Declarations and the Information System

14.1 The due diligence statement (DDS)

The DDS is the formal instrument submitted in the Information System before a product is placed on the market or exported. Its mandatory content (Annex II):

1. The operator's name and address and, for imports and exports, the EORI number.
2. The HS code, a free-text description, the trade name and, where applicable, the full scientific name, and the quantity (for import/export, kg of net mass and the supplementary unit where one is defined; in other cases, net mass with an estimate or percentage of deviation, volume or number of units).
3. The country of production and the geolocation of every plot (or of every establishment, for cattle).
4. (Deleted by Regulation (EU) 2025/2650.)
5. The standard wording: "By submitting this due diligence statement the operator confirms that due diligence in accordance with Regulation (EU) 2023/1115 was carried out and that no or only a negligible risk was found that the relevant products do not comply with Article 3, point (a) or (b), of that Regulation."
6. The signature block: "Signed for and on behalf of; Date; Name and function; Signature".

By submitting the DDS the operator assumes responsibility for compliance (Article 4(3)) and receives a reference number and a verification number.

14.2 The simplified statement (Annex III)

For MSPOs: name and address (and EORI, where importing or exporting); HS code, description and a single estimated annual quantity; country of production and geolocation or postal address of the plots or establishments; and standard wording by which the MSPO confirms that it will carry out due diligence and will place on the market only products with no risk or negligible risk. It generates a statement identifier. For irregular production (forest harvesting every 30 years, say), the annual quantity is based on the years of actual production, on multi-year plans or on the last normal year of sales (FAQ 3.30).

14.3 One DDS, several lots (FAQ 5.19)

A single DDS may cover several lots or physical consignments of several products, subject to these conditions:

• the total quantity placed on the market must be covered by a DDS submitted before any lot is placed on the market;
• once the declared quantity is used up, a new DDS is needed for additional quantities;
• because the due diligence system is reviewed annually, a DDS should not cover consignments for more than one year from submission;
• in principle the DDS covers products already produced (harvested); exceptionally it may be submitted before harvest where the operator sources from stable plots whose legality and freedom from deforestation are unchanged; the final product need not already be manufactured;
• the declared quantities must match those that went through due diligence; a product should not be covered by several DDS from the same person; where it is not known which products will go to the EU market and which will be exported, everything may be declared in an export DDS, keeping reconciliation records;
• quantity declared but not placed on the market requires records explaining the difference, kept for five years;
• the practical limit of 25 MB per DDS applies;
• a DDS covering many lots increases complexity — and risk: interim or non-compliance measures may reach every lot under that DDS.

14.4 When to submit (FAQ 5.20 and 5.21)

• Import and export: the DDS must be submitted and the reference number obtained before the customs declaration, in which the declarant states the number. The same number may appear in several customs declarations, and one customs declaration may contain several numbers.
• Internal market: placing on the market occurs when three elements come together: (1) the product is physically available; (2) there is a supply agreement between the parties; (3) physical delivery has begun, where there is any (loading the truck, for instance). Without physical delivery, (1) and (2) suffice.
• The earliest possible date: after due diligence has been carried out and with all the information available, including the expected quantity.
• Withdrawal or amendment: possible within 72 hours of the reference number being issued, unless the number has already been used in a customs declaration, the product has already been placed on the market or exported, or the operator has been notified of a check (FAQ 7.6).

14.5 The Information System

Article 33 required the Commission to create the system — launched on 04/12/2024 on the TRACES platform — with functions for registering operators, downstream operators and non-SME traders and authorised representatives; recording DDS and simplified statements; converting data into geolocation where possible; recording the results of checks; interconnection with customs through the Single Window; risk profiles; and cooperation and communication between authorities and companies. Complete anonymised datasets must be made publicly available in an open format (Article 33(5)).

14.6 Customs (Articles 26 to 28)

• Products released for free circulation or exported are subject to risk-based customs controls; overall responsibility for enforcing the EUDR lies with the competent authorities (Article 26(1) to (3)).
• The DDS reference number (or the MSPO identifier) must be given to customs before release for free circulation or export. This does not apply to exports by a downstream operator, which may use a specific TARIC certificate code (Article 26(4); FAQ 5.6.1).
• For transition-period products that are exported or re-imported, the conventional reference number in the format 99EU9999999999 is used (FAQ 9.2).
• Once the electronic interface provided for in Article 28 is in place (to be operational by 01/12/2029), customs will automatically check the status of the DDS and suspend release of flagged products; until then they cooperate with the competent authorities (Article 26(5) to (9)).
• Customs release is not proof of compliance (Article 26(10)).
• There is no obligation to state the DDS number on invoices or transport documents (FAQ 7.21).
• Only the customs declaration — not a bill of lading — serves as proof that imported products were placed on the market (FAQ 5.6).