What Is a Due Diligence Statement (DDS)?
A Due Diligence Statement (DDS) is an official declaration submitted by operators to the EU Information System confirming that they have exercised due diligence and found the products they're placing on the market to be compliant with EUDR requirements.
Key Point: The DDS is not just a form—it's a legally binding statement that you have collected all required information, assessed risks, and taken mitigation measures where necessary. Submitting a false or incomplete DDS can result in significant penalties.
DDS vs. Due Diligence System
It's important to understand the distinction:
- Due Diligence System: The overall framework and procedures you establish to collect information, assess risks, and mitigate concerns across your supply chain
- Due Diligence Statement (DDS): The specific document you submit for each batch/shipment declaring that you've applied your due diligence system and the products are compliant
Think of the due diligence system as your company's compliance infrastructure, while the DDS is the output document proving you've used that infrastructure for a specific transaction.
Who Must Submit a DDS?
Operators only. If you're the first entity placing covered commodities or products on the EU market, you are an operator and must submit a DDS.
Operators Submit DDS
- Importers bringing commodities into the EU from third countries
- EU-based producers placing products derived from covered commodities on the market
- Any entity making covered products available for the first time in the EU
Traders Do NOT Submit DDS
Traders (entities purchasing products already on the EU market and reselling them) do not submit their own DDS. Instead, they:
- Collect the DDS reference number from their supplier (the operator)
- Keep records of the DDS reference number for 5 years
- Verify that the DDS reference number is valid in the EU Information System
- Provide the DDS reference number to their customers and authorities upon request
Example: A German coffee roaster imports green coffee beans from Colombia. As an importer, they are an operator and must submit a DDS. A café in Berlin that buys roasted coffee from the German roaster is a trader—they collect and record the roaster's DDS reference number but don't submit their own DDS.
When Do You Need to Submit a DDS?
A DDS must be submitted before placing products on the EU market. This means:
- For importers: Before customs clearance (the DDS reference number is required for customs release)
- For EU producers: Before making the product available to customers or distributors
Frequency of Submission
You must submit a separate DDS for each batch or shipment. The regulation does not define "batch" rigidly, but common interpretations include:
- Import shipments: One DDS per customs declaration (container, pallet group, truck load)
- Production runs: One DDS per production batch using the same sourced materials and geolocation data
- Aggregated lots: For products from multiple plots (e.g., coffee from various farms processed together), one DDS can cover the aggregated batch if all geolocation data is included
Practical Tip: Many SMEs align DDS submissions with their import declarations or production batch numbers to simplify record-keeping and traceability.
Information Required in a DDS
The DDS must contain comprehensive information about the products, their origin, and the due diligence process applied. Here's a complete breakdown:
1. Operator Information
- Company name and legal form
- Full address of the operator
- EORI number (Economic Operators Registration and Identification)
- Contact person and details
2. Product Information
- Commodity type: Coffee, cocoa, timber, palm oil, cattle, soy, or rubber
- Product description: Specific product type (e.g., "green coffee beans, Arabica")
- HS Code: Harmonized System classification code
- Quantity: Volume, weight, or number of units
- Country of production: Where the commodity was grown/harvested
3. Geolocation Data (Critical Requirement)
This is the most detailed and critical part of the DDS. You must provide:
- GPS coordinates (latitude and longitude) of all plots where the commodity was produced
- Precision requirements:
- Plots ≤ 4 hectares: Single coordinate point (center or access point)
- Plots > 4 hectares: Polygon with multiple coordinates outlining the plot boundary
- Format: Decimal degrees (WGS 84 coordinate system) with at least 6 decimal places precision
Example Geolocation Entry:
Plot ID: Farm-Colombia-001
Latitude: -1.234567
Longitude: -76.543210
Area: 2.5 hectares
(For plots over 4 ha, you'd provide multiple coordinate pairs forming a polygon)
4. Supplier Information
- Name and address of direct supplier(s)
- Contact information
- Country of establishment
- If applicable: names and details of any intermediaries in the supply chain
5. Production Date / Harvest Period
- Date or period when the commodity was produced/harvested
- For timber: felling date or period
- For agricultural products: harvest season/year
6. Deforestation-Free Assurance
A declaration that the products:
- Were produced on land that has not been deforested after December 31, 2020
- Comply with all relevant laws of the country of production
7. Risk Assessment Conclusion
- Summary of the risk assessment performed
- Risk level determined (negligible, low, standard, high)
- If non-negligible risk was identified: description of mitigation measures taken
- Conclusion that risk has been reduced to negligible level
8. Supporting Documents (Referenced or Attached)
While not all documents are uploaded with the DDS, you must reference them and keep them available for inspection:
- Supplier declarations
- Certificates (e.g., FSC, Rainforest Alliance, organic certifications)
- Satellite imagery or deforestation analysis reports (if used for verification)
- Third-party audit reports (if applicable)
- Contracts with suppliers
- Bills of lading, invoices, customs documents
Step-by-Step: Filling Out a DDS
Here's a practical walkthrough of preparing and submitting your DDS:
Step 1: Gather All Required Information
Before you start filling out the DDS form (in the EU Information System), compile:
- Your EORI number and company registration details
- Supplier names, addresses, and contact information
- GPS coordinates for all production plots (from supplier declarations)
- Product specifications, HS codes, quantities
- Production/harvest dates
- Risk assessment documentation
Step 2: Format Geolocation Data Correctly
GPS data is the most common source of errors. Ensure:
- Coordinates are in decimal degrees (not degrees/minutes/seconds)
- Latitude and longitude are correct (check: latitude -90 to +90, longitude -180 to +180)
- At least 6 decimal places for accuracy (~0.1 meter precision)
- Polygons for large plots close properly (first and last coordinate match)
Pro Tip: Use Google Maps or a GPS coordinate converter to validate coordinates before submission. Right-click on a location in Google Maps to see its decimal coordinates.
Step 3: Access the EU Information System
The official EU Information System for EUDR will be accessible through the European Commission's portal. You'll need:
- EU Login credentials (create an account if you don't have one)
- Your EORI number linked to your account
- Authorization to submit DDS on behalf of your company (if you're not the legal representative)
Step 4: Complete the DDS Form
The EU Information System provides a structured form. Fill in each section carefully:
- Operator Details: Auto-populated from your EORI, verify accuracy
- Product Information: Select commodity, enter HS code, quantity, description
- Geolocation: Upload GPS data (CSV or manual entry via map interface)
- Supplier Chain: Add supplier details, attach supplier declarations if required
- Dates: Enter production/harvest period and submission date
- Risk Assessment: Select risk level, describe mitigation if applicable
- Declaration: Tick boxes confirming deforestation-free and legal compliance
Step 5: Validate Before Submission
Use the system's built-in validation tool (if available) or manually check:
- No mandatory fields left blank
- GPS coordinates fall within the correct country/region
- Total quantity matches your shipment or production records
- HS code matches the product description
- Risk assessment conclusion is justified by your due diligence
Step 6: Submit and Receive DDS Reference Number
Once submitted, the system will:
- Perform automated checks (e.g., coordinate validity, completeness)
- Generate a unique DDS reference number
- Provide a confirmation receipt (save this!)
The DDS reference number is crucial—you'll need it for:
- Customs clearance (for imports)
- Providing to your customers (traders need this for their records)
- Future reference and audit trail
Step 7: Record Keeping
After submission, you must keep for at least 5 years:
- DDS reference number and confirmation receipt
- All supporting documents (supplier declarations, GPS evidence, contracts, etc.)
- Risk assessment documentation
- Any correspondence related to the DDS or shipment
Common Mistakes to Avoid
Based on early EUDR implementations and similar regulatory schemes, here are the most frequent errors:
1. Incorrect GPS Format
Mistake: Submitting coordinates in degrees/minutes/seconds (e.g., 1°14'04.4"S) instead of decimal degrees (-1.234567).
Solution: Always convert to decimal degrees before submission. Use online converters if needed.
2. Insufficient Precision
Mistake: Providing coordinates with only 2-3 decimal places (e.g., -1.23), which gives ~1 km accuracy instead of the required meter-level precision.
Solution: Use at least 6 decimal places (e.g., -1.234567).
3. Missing Plots
Mistake: Forgetting to include GPS coordinates for some production plots, especially in aggregated batches from multiple farms.
Solution: Cross-reference your supplier list with geolocation data. Every source plot must have coordinates.
4. Mismatched Quantities
Mistake: DDS quantity doesn't match customs declaration or invoice quantities.
Solution: Verify quantities across all documents before submission. Use the same units (kg, tons, m³).
5. Incomplete Risk Assessment
Mistake: Declaring "negligible risk" without sufficient justification, or failing to document mitigation measures for identified risks.
Solution: Keep detailed records of your risk assessment process. If you find risks, document the specific measures taken to mitigate them.
6. Wrong HS Code
Mistake: Using a generic or incorrect HS code that doesn't match EUDR-covered products.
Solution: Verify your HS code against the official list of covered HS codes in EUDR Annex I. When in doubt, consult a customs expert.
7. Late Submission
Mistake: Submitting the DDS after goods have already been placed on the market or cleared through customs.
Solution: Build DDS preparation and submission into your import or production workflow well in advance of the deadline.
DDS Validation and Submission
The EU Information System will perform several automated validation checks. Understanding these can help you avoid rejections:
Automated Checks
- Data Completeness: All mandatory fields filled
- Coordinate Validity: GPS coordinates within valid ranges and matching declared country of production
- HS Code Verification: HS code is on the list of covered products
- EORI Validation: Your EORI number is valid and active
- Date Logic: Production date is before submission date; no future dates
Manual Reviews and Audits
Competent authorities may conduct spot checks or audits on submitted DDS, especially for:
- High-risk countries or regions
- Large quantities
- First-time operators
- Random compliance checks
If selected for review, you may be asked to provide:
- Original supplier declarations and contracts
- Satellite imagery or third-party verification reports
- Detailed risk assessment documentation
- Proof of legal compliance in the country of production
Best Practice: Even if not immediately requested, keep all supporting documents organized and easily accessible. Authorities can request them up to 5 years after submission.
Free DDS Preparation Template
To help you prepare your DDS efficiently, we've created a comprehensive free Excel template that guides you through collecting all required information before submitting to the EU Information System.
📊 Get the Complete DDS Template + Section-by-Section Guide
We've created a dedicated resource page with our professional DDS template PLUS detailed explanations for every section, examples by commodity type, GPS coordinate validation guide, and step-by-step usage instructions.
What's Included in the Template
- 8 Comprehensive Sheets: Instructions, Operator Info, Product Details, Geolocation Data, Supplier Information, Risk Assessment, Summary Report, Document Checklist
- Color-Coded Required Fields: Yellow highlights show mandatory EUDR fields
- GPS Validation Instructions: WGS 84 decimal format with 6+ decimal place requirements
- Auto-Calculated Summary: Excel formulas generate compliance overview automatically
- Multi-Supplier Support: Track unlimited suppliers in your supply chain
- Risk Scoring Framework: Built-in risk assessment methodology
- EU System Format Match: Fields mirror official EU Information System requirements
→ See detailed section-by-section explanations, examples by commodity type, and complete usage guide
How to Use the Template
- Download the Excel file and save it with your batch/shipment identifier
- Fill in the "Operator Info" sheet once (reuse for future DDS)
- Complete the "Product Details" tab for your current shipment
- Enter GPS coordinates in the "Geolocation" sheet (copy-paste from supplier declarations)
- Add supplier information in the "Suppliers" tab
- Use the "Risk Assessment" checklist to document your due diligence
- Review the "Validation" sheet for any errors or missing data
- Once complete, use the compiled data to fill out the official DDS form in the EU Information System
Note: This template is for preparation and record-keeping only. The official DDS must be submitted through the EU Information System. However, having all data organized in advance makes the official submission much faster and reduces errors.
Simplify DDS Preparation with EUDR Simple
While our free template helps you organize information, preparing and submitting DDS for every shipment can still be time-consuming—especially if you have multiple suppliers, frequent imports, or complex supply chains.
How EUDR Simple Automates DDS Preparation
- Supplier Data Management: Store all supplier information, GPS coordinates, and certifications in one central database
- Batch Tracking: Link each shipment to source plots automatically based on supplier declarations
- GPS Validation: Real-time coordinate format checking and satellite overlay for visual verification
- Risk Assessment: Automated country and plot-level risk scoring based on EU benchmarking data
- Document Repository: Centralized storage for supplier declarations, contracts, and certificates linked to each DDS
- Pre-Filled DDS Forms: Generate DDS-ready data exports compatible with the EU Information System
- Audit Trail: Complete history of all due diligence activities and DDS submissions for 5+ years
Time Savings Example
Manual Process: 2-4 hours per DDS (gathering data, formatting coordinates, double-checking, manual entry)
With EUDR Simple: 10-15 minutes per DDS (review pre-populated data, click to export)
Frequently Asked Questions
Can I submit one DDS for multiple shipments?
No. Each shipment or batch requires a separate DDS. However, you can include products from multiple plots/suppliers in one DDS if they're part of the same batch (e.g., coffee from 10 farms blended into one container).
What if I don't have GPS coordinates from my supplier?
GPS coordinates are mandatory. If your supplier cannot provide them, you have several options:
- Request coordinates directly from the producer/farm
- Use satellite imagery or remote sensing to determine plot locations (requires verification)
- Engage a third-party auditor to visit and record coordinates
- Consider switching to suppliers who are EUDR-ready
Without geolocation data, you cannot legally place products on the EU market under EUDR.
How long does DDS validation take?
Automated validation in the EU Information System is typically instant (a few seconds to minutes). If your DDS passes automated checks, you'll receive your reference number immediately. Manual reviews (if triggered) can take several days to weeks.
Can I update or correct a DDS after submission?
The EU Information System may allow minor corrections (e.g., fixing a typo in a supplier name). However, substantial changes (e.g., adding missing GPS coordinates, changing quantities) may require withdrawing the original DDS and submitting a new one. Consult the system's help documentation or your competent authority.
Do traders need a DDS?
No. Traders do not submit a DDS. Instead, they collect and record the DDS reference number from the operator they purchase from and pass it along to their customers.
What happens if my DDS is rejected?
If the automated system rejects your DDS, you'll receive an error message indicating the issue (e.g., invalid coordinates, missing field). Correct the error and resubmit. Repeated rejections or fraudulent submissions can lead to penalties and increased scrutiny from authorities.
Is there a fee for submitting a DDS?
As of the current regulation, there is no fee charged by the EU Information System for DDS submission. However, costs associated with gathering data (e.g., third-party audits, GPS mapping) are borne by the operator.
Next Steps
Now that you understand the DDS requirements, here's how to move forward:
- Download the free template and start organizing your supplier and geolocation data
- Review your supply chain and identify any gaps in GPS data or supplier documentation
- Set up your EU Login account and familiarize yourself with the EU Information System interface
- Prepare a pilot DDS for an upcoming shipment to practice the process
- Consider automation if you handle multiple shipments per month—manual DDS preparation doesn't scale well