How to file an EUDR Due Diligence Statement (DDS)

The Article 9 set, collected, organised and kept for five years: the description and trade name of the product (for wood, the common and full scientific species name), the quantity as kilograms of net mass, the country of production, the geolocation of every plot together with the date or time range of production, supplier and customer names, addresses and emails, and evidence on both substantive limbs: that the goods are deforestation-free after the 31 December 2020 cut-off, and that they were produced in accordance with the relevant legislation of the country of production, including land-use rights. Gather this once per sourcing line. The plots are the long-lead item.

Register in the Commission’s information system as an operator or trader, with your EORI number so the record can meet customs. Enter the Article 9 data, manually for a few lines or by API for volume, record the risk assessment, and submit. The system issues a reference number and a separate verification number, which anyone holding it can use to check the statement’s validity. One statement may cover several batches or shipments of several products, provided it covers the whole quantity and is submitted before any of it is placed on the market. Each legal entity needs its own account: there are no group accounts, and due diligence is individual to the entity placing the product.

Only inside a narrow window. Under Commission Implementing Regulation (EU) 2024/3084 a statement can be amended or withdrawn within 72 hours of issue, and not at all once it has been used in a customs declaration, once the product has been placed on the market, or once a check has been notified. Treat submission as the commitment point, not the draft stage. If new information later shows the goods do not comply, the route is Article 4(5): notify the competent authority and everyone downstream, not a quiet edit.

Yes, and in fact they cannot file one. Only the operator placing the product on the EU market submits the statement and, by submitting it, assumes responsibility for compliance. Downstream operators and traders keep the supplier and customer information and the reference numbers, and pass those numbers on to their own first downstream operators and traders. A small downstream buyer relying on a compliant supplier is doing the right thing, not cutting a corner. A larger one has an extra duty: a non-SME operator must ascertain that due diligence was carried out upstream and include the references. See EUDR for SMEs for which side of that line you are on.

Two, and only two: release for free circulation and export. Customs warehousing, inward processing, temporary admission and transit do not trigger the EUDR, so a consignment moving through an EU port in bond on its way elsewhere is outside it. Note the asymmetry at the other end: customs release is not proof of compliance. A competent authority can still act on goods after they have been released.

Five years from placing or export. Keep the collected information, the risk assessment, and any mitigation, and produce them to a competent authority on request. The exposure for gaps is real: Article 25 requires Member States to set fines whose maximum is at least 4%of the operator’s total annual EU-wide turnover in the preceding financial year, and adds confiscation of the goods and of the revenues from them, exclusion from public procurement and funding for up to twelve months, and, for serious or repeated breaches, a temporary market ban. Not sure a product even needs a statement? The commodity guides resolve scope commodity by commodity.