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EUDRDDS filingEU

EU Deforestation Regulation Due Diligence Statement Filing Workflow

A practical workflow for filing an EUDR only after scope, due diligence, risk, and role prerequisites are in place.

The main obligations apply from 30 December 2026; the later 30 June 2027 date applies only to the micro and small group specified in Article 38(3).

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
5 sections5 primary sources
Overview

Under Regulation (EU) 2023/1115, the EU Deforestation Regulation (EUDR), the operator files the before placing an in-scope relevant product on the EU market or exporting it, and only after due diligence supports no or negligible risk. Downstream operators and traders do not file a second statement for products already covered upstream; Article 5 requires them to hold the prescribed supply-chain information and apply the new-information and substantiated-concern duties that match their status. A qualifying micro or small primary operator uses the one-time simplified declaration under Article 4a instead of an ordinary DDS.

Section 1

DDS filing prerequisites

Start with the release event and the actor. An operator placing an Annex I relevant product on the EU market or exporting it uses the Article 4 DDS route. A downstream operator or trader follows Article 5 without submitting another DDS. A qualifying micro or small primary operator uses Article 4a. An may submit for an operator under mandate, but the operator retains responsibility.

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 or simplified declaration as applicable.

  • Procurement confirms commodity and product scope, supplier identity, country of production, and supply-chain boundaries.
  • Sustainability or compliance collects Article 9 information and evidence, including geolocation or permitted replacement information where the simplified primary-operator route applies.
  • Risk review confirms the applicable no-or-negligible-risk basis: an Article 10 risk assessment and any required mitigation, or the Article 13 simplified-due-diligence checks.
  • Legal or trade compliance confirms the actor role and whether the Article 4 route, Article 4a simplified declaration route, or downstream Article 5 information route applies.
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Section 2

Filing in the Article 33 information system

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

Build the submission from Annex II, not from a generic internal checklist. The DDS contains the operator's name and address and, for products entering or leaving the market, Economic Operators Registration and Identification (EORI) number; the Harmonised System (HS) customs classification code and product description, trade name and scientific name where applicable; quantity in the prescribed unit; country of production; geolocation for all plots or establishments; and the required operator declaration. The Information System assigns the filing identifiers used for later handoff.

For a micro or small primary operator that qualifies under Article 2, the filing event is a one-time simplified declaration containing the Annex III information. The operator may update that declaration after a major change to the information supplied. Keep this route separate from an ordinary DDS because its eligibility test, information fields, and declaration identifier differ.

  • Create a controlled filing record before submission: product line, commodity, supplier, production origin, due diligence file owner, risk conclusion, filing route, and approver.
  • Reconcile the final Annex II product description, HS code, quantity and unit, production country, geolocation coverage, and EORI field where applicable against the evidence file.
  • Submit the only after the release approver confirms that the due diligence file supports no or negligible risk.
  • For authorised-representative filing, keep the mandate and the operator responsibility statement with the DDS record.
  • For simplified declarations, record the declaration identifier and the basis for treating the filer as a micro or small primary operator.
Section 3

Reference numbers, identifiers, and trade release

After filing, the DDS reference number or simplified declaration identifier becomes the operational handoff item. Article 4 requires operators to communicate the relevant reference number or declaration identifier to downstream operators and traders. The system also assigns a verification number for access control; do not publish or pass it as though it were the Article 4 supply-chain reference.

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.

  • Trade compliance stores the DDS reference number or declaration identifier with the shipment or release record.
  • Procurement and supplier management pass received reference numbers into downstream product records instead of keeping them only in email threads.
  • Sales or distribution teams pass the official reference number or declaration identifier when acting as an operator supplying downstream operators or traders. Further downstream, distinguish any voluntary reference-sharing control from the Article 5 requirement to collect references only when the supplier is an operator.
  • If a non-SME downstream operator or non-SME trader receives a substantiated concern, pause further release until Article 5 verification demonstrates no or negligible risk. Apply the separate Article 5 notification duties when any downstream operator or trader obtains relevant new information after placement or availability.
Section 4

Roles and recordkeeping

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 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.

  • Operator: owns the due diligence result, filing decision, responsibility for Article 3 compliance, and five-year DDS record.
  • : may submit the DDS or simplified declaration under mandate, while the operator retains compliance responsibility.
  • Non-SME downstream operator or non-SME trader: registers in the Article 33 information system before placing, making available, or exporting relevant products.
  • Downstream operator or trader: keeps supplier details, received DDS reference numbers or declaration identifiers, and downstream recipient information for at least five years.
Section 5

When the DDS file should stop before submission

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 .

If information in a draft does not match the evidence, stop before submission. If information changes after submission, use the Information System's amendment or withdrawal function only when the applicable rule and filing status permit it; preserve the prior record and reason. Separately, new non-compliance information can trigger Article 4 or 5 notification duties to competent authorities and affected supply-chain recipients.

  • Where Article 10 applies, stop before filing when the risk assessment has not reached no or negligible risk.
  • For a non-SME downstream operator or non-SME trader with substantiated concerns, stop before release until Article 5 verification demonstrates no or negligible risk.
  • After market placement, an operator receiving information indicating non-compliance risk must immediately notify the relevant competent authorities and downstream recipients under Article 4(5). Downstream operators and traders apply their separate Article 5 notification duties.
  • Do not replace the Article 33 filing record with an internal memo, purchase-order note, or supplier attestation.
Primary sources

References and citations

Consolidated Regulation (EU) 2023/1115
eur-lex.europa.eu6 citations
Referenced sections
  • Primary source for the DDS prerequisite, Annex II fields, Article 33 submission, reference-number handoff, simplified declarations, authorised representatives, application dates, and recordkeeping.
  • Articles 3 to 6 and 38 support the product conditions, actor-specific filing routes, authorised-representative rule, and application dates.
  • Articles 4, 4a, 6, and Annexes II and III support the filing step, mandatory data, no-or-negligible-risk precondition, authorised-representative submission, and simplified declaration route.
Show 3 more
  • Articles 4 and 5 distinguish the operator's reference-number handoff from the information held by downstream operators and traders.
  • Articles 4 to 6 support the role split, registration rule, authorised-representative mandate, five-year DDS retention, and at-least-five-year Article 5 retention.
  • Articles 4, 5, 10, and 11 support the stop point, mitigation before placement or export, and notification duties when new risk information appears.
Commission Implementing Regulation (EU) 2026/1565
eur-lex.europa.eu3 citations
Referenced sections
  • Current Information System amendment covering DDS administration, simplified declarations, and grouped records.
  • Current amendment to the Information System rules, including simplified declarations, updates after major changes, and grouped DDS or declaration identifiers.
  • Sets current Information System rules relevant to amending or withdrawing a submitted record, rejecting a record, and simplified declarations.
EUDR overview
environment.ec.europa.eu2 citations
Referenced sections
  • European Commission overview used for the current application-date framing.
  • Commission overview supporting the 30 December 2026 and 30 June 2027 application dates used in release planning.
Regulation (EU) 2025/2650
eur-lex.europa.eu
Referenced sections
  • Amending act that introduced the current simplified-declaration and downstream-actor framework.

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