EUDR due diligence is the process businesses use to gather required information, assess the risk that relevant products do not meet the EU Deforestation Regulation (EUDR), and mitigate identified risks where necessary. It requires businesses to connect product and supplier information with evidence about production origin, geolocation, legality and deforestation risk.
A Due Diligence Statement (DDS) is an important output of this process, but submitting a statement is not the same as completing due diligence. The underlying records, traceability links, risk assessment and mitigation decisions must support the declaration. This guide explains the main requirements, the end-to-end workflow, DDS examples and how digital systems can help organise the process.
Key Takeaways
- EUDR due diligence includes information collection, risk assessment and risk mitigation where necessary.
- Relevant products must be traceable to the production plots and supporting information required by the regulation.
- Geolocation, supplier records, product quantities and evidence should be connected—not stored as disconnected documents.
- The DDS is the declaration output; the records and decisions behind it remain essential.
- Digital workflows can help organise data and reviews, but do not transfer legal responsibility away from the operator.
What Is EUDR Due Diligence?
EUDR due diligence is a structured process required for relevant products placed on the EU market or exported from the EU, where applicable. Businesses need to determine whether their products and activities fall within scope, collect the required information, assess risk and take appropriate mitigation measures if risk is more than negligible.
Information can include operator and product details, quantities, country of production, production-plot geolocation, relevant production dates or time ranges, and evidence supporting deforestation-free production and legal production. The exact data set depends on the product and circumstances. Check the current regulation and official guidance for your role and product classification.
The EUDR Due Diligence Process in Five Core Stages
1. Identify products and supply chains in scope
Review relevant commodities and products, applicable product classifications, suppliers, sourcing countries and the way products move through the supply chain. Map import, export, manufacturing and trading flows that may trigger due diligence responsibilities. A scope review helps prevent teams from collecting the wrong data or overlooking products that need attention.
2. Collect supplier, product and plot information
Collect required information in a consistent format. This can include supplier and operator details, product descriptions, quantities, country of production, production plots and geolocation, production dates or time ranges, and supporting evidence. Assign ownership for each data field and define how missing or inconsistent information will be corrected.
Missing plot coordinates, incomplete production details, or disconnected supplier records can create gaps in your EUDR due diligence process.
Understand what Article 9 requires, what information you need to collect, and how to organise your data for better traceability and due diligence readiness.
Read the blog to understand EUDR Article 9 requirements and prepare your supply chain data.
3. Validate geolocation and connect traceability records
Geolocation should be linked to the correct producer, plot, commodity and production information. Validate coordinates or polygons, file structure and completeness, and identify duplicate or inconsistent plot records. Then connect source information to purchases, batches, processing records, finished products and shipments. This is especially important when materials from multiple plots are aggregated or transformed.
4. Assess risk and mitigate where necessary
Risk assessment should consider the information gathered and applicable EUDR criteria, including country context, deforestation indicators, supply-chain complexity, data reliability and evidence concerning legal production. If the assessment identifies more than negligible risk, additional information, verification, audits or other appropriate mitigation may be needed. Document the action taken, evidence reviewed and resulting decision.
5. Prepare the DDS and retain supporting records
Once the required information has been collected, risk assessed and any necessary mitigation completed, the operator can prepare and submit the applicable DDS through the EU Information System. Keep the declaration reference connected to relevant product, quantity, batch or shipment records where applicable. Retain the underlying due diligence documentation for the required period and maintain traceability links that explain the decision later.
From gathering supplier information to submitting your Due Diligence Statement (DDS) through the EU Information System, every step matters.
Learn how to file a DDS, avoid common mistakes, and streamline your EUDR due diligence workflow.
Read the blog for a step-by-step guide to filing your EUDR DDS.
EUDR Due Diligence Workflow: From Data Collection to Risk Assessment
A reliable workflow moves through connected steps: identify, collect, validate, trace, assess, mitigate, approve, submit and retain. Each stage depends on the quality of the previous one. Incomplete supplier data can weaken plot traceability; inaccurate geolocation can compromise risk assessment; and undocumented mitigation can make the final decision difficult to explain.
In practice, teams should connect supplier → farm or plot → geolocation → commodity → batch → product → shipment → DDS. Supporting documents should be attached or referenced against the records they substantiate, rather than stored in unstructured folders. A controlled review step can confirm that required information is present, geolocation has been checked, evidence reviewed and the due diligence decision documented before submission.
Common workflow gaps include treating the DDS as the starting point, managing geolocation as a standalone file, failing to link source plots to batches, beginning mitigation only when a shipment is waiting, and losing the audit trail behind a final decision. A structured workflow helps teams identify and resolve these gaps earlier.
For EU importers, fragmented supplier data, geolocation gaps, and repetitive documentation can make EUDR compliance workflows complex.
Discover how DDS automation can help streamline data validation, risk assessment, and declaration filing.
Read the blog to explore how DDS automation can simplify EUDR compliance for EU importers.
EUDR Due Diligence Statement Examples
A DDS records a due diligence declaration for relevant products. The appropriate approach depends on the product, supply-chain structure, traceability evidence, quantities and applicable rules. Examples can help teams understand how the principles apply to different operating models, but scenarios should not be treated as universal filing instructions.
Example 1: Cocoa exporter working with a cooperative
A cocoa exporter sources beans from multiple farms through a cooperative. The exporter needs reliable farmer and plot records, procurement information, harvest details and traceability links between the contributing plots and the relevant cocoa lot. Where a declaration covers more than one shipment or batch, the exporter must verify that applicable conditions are met and maintain clear records of quantities and shipments linked to the declaration.
From Nigerian Cocoa Farms to EUDR-Ready Exports
How can cocoa traders strengthen traceability, manage deforestation risks, and prepare for EUDR compliance across complex supply chains?
Discover how a leading Nigerian cocoa trading firm leveraged TraceX’s EUDR platform to streamline compliance workflows from farm to export.
Read the case study to see how TraceX supports EUDR compliance across the cocoa supply chain.
Example 2: Manufacturer using timber from multiple origins
A manufacturer sources timber from more than one country and processes it into a finished product. The production facility is not necessarily the origin of the timber. The business must preserve relevant source information and supporting records for each applicable origin and ensure the finished product remains connected to the required upstream evidence.
Example 3: Processor combining agricultural inputs
A processor combines material from different farms or input lots. Its traceability records should preserve the relationship between the output batch and all relevant source plots. If inputs are mixed, split or transformed, the system should document those movements and quantities so the company can identify which source records support the product covered by its due diligence.
The central lesson is that a DDS should reflect the real supply chain. Before reusing or consolidating declaration information, verify the current rules, applicable system constraints, quantities and traceability evidence. Never assume that similar products or shipments can automatically share one declaration.
Discover how DDS grouping and consolidation can help streamline declaration management, reduce repetitive work, and improve traceability across your supply chain.
Read the blog to understand DDS grouping and consolidation under EUDR.
What Evidence Should Be Connected to Due Diligence Records?
Depending on the product and supply chain, supporting information may include supplier declarations, permits, invoices, land-use information, certificates, audit records, production records and geolocation data. The question is not simply whether a document exists, but which supplier, plot, commodity, batch or product it supports and how it contributes to the due diligence assessment.
A practical evidence register should identify the record, its owner, the date collected, the product or supplier it relates to, its review status and any gaps requiring follow-up. Where information is corrected, preserve a record of the change and the reason for it. This creates a more reproducible basis for compliance reviews and customer questions.
Common EUDR Due Diligence Mistakes
- Submitting a DDS before the underlying information and risk assessment are complete.
- Collecting supplier documents without connecting them to the relevant plots and products.
- Using incomplete or unvalidated geolocation data.
- Failing to account for aggregation, processing, batch splits or quantity changes.
- Treating a risk flag as a final conclusion without documenting the review.
- Failing to record mitigation actions, approvals and the reasoning behind decisions.
- Losing the link between DDS references and the products or shipments they concern.
EU Information System and TRACES in EUDR Due Diligence
The EU Information System is the European Commission’s digital platform for submitting and managing Due Diligence Statements (DDS) under the EU Deforestation Regulation (EUDR). Operators and traders subject to the relevant obligations use the system to submit required information about in-scope products, including commodity details, supplier information, and plot-level geolocation data.
EU TRACES (Trade Control and Expert System) is associated with the EU’s broader digital infrastructure for managing regulatory and trade-related processes. For EUDR, businesses need to ensure that the required due diligence information is complete, accurate, and submitted through the applicable EU Information System workflow. Access to the system does not replace the underlying due diligence: businesses must still collect and verify relevant data, assess deforestation and legality risks, and document any required mitigation measures.
Read our guide to EU TRACES for EUDR compliance to understand the submission process and discover how TraceX helps streamline due diligence data management, declaration preparation, and compliance workflows.
The EUDR Information System operates within the European Commission’s TRACES platform, where operators and authorised representatives can submit and manage due diligence statements and applicable simplified declarations. Each successful DDS submission receives a reference number and a verification number, which help businesses manage declarations and link them to relevant supply chain records.
EUDR Record Keeping, Reporting and Audits
EUDR Record Keeping: Maintaining accurate and accessible records is essential for demonstrating compliance. Businesses should organise supplier information, plot-level geolocation, legality documents, risk assessments, mitigation measures and Due Diligence Statements (DDS) so supporting evidence can be retrieved when required.
Discover what information to retain, understand record retention requirements, and learn how to organise supplier data and due diligence evidence effectively. Read our guide to EUDR Record Keeping and strengthen your compliance [sentence ends here, unfinished]
EUDR Reporting: Accurate reporting depends on complete, validated supply-chain data. Businesses must ensure that the information required for due diligence and DDS submission is consistent, traceable and ready for submission through the EU Information System, where applicable.
EUDR Audits: Being audit-ready means more than having documents on file. Businesses should be able to demonstrate how products were traced to their origin, how deforestation and legality risks were assessed, and how identified gaps were addressed. A structured, digital compliance workflow can make evidence easier to verify and retrieve.
Integrating record keeping, reporting and audit preparation into your EUDR due diligence process helps reduce documentation gaps, improve accountability and support more efficient compliance management.
How TraceX Can Support EUDR Due Diligence
TraceX EUDR Solutions supports EUDR-related workflows by helping businesses structure supplier and farm data, manage plot geolocation, connect commodities to batches and products, organise supporting evidence, support risk assessment and mitigation workflows, and prepare structured records for DDS processes. Capabilities available depend on the product configuration and workflow used by the business.
When evaluating software, confirm how it handles your actual commodities, suppliers, plots, product flows, integrations and declaration process. Ask to see a workflow that connects upstream records to a relevant batch or shipment, highlights a data gap, records its resolution and shows how supporting information is retained. Software can make processes more consistent, but the responsible operator remains accountable for due diligence decisions.
EUDR Due Diligence Checklist
- Confirm that the relevant products and supply-chain activities are in scope.
- Collect required supplier, product, quantity, country and production information.
- Capture and validate production-plot geolocation.
- Connect plots and supplier records to commodities, batches, products and shipments.
- Link supporting evidence to the records it substantiates.
- Complete and document the risk assessment.
- Resolve more-than-negligible risk through appropriate mitigation before proceeding.
- Review and approve the due diligence record.
- Prepare and submit the applicable DDS through the EU Information System.
- Retain records and maintain links between declaration references and relevant products or shipments.
Conclusion
EUDR due diligence is not a single form or a last-minute filing task. It is a connected process that begins with product and supplier identification and continues through information collection, geolocation validation, traceability, evidence management, risk assessment, mitigation, declaration preparation and record retention.
The strongest approach is to build the workflow around the information and decisions that support the DDS. By making each relationship clear and documenting how gaps and risks are addressed, businesses can make their due diligence process more consistent and easier to explain.
Frequently asked questions
Can we manage EUDR due diligence using Excel instead of compliance software?
Excel may work for basic record-keeping, but managing supplier data, plot geolocation, risk assessments, supporting evidence and shipment traceability becomes more complex as operations scale. EUDR software can help connect records, identify data gaps and maintain an auditable workflow.
We already have an ERP system. Do we still need an EUDR compliance platform?
Yes, your ERP may manage procurement, inventory and shipments, but may not support all EUDR-specific requirements, such as plot-level geolocation validation, deforestation-risk screening and due diligence evidence management. Assess your existing capabilities first; a dedicated platform can complement your ERP where gaps exist.
If our suppliers provide DDS reference numbers, is that enough to meet our EUDR obligations?
Not necessarily. A DDS reference number alone does not establish that all applicable due diligence requirements have been met. Businesses should determine their responsibilities based on their role and ensure the relevant supplier, sourcing, product and risk information is available and appropriately assessed.
What should we do if suppliers cannot provide complete plot coordinates or supporting documents?
If suppliers cannot provide complete documents, establish minimum data requirements, validate geolocation and documentation early, and follow up on missing or inconsistent information. Unresolved gaps should be assessed before reaching a due diligence conclusion; missing information should never be treated as proof of compliance.
Can EUDR compliance software guarantee that our products are compliant?
No. Software can support supplier onboarding, geolocation checks, risk assessment, evidence management and declaration workflows, but it cannot guarantee compliance by itself. Businesses remain responsible for conducting the due diligence applicable to their role, evaluating evidence and addressing identified risks.
