What a Due Diligence Statement is
A Due Diligence Statement is the formal output that an operator submits after completing all three steps of the EUDR due diligence process: information collection, risk assessment, and, where necessary, risk mitigation. The DDS is not a separate document that substitutes for due diligence. It is the conclusion of the process, submitted into a centralized EU system and assigned a reference number that makes it traceable and auditable.
The legal basis is Article 4 of Regulation (EU) 2023/1115. The article states that operators shall not place relevant products on the market or export them unless a DDS has been submitted and the reference number has been declared to customs authorities where required.
The DDS is the point where your internal compliance work becomes a documented, system-recorded commitment. Submitting a DDS without the underlying due diligence being complete is a violation of the regulation, not a compliance shortcut.
What the DDS must contain
The content requirements for a DDS are set out in Article 4 of the regulation. The statement must include:
- A description of the product, including its CN code as listed in Annex I, the quantity expressed in net mass and, as appropriate, volume or unit number.
- The country of production.
- Geolocation of all plots of land where the relevant commodity was produced, expressed as polygons or coordinates precise enough to identify the specific land area.
- The date or time range of production.
- The name, postal address, and email address of any supplier from whom the operator received the product.
- The name, postal address, and email address of the operator or trader to whom the product is supplied.
- Adequate and conclusive information that the product is deforestation-free.
- Adequate and conclusive information that the product has been produced in accordance with the relevant legislation of the country of production.
The geolocation data is typically the element that requires the most preparation. For most commodity supply chains, this data must come from the producer or an intermediary who has direct contact with the farm or forest. See our article on EUDR traceability requirements for what this means in practice.
The EUDR Information System
The EUDR Information System (EUDR-IS) is the digital portal operated by the European Commission through which all DDS submissions are made. Operators register for access using an EU Login account. For companies operating in the Netherlands, the registration is linked to your EORI number and the legal entity registered with Dutch Customs.
The EUDR-IS accepts DDS submissions via the web interface and, for high-volume operators, via an API that allows system-to-system submission. The API route is relevant for operators processing large numbers of shipments, as it enables integration with ERP or compliance management systems. The Commission provides API documentation and a test environment.
The DDS must be submitted before placing the product on the EU market. For importers, this means before the goods are released for free circulation under EU customs procedures. In practice, the DDS submission and reference number should be part of the pre-shipment preparation workflow, not something done at the time of customs clearance. Building it into your purchase order and shipping instruction processes is the operationally logical approach.
The reference number and its downstream use
Each submitted DDS generates a unique alphanumeric reference number. This number serves two functions. First, it must be declared on the customs declaration when importing goods from outside the EU. Dutch Customs uses this reference to verify compliance in their risk-based clearance model. Second, it must be passed to any downstream trader who makes the product available on the EU market. Traders use the reference number to satisfy their own EUDR obligations without repeating the full due diligence process.
The reference number is queried by the EUDR-IS to verify that the DDS exists and is valid. An invalid or non-existent reference number in a customs declaration creates an immediate compliance flag. Customs authorities can check the DDS content against the declaration data.
Using one DDS for multiple shipments
The regulation does not require a separate DDS for every individual shipment. An operator can submit one DDS that covers multiple shipments of the same product from the same supplier, provided that the underlying due diligence file covers all of the shipments and that the geolocation, quantity, and other information in the DDS remains accurate.
In practice, this means a standing DDS per supplier-product combination, reviewed and updated periodically (or when production circumstances change). When a new growing season begins, or when a supplier adds new plots of land, or when geolocation data changes, the DDS must be updated to reflect the current situation. An operator who submits a DDS and then continues importing under that reference without updating it when circumstances change is filing an inaccurate DDS, which is a violation.
Record-keeping obligation
Article 9 of the regulation requires operators to keep all documentation supporting their due diligence for a minimum of five years from the date of placing the product on the market. This includes the information collected in Step 1 (supplier data, geolocation documentation, production dates), the risk assessment record, any risk mitigation measures taken, and the DDS itself. In the event of a compliance check or investigation, authorities can request the full due diligence file underlying any DDS reference number.
For the full framework of EUDR obligations for operators, see our guide on EUDR compliance for EU importers.