The Due Diligence Statement (DDS) must be filed electronically through the EU Information System (TRACES NT). This checklist helps you organize the required data before filing — it is not a DDS itself. You cannot create a DDS in a Word document or PDF; it is an electronic submission with structured fields filed through the official system.
The EU Information System (TRACES NT) has been undergoing updates. Check ec.europa.eu for current availability before planning submissions. An interactive version of this template is available at /tools/supply-chain-template.
What is a Due Diligence Statement?
Under Article 4(2) of Regulation (EU) 2023/1115, a DDS is a structured electronic declaration confirming that due diligence was exercised and risk is negligible. Each DDS receives a unique reference number that competent authorities can check at any point in the supply chain.
Enforcement begins December 30, 2026 for large and medium operators; June 30, 2027 for micro and small enterprises. Under amending Regulation (EU) 2025/2650, operators may file a multi-batch DDS for repeated consignments from the same supply chain, valid up to one year, provided the risk assessment remains current.
What this template covers
This checklist organizes every data field required for a DDS filing by Article 4(2) category. Gather and verify each item before beginning your electronic submission.
Operator / Trader Identification
- Full legal name and registered address of the filing entity
- EORI number (Economic Operators Registration and Identification number)
- Indicate role: operator (first placement / export) or trader (resale within the EU)
- If filing as a trader: reference number(s) of the upstream operator's DDS
- Contact details of the person responsible for the filing
- If applicable: authorized representative details for non-EU operators
Operators must complete all fields below. Traders may submit a simplified DDS referencing the upstream operator's DDS reference number, but must still conduct their own risk assessment.
Product Description
- Product description and trade name
- CN/HS code — verify against EUDR Annex I to confirm the product is in scope
- Scientific name of the species (genus and species for timber; species for animal products)
- List of all EUDR commodity groups contained in or used to produce the product
- For composite products: each EUDR-covered commodity component and its proportion
Country of Production
- Country where the commodity was produced (grown, harvested, or raised)
- Sub-national region, where applicable or where the Commission has assigned sub-national risk classifications
- For multi-origin products: each country and its corresponding production plots
Geolocation Data
- Geolocation coordinates for each production plot
- Plots over four hectares: polygon boundaries (GeoJSON, WGS84/EPSG:4326, six decimal places)
- Plots of four hectares or less: centroid coordinates (same reference system and precision)
- Verification that coordinates are field-captured, not estimated from administrative boundaries
- Data capture timestamps for geolocation collection
- Total number of production plots in the consignment
This is the field most likely to cause DDS rejection. Data must be traceable to specific plots, not aggregated at the cooperative or regional level. See the EUDR Geolocation Data Collection Template for specifications.
Quantity
- Net mass of the product (in kilograms)
- Volume, where applicable (in cubic metres for timber; litres for oils)
- Number of items, where applicable
- For multi-batch DDS (Regulation EU 2025/2650): estimated total quantity for the period, updated as consignments ship
Risk Assessment Conclusion
- Documented conclusion: risk assessed as negligible or non-negligible
- Summary of reasoning and evidence supporting the conclusion
- If originally non-negligible: mitigation measures under Article 11 that reduced risk to negligible
- Country or sub-national risk classification assigned by the Commission
- Confirmation that the three-step due diligence process (Articles 9, 10, 11) was completed
- Date the risk assessment was completed
Do not file a DDS asserting negligible risk if your evidence does not support it. If mitigation has not resolved non-negligible risk, the product must not be placed on the EU market.
Risk Mitigation Measures (if applicable)
- Description of each mitigation measure and evidence obtained
- Confirmation that the chain of custody uses physical segregation or identity preservation — mass balance is prohibited under the EUDR
- Residual risk assessment confirming risk has been reduced to negligible
- For independent audits or site visits: scope, date, auditor, and findings
Supporting Documentation (retained, not filed in the DDS)
- Complete evidence file supporting each DDS field — retained for five years from filing date
- Raw geolocation data files, satellite imagery, and deforestation screening reports
- Supplier documentation: contracts, invoices, delivery records, certifications
- Legality evidence: land titles, permits, labour compliance records, tax records
- Chain of custody records and risk assessment working documents
How to use this template
Step 1: Complete the EUDR Supply Chain Due Diligence Checklist first. This checklist assumes due diligence is done and you are organizing data for filing.
Step 2: Work through each section, assembling data in structured format. For each field, confirm you have the underlying evidence — not just the data point.
Step 3: Confirm your role (operator or trader), verify CN/HS codes against Annex I, and decide whether to file per-consignment or multi-batch DDS.
Step 4: Transfer organized data into the EU Information System when available. Retain all supporting evidence for five years.
How to implement this in your organisation
Assign ownership. Your compliance officer or sustainability manager owns this checklist and is accountable for assembling complete DDS data packages. Procurement, processing, and logistics teams contribute the underlying evidence; the person responsible for the TRACES NT submission reviews the final package before filing.
Set the review cadence. Reassess data readiness quarterly and immediately when triggered by a new supplier entering the supply chain, a new production plot, or a country risk reclassification by the European Commission. For multi-batch DDS filings, verify that the underlying supply chain and risk assessment remain unchanged before each consignment ships under the existing reference number. Refer to the relevant commodity-specific checklist for operational details on evidence collection timing.
Define your escalation path. Any missing or unverifiable data field halts DDS filing until the gap is resolved. The responsible team member escalates unresolved gaps to the export manager within 48 hours, documenting the missing field and proposed remediation timeline. Do not file a DDS asserting negligible risk when the evidence does not support it.
Connect to existing workflows. Integrate DDS data assembly into your export documentation workflow so evidence compilation runs in parallel with commercial invoicing and shipping instructions. Link geolocation and risk assessment data feeds to your existing supplier management system, and store completed DDS packages alongside export records for the mandatory five-year retention period.
Who needs this template
- Compliance officers preparing to file DDS submissions for the first time
- Exporters who need to provide EU buyers with all data elements required for the buyer's DDS filing
- EU importers (operators) who bear primary legal responsibility and must ensure every field is substantiated
Can I file a single DDS covering multiple shipments?
Yes. Under Regulation (EU) 2025/2650, a multi-batch DDS covers repeated consignments from the same supply chain for up to one year. The underlying supply chain, geolocation data, and risk assessment must remain unchanged. Any material change — new supplier, production plot, or risk classification — requires a new filing.
What is the difference between the operator DDS and the trader DDS?
Operators complete a full DDS with all Article 4(2) fields. Traders may submit a simplified DDS referencing the upstream operator's reference number. Traders must still verify the upstream DDS exists and conduct their own risk assessment, but need not independently collect geolocation data already in the operator's filing.
What happens if filed DDS information turns out to be incorrect?
Operators must review due diligence at least annually. If new information reveals incorrect data or an invalid risk conclusion, corrective action is required: amend the DDS, notify competent authorities, and suspend trade in the affected product. Failure to correct known errors is a separate violation.
How long will the DDS filing process take?
Filing time depends on data readiness. If geolocation data, risk assessment, and evidence are organized, the electronic submission is straightforward data entry. The preparation — gathering evidence, completing due diligence, organizing fields — is the real investment. This checklist reduces that time by specifying exactly what is needed.
Ready to organize your DDS data with evidence-grade traceability? ResourceLedger helps operators and exporters structure every DDS field — from geolocation capture to risk assessment documentation — so your filing is substantiated before submission. Book a demo to see how it works.