What Is a Due Diligence Statement?

A Due Diligence Statement (DDS) is the formal declaration that an operator submits to the EU before placing regulated products on the market. It is the final output of the three-step due diligence process described in the EUDR overview: information collection, risk assessment, and risk mitigation.

The DDS confirms that the operator has exercised due diligence and that the products are deforestation-free and legally produced. It is submitted electronically through the EUDR Information System connected to TRACES and serves as the official compliance record that customs authorities and competent authorities can check.

There are two important exceptions to this general DDS workflow. A qualifying micro or small primary operator submits a one-time simplified declaration and receives a declaration identifier. Downstream operators and traders do not submit another DDS for products already covered upstream.

For relevant products entering or leaving the market, customs generally needs the DDS reference number or, where applicable, the simplified-declaration identifier. The EUDR does not require a DDS verification number to be entered in the customs declaration or passed down the supply chain.

What Information Must a DDS Contain?

As specified in Annex II of the regulation, the DDS itself is a concise legal declaration. It is not the full evidence report. The broader evidence package should be kept in your records, while the DDS submission contains the core fields required by the EU system:

Operator Information

  • Company name and registered address
  • EORI number, where relevant, the customs identifier that links the DDS to the customs declaration. For details on EORI requirements, see our guide on who needs to comply.

Product Information

  • HS code of the product as listed in Annex I
  • Commercial description of the product
  • Quantity, usually net mass in kilograms, or another applicable unit

Production Information

  • Country of production
  • Geolocation data of all production plots, prepared in a format accepted by the EUDR Information System

Due Diligence Confirmation

  • Declaration that due diligence was carried out and no or only negligible risk was found
  • Signature details: signed for and on behalf of the operator, place and date, name, function, and signature

The evidence behind the DDS is much richer than the DDS form itself. Supplier records, producer questionnaires, documents, harvesting periods, remote-sensing results, risk decisions, and hashes should be retained in the operator's evidence package so the DDS can be explained if a competent authority asks.

This is why Bosqio separates the official DDS payload from the broader evidence package: the DDS is the submission, while the package preserves plots, questionnaires, documents, checks, hashes, mitigations, and decisions.

How to Submit a DDS Through the EUDR Information System

Step 1: Register for the EUDR Information System

Access the EUDR Information System through the Commission's login flow. Registration requires an EU Login account and an organization profile linked to the relevant operator or representative. Organization validation can take time, so this should be completed well before the first required submission.

Plan for this lead time. Leaving account and organization setup until close to a shipment date can delay the ability to submit a DDS. Register well in advance of your first required submission.

Step 2: Prepare Your Data

Before starting a DDS submission, assemble all required data:

  • All geolocation data validated: an accepted system-entry method or valid GeoJSON bulk upload, WGS84 longitude/latitude order, and consistent coordinate formatting
  • Supplier and producer evidence complete in your internal records
  • Product HS codes verified against Annex I
  • Net mass calculated in kilograms (not metric tons or pounds)
  • Harvesting or production periods confirmed where relevant to your evidence package

Data preparation is where most of the effort lies. The DDS submission itself is relatively straightforward if the data is ready. If the data is incomplete or fails validation, the submission can be rejected.

Step 3: Create the DDS in the Information System

In the EUDR Information System, create a new DDS and populate all required fields. The system performs validation against the technical rules. It will flag issues such as invalid geolocation data, missing required fields, or HS codes not found in Annex I. Common validation errors include:

  • Geolocation data rejected because of invalid geometry, reversed coordinate order, or an unsupported structure
  • HS code not matching a listed Annex I product
  • EORI number validation failure (ensure your EORI is active and correctly formatted)
  • Net mass entered in wrong units

Step 4: Submit and Receive Reference Numbers

Upon successful submission, the Information System issues a DDS reference number and a verification number. The DDS reference links the declaration to the covered products and is the number made available to customs where Article 26 applies. The verification number is an access-control credential for retrieving or managing a DDS; it is not an additional customs-declaration field and should not be distributed as a routine supply-chain identifier.

Keep the verification number secure and retain the DDS reference with the supporting compliance records for at least five years. A qualifying micro or small primary operator receives a simplified-declaration identifier instead.

The 72-Hour Amendment and Withdrawal Window

One of the most operationally significant rules in the EUDR is the 72-hour amendment and withdrawal window. Understanding its mechanics is essential for managing the risk of errors in your DDS submissions.

How It Works

  • After a DDS reference number is made available, the DDS can generally be amended or withdrawn within 72 hours
  • During this window, you can correct errors or withdraw a DDS submitted in error
  • After 72 hours, the DDS is locked and cannot be changed through the normal amendment route
  • The window may close earlier if the DDS has already been used or selected for checks

The Lock Exceptions

Even within the 72-hour window, amendment or withdrawal can be blocked if the DDS reference number has already been used, for example in a customs declaration, or if the DDS has been selected for checks by the authorities.

In practice, this means that if your shipment clears customs quickly, your practical amendment window may be much shorter than 72 hours.

What If the 72-Hour Window Closes With an Error?

If you discover an error after amendment or withdrawal is no longer available, assess immediately whether it affects the conclusion that the product is compliant and presents no or only negligible risk. If an operator obtains or becomes aware of relevant new information indicating that a product already placed on the market or exported may not comply, Article 4(5) requires it to inform the competent authorities of the Member States in which the product was placed or exported and the downstream actors it supplied. A new DDS for a future shipment does not retrospectively cure a non-compliant product. Contact the relevant competent authority for case-specific handling.

Best Practices for the Amendment Window

  • Never submit a DDS unless you have reviewed all data. The 72-hour window is a safety net, not a workflow step.
  • Set up internal alerts: monitor the 72-hour countdown actively using calendar reminders or compliance software
  • Coordinate with your customs broker: ensure they do not process the customs declaration immediately if you may need to amend the DDS
  • Maintain a review checklist: verify geolocation data, HS codes, net mass, supplier details, and harvesting dates before each submission

DDS Lifecycle

For internal planning, a DDS can be viewed through the following practical stages. These are not an exhaustive list of official Information System status labels:

  1. Draft: DDS is being prepared in the Information System but has not been submitted
  2. Submitted: DDS has been submitted and reference identifiers are made available
  3. Amendment Window: within 72 hours, amendment or withdrawal may be possible
  4. Locked: 72 hours have elapsed, the DDS has been used, or checks prevent further changes
  5. Referenced for Customs: the DDS reference has been used where Article 26 requires it
  6. Potential Authority Review: a competent authority may review the DDS and its supporting evidence

Understanding this lifecycle helps operators plan their submission timing. Submit too early, and you may need to amend if shipment details change. Submit too late, and you risk delaying customs clearance.

Common DDS Submission Pitfalls

The following are common categories of issue to check before submission:

1. Geolocation Data Rejection

Invalid geolocation data can prevent submission. See our GeoJSON guide for the technical requirements. Typical problems include swapped latitude/longitude order, invalid or unclosed polygons, unsupported geometry structures, and non-WGS84 coordinates. The Information System pads fewer displayed decimal digits with zeros, so that formatting issue should not be described as the main rejection reason.

2. Net Mass Discrepancies

The DDS requires net mass in kilograms. Operators sometimes enter the gross shipping weight instead of the net product weight, or convert from metric tons incorrectly. A shipment of 20 metric tons of green coffee should be entered as 20,000 kg.

3. Mismatched Production Evidence

The evidence package should be internally consistent. If a supplier provides geolocation data for a plot harvested in March 2025, but the supporting records point to a different production period or supplier chain, the inconsistency could trigger a compliance question during an audit.

4. Incomplete Evidence Chains

The DDS is supported by the operator's underlying records. If you purchase through an intermediary, you still need evidence linking the product back to the production plots and the required producer information. Gaps in the evidence chain, where you can name a supplier but not the production plots, make a defensible DDS impossible.

Penalties for Non-Compliance

Competent authorities in each EU member state are responsible for enforcement. The EUDR prescribes penalties that member states must make available, including:

  • Fines proportionate to environmental damage and product value, with a maximum level of at least 4% of annual EU-wide turnover. This is calculated on the operator's entire EU revenue, not just the revenue from regulated products.
  • Confiscation of the relevant products and any revenue generated from their sale
  • Temporary exclusion from public procurement and public funding for a maximum period of 12 months
  • Temporary prohibition from placing or making relevant products available on the market or exporting them in cases of serious or repeated infringement
  • Publication of final judgments: the Commission publishes specified information on final judgments against legal persons after notification by Member States, creating reputational risk beyond the direct financial penalty

Frequently Asked Questions

Can I submit one DDS for multiple shipments?

A DDS must match the product, quantity, origin, and geolocation data it covers. Many operators align DDS records with shipments or consignments for operational clarity, but the legal point is that the DDS reference must support the actual products being placed on the market, exported, or declared to customs.

What if my supplier refuses to share geolocation data?

Without geolocation data, you cannot complete a valid DDS. In practice, this means you cannot legally import from that supplier. This is one of the regulation's most powerful enforcement mechanisms because it creates a commercial incentive for supply chain transparency. If a supplier cannot or will not provide compliant geolocation data, you need to find an alternative source.

How long must I retain DDS records?

DDS references and the information, data, and evidence supporting due diligence must be retained for at least five years. For practical evidence management, keep the DDS itself, geolocation data, supplier correspondence, risk assessment documentation, and any amendments together in the same evidence package.

Can I withdraw a submitted DDS?

Yes, in limited circumstances. A DDS can generally be withdrawn within 72 hours after the reference number is made available, unless it has already been used or selected for checks. After the window closes, contact your competent authority if a material error is discovered.

Sources

Important note

This guide is provided for general information only and is not legal advice. Regulatory requirements, official guidance, and implementation dates can change. Operators should verify current obligations with official sources or qualified counsel before making compliance decisions.