Due Diligence Statement (DDS) 

A Due Diligence Statement (DDS) is a mandatory electronic declaration under the EU Deforestation Regulation (EUDR) confirming that regulated products placed on or exported from the EU market are deforestation-free, legally produced, and compliant with all EUDR requirements. 

What Is a DDS? 

The Due Diligence Statement is the formal legal confirmation of EUDR compliance. It represents the point at which an operator declares under legal liability that all required due diligence steps have been completed and that the risk of deforestation and illegality is negligible. 

Without a valid DDS, a product: 

• Cannot be legally placed on the EU market 

• Cannot be legally exported from the EU 

• Remains exposed to enforcement action, regardless of commercial contracts 

Critically, DDS submission is not a post-shipment formality. EUDR requires the DDS to be submitted before the product is placed on the market. Any attempt to retroactively submit or “fix” a DDS after shipment creates immediate non-compliance. 

Why the DDS Is Central to EUDR Compliance 

The DDS is not just an administrative step it is the legal anchor of the EUDR framework. While data collection, risk assessment, and mitigation happen upstream, the DDS is where responsibility crystallizes. 

By submitting a DDS, the operator: 

• Accepts legal accountability for data accuracy 

• Confirms that deforestation risk has been assessed and mitigated 

• Enables EU authorities to trace products and audit compliance 

In enforcement scenarios, the DDS is often the first document requested by competent authorities. 

What Information a DDS Contains 

A DDS must include structured, verifiable information that allows authorities to assess compliance. This includes: 

• Operator identification 
  Legal entity name, registration details, and EU identifiers. 

• Commodity and HS code 
  Precise classification of the regulated product and its derived form. 

• Country of production 
  The country (or countries) where the commodity was produced. 

• Farm or plot geolocation 
  GPS coordinates or polygons identifying the exact land where production occurred. Polygons are strongly preferred for deforestation verification. 

• Risk assessment and mitigation confirmation 
  A declaration that deforestation and legality risks have been assessed and reduced to negligible levels. 

• Declaration of compliance 
  A legally binding statement affirming adherence to EUDR requirements. 

Incomplete or inconsistent data at this stage will result in DDS rejection or enforcement exposure. 

Where and When DDS Is Submitted 

DDS submissions must be made electronically through the EU’s designated system before the product is placed on the EU market or exported. 

Key timing rules: 

• Submission must occur prior to customs clearance or market placement 

• Late submissions are treated as non-compliant 

• Corrections often require full re-submission, not simple edits 

For high-volume operators, manual submission becomes operationally risky, increasing the likelihood of errors and delays. 

DDS Lifecycle and Validity 

Once submitted, a DDS enters an ongoing lifecycle: 

• Record retention 
  DDS references and supporting data must be retained for at least five years. 

• Downstream reliance 
  Traders and downstream operators rely on DDS references to demonstrate compliance. 

• Change management 
  Material changes—such as: 

• New farms or plots 

• Updated geolocation boundaries 

• Significant volume changes 

• Supplier substitutions 

may invalidate an existing DDS and require re-submission. 

This makes DDS management a continuous process, not a one-time task. 

Why DDS Submissions Fail 

DDS failures are rarely caused by the submission system itself. They almost always originate from upstream data issues, including: 

• Missing or incomplete geolocation data 

• Invalid coordinates or poorly defined polygons 

• Incorrect or mismatched HS codes 

• Inconsistent supplier identities across datasets 

• Submissions made too late in the shipment process 

At scale, these issues multiply quickly, making manual workflows unsustainable. 

Legal Consequences of an Incorrect DDS 

Submitting inaccurate, incomplete, or misleading DDS information carries serious consequences. Authorities may impose: 

• Administrative penalties, including substantial fines 

• Confiscation or withdrawal of products from the market 

• Temporary bans on placing products on the EU market 

• Criminal liability, depending on national enforcement frameworks 

Importantly, liability remains with the operator, even if incorrect data originated from suppliers outside the EU. 

Operational Implications for Companies 

DDS requirements affect multiple internal teams: 

• Procurement, which must ensure supplier readiness 

• Compliance, which manages due diligence and documentation 

• IT and data teams, which support geolocation and traceability 

• Logistics, which must align shipments with DDS timing 

Organizations that treat DDS as a last-minute compliance task often face shipment delays, rejected declarations, and audit exposure. 

Automation and Scalability 

While DDS submissions can be done manually, automation is strongly recommended for companies managing: 

• Multiple suppliers 

• Multiple origin countries 

• High shipment volumes 

Automated workflows reduce error rates, ensure earlier submission, and maintain consistent audit trails key advantages as EUDR enforcement intensifies. 

Frequently Asked Questions (FAQ’s)