EUDR: filling in your due diligence statement (DDS), step by step

The EUDR (Regulation (EU) 2023/1115) requires, for seven commodities (cocoa, coffee, wood, soya, palm oil, cattle, rubber), the filing of a due diligence statement (DDS) before placing on the European market. The principle is simple on paper — proving that a product does not come from a plot deforested after 31 December 2020 — and a source of filing failures in practice, most often for reasons of format, not substance. This guide covers filling in the statement, not the legal framework already detailed in our general EUDR guide.

What a DDS must contain

• Identification of the product (HS code, description, quantity).
• The country of production.
• The geographical coordinates of each plot of origin — the most technical point and the one that generates the most rejections.
• A declaration attesting to the absence of deforestation after 31 December 2020.
• The evidence supporting this declaration (documents, satellite imagery if necessary).

GPS coordinates: what passes, what fails

The EUDR information system expects a precise format. The most frequent rejections:

• Decimal format required (e.g. 48.8566, 2.3522), not the degrees-minutes-seconds format used by some older agricultural GPS surveys.
• A single point is enough for a plot of under 4 hectares producing commodities other than cattle; above that, a polygon (the complete outline of the plot) is required, not just a centroid.
• Insufficient precision: a coordinate recorded at the level of the municipality or hamlet rather than the actual plot is rejected — the precision must make it possible to identify the specific plot, not just the area.
• Coordinates inconsistent with the declared country — a data-entry error (swapping latitude and longitude, for example) places the point in another country and blocks the filing immediately.

Declaring for several suppliers

This section applies to whoever files, that is the operator placing the raw material on the European market for the first time — a processor that imports it itself, for example. If it buys the material already covered by a statement, it is a downstream operator and falls under the next section. An operator receiving a raw material from several producers cannot merge their plots into a single aggregated statement: each plot of origin must remain individually identifiable in the DDS, even if the finished product mixes several batches. Two workable approaches:

• One DDS per production batch, referencing all the plots that contributed to that specific batch — the most rigorous method, aligned with well-structured batch numbering.
• One reference DDS per supplier, reused for each new delivery as long as the declared plots have not changed — this lightens the burden of repeated data entry, provided it is updated as soon as a supplier changes plot.

What is passed on downstream, what must be redone

The rule for this section changed in December 2025. Regulation (EU) 2025/2650 removed the filing obligation for downstream operators: they no longer file a statement in the information system; they collect and keep the reference number of the primary operator's statement, and report it in their customs declaration. Downstream operators other than SMEs also no longer have a periodic reporting obligation. A chain organised so that a trader, processor or exporter files its own DDS each time goods change hands is therefore doing work today that the text no longer requires.

One point should be checked with your competent authority rather than inferred: the case of mixing with a non-covered origin. As long as the product remains covered by the upstream statement, the reference number is enough; as soon as a non-covered origin goes into the product, the question arises of who becomes the primary operator again, and the answer depends on the exact nature of the operation. We do not settle it here for lack of an explicit official source — and this is precisely the kind of point on which an invented answer would cost more than a question asked.

Common mistakes

• GPS survey done at the office, not on the plot — an approximate coordinate, taken from a map rather than measured on site, fails the slightest consistency check against the satellite imagery available to the authorities.
• A single survey for several distinct plots of the same producer, when each must be declared separately if they are not contiguous.
• Statement not updated after a change of supply plot — the DDS referenced downstream then becomes false without anyone noticing before an inspection.
• Confusing the planting date with the current date of cultivation — all that counts is the absence of deforestation on the plot after 31 December 2020, however old the farm itself is.

Checklist before filing

1. Coordinates in decimal format, recorded on the actual plot.
2. A complete polygon if the plot exceeds 4 hectares (cattle excepted).
3. One plot = its own geolocation, no approximate grouping.
4. Consistency checked between the declared country and the coordinates entered.
5. DDS updated if the supplier or the plot has changed since the last statement.
6. Supporting documents ready to be produced in the event of an inspection.