must provide verified GPS coordinates, satellite deforestation evidence, legal land documentation and a filed DDS. A single missing data point can hold a shipment at the border.

EUDR due diligence in 5 steps

Every compliant DDS is built from the same five steps. Complete them in order for each shipment.

1. Collect geolocation data as GPS points or polygons for every production plot, in GeoJSON format.
2. Prove no deforestation after 31 December 2020 using time-stamped satellite evidence.
3. Gather legal production documents covering land tenure, permits and supplier identity.
4. Assess and mitigate risk under Articles 10 and 11 until residual risk is negligible.
5. Submit the Due Diligence Statement in the EU Information System and obtain the DDS reference number.

The 5 core components in detail

Most shipment rejections trace back to a gap in one of these five areas. Build your workflow around each.

1. What geolocation data does EUDR require?

Geolocation is the technical foundation of every DDS. You must record either a GPS point or a mapped polygon boundary for each production plot in your supply chain.

• Polygon boundaries, not just single points, are required for most production systems.
• Each plot is mapped individually, including in smallholder aggregation models.
• GeoJSON is the required format for submission to the EU Information System.
• Incomplete or inaccurate coordinates are the leading cause of DDS rejections.

Related reading: EUDR geolocation requirements explained.

2. How do you prove no deforestation after 2020?

You must confirm the land used to grow the commodity was not deforested after the 31 December 2020 cut-off.

• Reference satellite data from JRC, Global Forest Watch or Hansen datasets.
• Use time-stamped analysis showing no forest-cover change after the cut-off.
• Expect EU buyers to ask for third-party verification before accepting a DDS.
• High-risk countries face stricter verification and more frequent audits.

3. What legal documentation is needed?

EUDR requires proof that the commodity was legally produced, not only deforestation-free. That means documenting land rights, permits and supplier identity.

• Land tenure certificates or customary land-rights documentation per supplier.
• Harvest permits and agricultural licences where applicable.
• Business or cooperative registration records, and supplier KYC indexed by supplier ID.
• Note: certifications such as Rainforest Alliance or FSC are supporting evidence only, not a substitute for due diligence.

Related reading: EUDR legality requirements explained.

4. How does the EUDR risk assessment work?

Operators sourcing from standard or high-risk countries must conduct a documented risk assessment under Article 10 and record mitigation under Article 11.

• Assess deforestation risk, legality risk and supply-chain transparency risk.
• Document mitigation: supplier audits, monitoring, field checks and certifications.
• The final residual risk must be classified as negligible before you file.
• Low-risk country classification enables simplified due diligence procedures.

Understand how EUDR country risk classification works, what the three risk categories mean, and how businesses should incorporate country risk into their due diligence and supplier risk assessment process.

→ Read Our Guide: EUDR Country Risk Classification

5. How do you submit the DDS?

Once data is collected and verified, you submit a formal Due Diligence Statement in the EU Information System before goods enter the market.

• The DDS is tied to a specific shipment and references all underlying compliance data.
• A DDS reference number is issued and is required before goods clear customs.
• Records must be retained and audit-ready for at least 5 years.

Understand how to build an effective EUDR due diligence workflow that connects supplier onboarding, source-level traceability, risk assessment, evidence management, and DDS preparation.

→ Read Our Guide: EUDR Due Diligence Workflow

A worked EUDR DDS example

Here is what the core of a completed Due Diligence Statement looks like for a single coffee shipment. Use it as a reference for the fields you will need to populate.

Who must complete EUDR due diligence? Operators vs traders

Operators, the companies that first place a regulated commodity on the EU market or export it from the EU, carry the full legal obligation to perform due diligence and submit the DDS. Under the simplification package, only the first operator placing a product on the market submits the DDS; downstream operators and traders pass on the reference number and keep their own traceability records. Non-EU exporters are affected too, because EU importers cannot comply without plot-level data from upstream partners.

Learn how upstream operators fit into the EUDR framework, what information they need to provide, and how businesses can build a connected due diligence process across suppliers and source locations.

→ Read Our Guide: EUDR Upstream Operators

Operators: full due diligence and DDS submission

• An EU importer bringing in coffee, cocoa, soy or rubber.
• A manufacturer producing chocolate, furniture or leather goods for EU sale.
• An exporter shipping timber or rubber from the EU to another country.

Traders and downstream operators: reference tracking

• A wholesaler distributing pre-packaged coffee or cocoa within the EU.
• A retailer sourcing certified cocoa ingredients for repackaging.

They register in the system and maintain traceability through DDS reference identifiers, rather than filing a separate DDS.

What happens if you fail EUDR due diligence?

Non-compliance carries direct operational consequences, not just reputational risk.

Shipment rejection at the EU border

A container arriving with an incomplete or missing DDS is held at customs. Even one missing polygon or invalid coordinate can trigger a hold, and demurrage, spoilage and rebooking costs compound quickly.

Financial penalties and investigations

Authorities can impose fines of up to 4% of an operator’s annual EU turnover for negligent due diligence. Persistent non-compliance can lead to temporary bans and full supply-chain audits.

Loss of market access and reputation

EU buyers now embed EUDR requirements in purchase orders. Operators that cannot produce a valid DDS on demand risk losing contracts to compliant competitors, and failed traceability audits are increasingly read as a greenwashing signal.

EUDR due diligence deadlines in 2026 and 2027

The December 2025 amendment and the May 2026 simplification package confirmed the timeline rather than resetting it. The simplification package is estimated to cut annual compliance costs by around 75% versus the original 2023 estimates, but the core obligations and dates below are unchanged.

A July 2026 delegated act also refined the product scope (for example soluble coffee and certain palm oil derivatives were added, while leather and retreaded tyres were removed). Check whether your specific derived products are in scope before you file.

How technology simplifies EUDR due diligence

Prepared manually, a single DDS can take days to weeks: collecting supplier data, validating geolocation, running satellite checks, compiling legal documents and formatting for submission. EUDR Solutions from TraceX reduces this to minutes.

Frequently asked questions