EU Deforestation Regulation Due Diligence Statement Filing Workflow

Start with the release event: a relevant product is being placed on the EU market or exported. Confirm that the product is in Annex I scope, that the responsible actor is an operator, downstream operator, trader, micro or small primary operator, or authorised representative, and that the product is covered by the right filing route before shipment or EU market release is approved.

A standard operator filing should not be prepared until the due diligence file supports the Article 3 conditions: the relevant product is deforestation-free, produced in accordance with the relevant legislation of the country of production, and covered by a due diligence statement or simplified declaration as applicable.

Once due diligence concludes no or only negligible risk, the operator makes the due diligence statement available to competent authorities through the Article 33 information system. The filing owner should be the operator or an authorised representative acting under mandate; using a representative does not move responsibility for EUDR compliance away from the operator.

For a micro or small primary operator that qualifies for the simplified route, the filing event is a one-time simplified declaration in the same Article 33 information system before placing on the market or exporting. The team should separate these simplified declarations from ordinary operator DDS filings because the evidence fields and downstream identifier differ.

After filing, the reference number or simplified declaration identifier becomes the operational handoff item. Operators must communicate due diligence statement reference numbers, or declaration identifiers where applicable, to downstream operators and traders further down the supply chain.

For import, export, and order-release controls, do not let the commercial shipment record stand alone. Link the shipment, purchase order, sales order, or export release to the relevant DDS reference number or declaration identifier so downstream recipients and trade-compliance reviewers can verify that the filing prerequisite was met before the product is placed, made available, or exported.

The filing workflow needs separate owners for the evidence file, risk conclusion, information-system submission, and downstream handoff. That separation matters because the person submitting the statement may not be the person who collected supplier evidence or approved the no-or-negligible-risk conclusion.

Keep the due diligence statement record, the supporting due diligence evidence, and the downstream handoff log together for the retention period. Operators keep a record of due diligence statements for five years; downstream operators and traders keep required supply-chain information for at least five years and provide it to competent authorities on request.

The filing owner should stop the DDS submission if the product scope is not tied to Annex I, if the due diligence file does not demonstrate no or negligible risk, if required geolocation or permitted replacement information is missing, or if the filer cannot identify the responsible operator or authorised representative.

If the team discovers risk information after a product has been placed, made available, or exported, downstream operators and traders have separate duties to inform competent authorities and downstream recipients. Treat already-submitted DDS records as a competent-authority-facing legal review issue unless a documented correction or withdrawal procedure is available for the specific filing scenario.