Writing an EUDR due diligence statement: A practical guide

Why the Due Diligence Statement matters 

The EUDR introduces a real shift in how organisations demonstrate responsible sourcing. Rather than relying solely on supplier declarations or voluntary sustainability certifications, businesses are expected to carry out structured due diligence before placing relevant products on the EU market. 

The Due Diligence Statement is the formal declaration that this process has been completed. By submitting one, an organisation confirms it has gathered the required information, assessed deforestation risk and concluded that the products in question present no more than a negligible risk of non-compliance. 

The stakes for getting this wrong are real. Non-compliance can bring fines of at least 4% of a company's EU-wide annual turnover, alongside confiscation of the goods and any revenue generated from them, exclusion from public procurement, and potential criminal liability in some member states. So the statement is more than an administrative box to tick. It reflects whether the organisation has actually implemented a systematic due diligence process backed by proper governance, documentation and evidence, and for many businesses it becomes the final step in a much broader compliance programme. 

Worth noting on timing: mandatory DDS submission applies from 30 December 2026 for large and medium operators and traders, and from 30 June 2027 for micro and small enterprises, following two postponements to the regulation's original schedule. That gives most organisations a few months still to get their process properly in shape before the main deadline lands. 

What is an EUDR Due Diligence Statement? 

The Due Diligence Statement is a declaration submitted through TRACES, the EU's official information system for this regulation, before relevant products are placed on the EU market or exported from it. The statement confirms that the organisation has: 

Submitting the statement does not replace the due diligence process itself. It confirms that due diligence has already happened and that there is sufficient evidence behind the organisation's conclusions. So it is best to think of the DDS as the output of an effective due diligence system, not a standalone compliance exercise you can complete on its own. 

Once submitted, TRACES generates a unique reference number for the statement, along with a verification number. This matters beyond your own paperwork: operators are required to pass their DDS reference number down to their first known downstream buyers or traders. Those downstream operators can then cite the upstream reference number when they place the same product further along the chain, rather than needing to build an entirely new DDS from scratch, provided nothing about the product's compliance position has changed. Non-SME downstream operators and traders can also request the verification number directly where there are substantiated concerns about a shipment, as a way of checking the original statement is valid. 

What information supports the Due Diligence Statement? 

Preparing the DDS means maintaining a comprehensive set of supporting information throughout the supply chain, typically including: 

Exactly what is required varies by commodity, product type and sourcing arrangement. But keeping this documentation complete and well organised throughout is essential for demonstrating compliance if a regulator asks for it, and considerably less painful than trying to reconstruct it after the fact. 

One thing worth checking before you assume the full documentation burden applies: where an organisation sources exclusively from countries classified as low risk under the EU's country risk benchmarking system, a simplified due diligence route is available under Article 13 of the regulation. Micro and small primary operators sourcing this way can often file a single simplified declaration rather than a full DDS for each placement on the market. It is worth confirming your sourcing countries' risk classification early, since it can meaningfully reduce the documentation task ahead. 

Step 1: Confirm product scope 

Before preparing the statement, confirm that the products concerned actually fall within EUDR scope. That means identifying: 

Most organisations start by reviewing their product portfolio and procurement records to work out which products genuinely need due diligence before entering or leaving the EU market. Getting this right early means compliance resources go towards the products that actually need them, rather than being spread thinly across the whole portfolio. 

Step 2: Gather required supply-chain information 

With scope confirmed, start collecting the information needed to support due diligence. This often includes: 

Collecting this usually means close collaboration with suppliers across multiple tiers of the supply chain, not just the ones you deal with directly. Many organisations find that standardised supplier questionnaires and documentation templates make a real difference to consistency and data quality here. 

Step 3: Conduct a risk assessment 

The EUDR requires organisations to assess whether products may be associated with deforestation, forest degradation, or non-compliance with applicable legislation in their country of origin. Risk assessments typically weigh up: 

The country risk classification (low, standard or high) is a useful starting point here, since it shapes how much additional assessment is actually required. The goal throughout is to reach a defensible conclusion that overall risk can reasonably be considered negligible before products go to market, using a structured, documented methodology applied consistently across products and sourcing regions. 

Step 4: Apply risk mitigation where necessary 

Where risks come up, organisations are expected to put mitigation measures in place before proceeding. That might include: 

Only once you can genuinely conclude that identified risks have been brought down to a negligible level should the Due Diligence Statement move forward. 

Step 5: Review governance and approvals 

Preparing a DDS should go through proper governance and internal oversight rather than being signed off by a single person. Many organisations build in review from: 

Cross-functional governance means the evidence behind the statement gets checked from more than one angle, and that responsibilities are clearly assigned. It also strengthens your position considerably if a regulator asks for supporting evidence down the line. 

Step 6: Submit the Due Diligence Statement 

Once due diligence is complete and internal approvals are in place, submit the DDS through TRACES before placing products on the market or exporting them from the EU. The system will generate a unique reference number, which serves as confirmation that the organisation has met its obligations and holds the supporting documentation to prove it. 

Remember to pass that reference number on to your first known downstream buyers or traders, since they will need it to reference your DDS rather than starting from scratch. It is also worth setting up internal procedures for keeping records current and updating due diligence whenever sourcing arrangements or risk profiles shift, rather than treating the DDS as a one-off filing exercise. 

Maintaining evidence after submission 

Submitting the DDS is not the end of the process. Keep maintaining documentation covering: 

Well-organised records make future inspections and regulatory reviews considerably less stressful, and they let you respond quickly when supplier relationships or sourcing risks change, which they inevitably will. 

Common challenges organisations face 

Preparing an EUDR Due Diligence Statement tends to surface a handful of recurring practical difficulties. 

Incomplete supplier information. Many organisations struggle to get complete geolocation data or supporting documentation from suppliers, particularly in fragmented agricultural supply chains involving large numbers of small producers. Improving supplier engagement often turns out to be the single most resource-intensive part of compliance. 

Inconsistent documentation. Different suppliers tend to provide information in different formats, which makes validating and consolidating data considerably harder than it should be. Standardised documentation templates go a long way towards fixing this. 

Cross-functional coordination. The DDS needs input from procurement, sustainability, legal, compliance and operations teams. Without clear governance structures, organisations often see delays or inconsistencies creep into the review process. 

Keeping information current. Supply chains change constantly, new suppliers, new sourcing regions, revised product specifications, so organisations need a process for keeping due diligence information accurate on an ongoing basis rather than treating it as something you do once and file away. 

Building a repeatable due diligence process 

While the Due Diligence Statement is a regulatory requirement, most organisations get more value from treating it as part of a broader due diligence management system rather than a standalone task. Many businesses are integrating EUDR processes into their existing: 

This tends to improve operational efficiency while also supporting compliance across other environmental and human rights regulations at the same time. As sustainability legislation keeps evolving, organisations with well-established due diligence systems are generally better placed to adapt to whatever comes next. 

From documentation to responsible supply-chain governance 

The EUDR Due Diligence Statement is more than a regulatory declaration. It reflects the quality and effectiveness of an organisation's broader due diligence processes. A robust statement depends on reliable supplier information, accurate geolocation data, structured risk assessment and clear governance over sourcing decisions, not just a completed form submitted through TRACES at the last minute. 

For FMCG and retail organisations, compliance means moving beyond document collection towards building genuinely repeatable systems that support supply-chain transparency and continuous risk management. With the main compliance deadline now set for 30 December 2026, organisations that integrate due diligence into procurement, governance and sustainability processes now will be better placed not only to meet EUDR requirements, but to strengthen responsible sourcing practices and long-term supply-chain resilience more broadly.