---
title: "EUDR due diligence statement filing workflow"
canonical_url: "https://www.sorena.io/artifacts/eu/deforestation-regulation/dds-filing-workflow"
source_url: "https://www.sorena.io/artifacts/eu/deforestation-regulation/dds-filing-workflow"
author: "Sorena AI"
description: "A grounded workflow for filing EUDR due diligence statements: prerequisites, Article 33 information-system use, reference numbers, role handoffs, and records."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "EUDR due diligence statement"
  - "EUDR DDS filing"
  - "Article 33 information system"
  - "EUDR reference number"
  - "EUDR operators"
  - "EUDR traders"
  - "deforestation-free products"
  - "EUDR"
  - "EU Deforestation Regulation"
  - "due diligence statement"
  - "reference number"
  - "operators"
  - "traders"
---
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---

# EUDR due diligence statement filing workflow

A grounded workflow for filing EUDR due diligence statements: prerequisites, Article 33 information-system use, reference numbers, role handoffs, and records.

*EUDR* *DDS filing* *EU*

## EU Deforestation Regulation Due Diligence Statement Filing Workflow

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

Use it to connect procurement evidence, sustainability review, Article 33 information-system filing, reference-number handoff, and five-year records.

Under the EUDR, an operator must exercise due diligence before placing relevant products on the EU market or exporting them, and must not proceed without prior submission of a due diligence statement. This workflow treats filing as the controlled release step after the team has confirmed product scope, gathered Article 9 information, assessed risk, completed any needed mitigation, and identified who is allowed to submit in the Article 33 information system.

## DDS filing prerequisites

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.

- 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 risk assessment result is no or only negligible risk, or that mitigation has been completed before filing.
- Legal or trade compliance confirms the actor role and whether the Article 4 due diligence statement route, Article 4a simplified declaration route, or downstream Article 5 information route applies.

Sources for this answer:

- [Consolidated EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the prerequisite that in-scope relevant products must be deforestation-free, legally produced, and covered by the required statement or declaration before market placement or export.
- [Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1115&ref=sorena.io) - Original EUDR legal text for the regulation identity, adoption metadata, and application framework behind the filing obligation.

*Recommended next step*

*Placement: after recordkeeping section*

## Turn EUDR filing into a controlled release workflow

Connect EUDR scope checks, due diligence evidence, Article 33 filing, reference-number handoff, and five-year records before relevant products are placed, made available, or exported.

- [Open Research Copilot](/solutions/research-copilot.md): Answer EUDR implementation questions with cited source material.
- [Discuss EUDR implementation](/contact.md): Review EUDR role mapping, DDS filing controls, and evidence handoffs with Sorena.

## Filing in the Article 33 information system

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.

- Create a controlled filing record before submission: product line, commodity, supplier, production origin, due diligence file owner, risk conclusion, filing route, and approver.
- Submit the due diligence statement 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.

Sources for this answer:

- [Consolidated EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the Article 33 filing step, the no-or-negligible-risk precondition, authorised-representative submission, and simplified declaration route.
- [Commission Implementing Regulation (EU) 2024/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3084&ref=sorena.io) - Identifies the Commission implementing regulation for the EUDR information system used for due diligence statements.

## Reference numbers, identifiers, and trade release

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.

- 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 receive the reference number needed for downstream customer and trader handoff.
- If a downstream operator or trader receives new information indicating risk of non-compliance, pause further release until the verification duties in Article 5 are resolved.

Sources for this answer:

- [Consolidated EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports communication of DDS reference numbers and declaration identifiers down the supply chain, plus the Article 5 duties for downstream operators and traders.
- [EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - Commission overview source for the EUDR program context and high-level implementation dates relevant to release planning.

## 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 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.

- Operator: owns the due diligence result, filing decision, responsibility for Article 3 compliance, and five-year DDS record.
- Authorised representative: 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.

Sources for this answer:

- [Consolidated EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the role split among operators, authorised representatives, downstream operators, and traders, including five-year recordkeeping.
- [Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2650&ref=sorena.io) - Grounding source for later EUDR amendments that affect operator and trader obligation framing.

## 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 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.

- Stop before filing when the risk assessment has not reached no or negligible risk.
- Stop before release when a downstream actor has substantiated concerns and verification has not demonstrated no or negligible risk.
- Escalate after filing if new information indicates non-compliance, because the Article 5 information and notification duties may apply.
- Do not replace the Article 33 filing record with an internal memo, purchase-order note, or supplier attestation.

Sources for this answer:

- [Consolidated EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the no-or-negligible-risk stop point, risk mitigation before market placement or export, and downstream notification duties when new risk information appears.
- [Regulation (EU) 2024/3234 amending Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3234&ref=sorena.io) - Grounding source for EUDR amendment context relevant to release planning and filing controls.

## Primary sources

- [Consolidated EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Primary source for the DDS filing prerequisite, Article 33 information-system submission, reference-number handoff, simplified declarations, authorised representatives, and five-year recordkeeping.
  - Quote: "Operators shall not place relevant products on the market or export them without prior submission of a due diligence statement."
- [Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1115&ref=sorena.io) - Original EUDR legal text source for regulation identity and baseline legal context.
  - Quote: "Regulation (EU) 2023/1115"
- [Commission Implementing Regulation (EU) 2024/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3084&ref=sorena.io) - Official implementing regulation source for the EUDR information system used in the filing workflow.
  - Quote: "EUDR information system"
- [EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - European Commission overview used for high-level EUDR context and implementation-date framing.
  - Quote: "EUDR overview"

## Related Topic Guides

- [EU Deforestation Regulation FAQ](/artifacts/eu/deforestation-regulation/faq.md): Concise EU Deforestation Regulation answers on scope, covered commodities, operator and trader roles, due diligence statements, geolocation, low-risk countries, customs release, SME timing, enforcement, and records.
- [EUDR Annex I product lookup: how to check scope](/artifacts/eu/deforestation-regulation/faq/annex-i-product-lookup.md): How to check whether a product is in EUDR Annex I, connect it to a covered commodity, and keep supplier and trade evidence without relying on unsupported code lists.
- [EUDR Applicability Test: Products, EU Market Activity, and Actor Roles](/artifacts/eu/deforestation-regulation/applicability-test.md): Test whether the EU Deforestation Regulation applies by checking Annex I product scope, EU market placement or export, operator/trader status, downstream role, SME status, and simplified due diligence conditions.
- [EUDR compliance checklist for products, suppliers, and DDS filing](/artifacts/eu/deforestation-regulation/checklist.md): A practical EU Deforestation Regulation checklist covering product scope, supplier evidence, geolocation, risk assessment, mitigation, due diligence statements, recordkeeping, and customs readiness.
- [EUDR compliance obligations for operators and traders](/artifacts/eu/deforestation-regulation/compliance.md): Source-grounded EUDR compliance guide covering operator and trader duties, Article 9 information, Article 10 risk assessment, Article 11 mitigation, due diligence statements, records, and authority-readiness.
- [EUDR country benchmarking and simplified due diligence](/artifacts/eu/deforestation-regulation/country-benchmarking-and-simplified-due-diligence.md): How EUDR country-risk benchmarking affects low-risk simplified due diligence, full due diligence, information collection, risk monitoring, and evidence records.
- [EUDR country benchmarking FAQ: low, standard, and high risk](/artifacts/eu/deforestation-regulation/faq/country-benchmarking.md): What EUDR country benchmarking means, how low-risk production affects simplified due diligence, and what operators still need to collect.
- [EUDR country benchmarking triage workflow](/artifacts/eu/deforestation-regulation/country-benchmarking-triage-workflow.md): Route EUDR consignments and suppliers after country benchmarking: low-risk simplification checks, standard or high-risk due diligence, monitoring triggers, and evidence records.
- [EUDR customs and import release FAQ](/artifacts/eu/deforestation-regulation/faq/customs-and-import-release.md): How to prepare EUDR due diligence statement references, information-system handoffs, importer checks, and release evidence before customs or export clearance.
- [EUDR DDS Reference Numbers: What to Record and Pass Down](/artifacts/eu/deforestation-regulation/faq/dds-reference-numbers.md): FAQ on EU Deforestation Regulation DDS reference numbers, including operator submissions, downstream handoffs, Article 33 information-system context, and evidence records.
- [EUDR deadlines and compliance calendar](/artifacts/eu/deforestation-regulation/deadlines-and-compliance-calendar.md): A grounded EUDR calendar covering application dates, benchmarking milestones, the due diligence statement system, and preparation tasks for operators and traders.
- [EUDR deadlines, phasing, and first actions](/artifacts/eu/deforestation-regulation/deadlines-phasing-and-what-to-do-first.md): Source-grounded EUDR readiness guide covering application dates, operator and trader first actions, geolocation evidence, due diligence statements, the information system, and country benchmarking.
- [EUDR Due Diligence Statement Evidence: DDS records, geolocation, and supplier proof](/artifacts/eu/deforestation-regulation/due-diligence-statement-and-evidence.md): Build an EUDR evidence file for due diligence statements: Article 9 information, geolocation records, supplier proof, risk assessment, mitigation, reference numbers, and retention.
- [EUDR Due Diligence Statement Template](/artifacts/eu/deforestation-regulation/eudr-due-diligence-statement-template.md): A source-grounded EUDR due diligence statement template covering operator data, product scope, geolocation evidence, risk conclusion, reference numbers, and attachment records.
- [EUDR Geolocation Data Requirements: plots, suppliers, and DDS evidence](/artifacts/eu/deforestation-regulation/eudr-geolocation-data-requirements.md): How to collect, check, and use EUDR geolocation evidence for relevant commodities and products, Article 9 information, risk assessment, supplier records, and due diligence statements.
- [EUDR Geolocation Evidence and Annex I Commodity Lookup](/artifacts/eu/deforestation-regulation/geolocation-evidence-and-commodity-lookup.md): Build an EUDR evidence file that links Annex I commodity scope, supplier and trader records, geolocation evidence, product lots, risk assessment, and due diligence statement support.
- [EUDR geolocation plots and polygons FAQ](/artifacts/eu/deforestation-regulation/faq/geolocation-plots-and-polygons.md): How EUDR teams should collect, link, and use plot-level geolocation evidence for due diligence statements, suppliers, consignments, and risk assessment.
- [EUDR Geolocation Traceability Systems: records, DDS handoffs, and supplier evidence](/artifacts/eu/deforestation-regulation/geolocation-traceability-and-systems.md): How to structure EUDR traceability records for geolocation, supplier evidence, product lots, risk assessment inputs, and due diligence statement handoffs.
- [EUDR in-scope commodities and products](/artifacts/eu/deforestation-regulation/in-scope-commodities-and-products.md): How to check EUDR scope for the seven commodities, Annex I relevant products, operator and trader roles, and the evidence needed to support a scope decision.
- [EUDR information system filing: DDS references and handoffs](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md): FAQ guidance on EUDR information system filing, due diligence statement submission, declaration identifiers, downstream handoffs, representatives, and evidence retention.
- [EUDR non-negligible risk: what stops product release?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md): FAQ on how EUDR Articles 10 and 11 handle non-negligible risk, when operators should stop placement or export, and what evidence belongs in the file.
- [EUDR operator, trader, and downstream roles FAQ](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md): How to classify EUDR operators, downstream operators, and traders, including market-placement triggers, DDS reference handoffs, non-SME duties, and evidence records.
- [EUDR Penalties and Enforcement: Checks, Corrective Action, and Sanctions](/artifacts/eu/deforestation-regulation/penalties-and-enforcement.md): Grounded guide to EUDR enforcement: competent authority checks, interim measures, corrective action, EU penalty categories, and records to keep ready.
- [EUDR Penalties, Fines, and Enforcement Consequences](/artifacts/eu/deforestation-regulation/penalties-and-fines.md): Grounded guide to EUDR enforcement exposure: Member State penalties, competent authority checks, corrective measures, product holds, and evidence records without invented national fine tables.
- [EUDR requirements for operators, traders, and DDS filing](/artifacts/eu/deforestation-regulation/requirements.md): Source-grounded guide to EU Deforestation Regulation requirements: scope, due diligence, geolocation, risk assessment, mitigation, DDS filing, records, and simplified regimes.
- [EUDR risk assessment and mitigation under Articles 10 and 11](/artifacts/eu/deforestation-regulation/risk-assessment-and-mitigation.md): How to run an EUDR Article 10 risk assessment, decide when risk is not negligible, apply Article 11 mitigation, and keep release evidence before placing products on the EU market or exporting.
- [EUDR simplified due diligence: low-risk country evidence FAQ](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md): FAQ answer on when EUDR simplified due diligence applies, what Article 9 information remains required, when Articles 10 and 11 return, and what records to keep.
- [EUDR SME timing: which dates apply to micro, small, and medium businesses?](/artifacts/eu/deforestation-regulation/faq/sme-timing.md): FAQ on EUDR SME timing, including the 30 December 2026 main application date, the 30 June 2027 later date for certain micro and small undertakings, and first evidence records to prepare.
- [EUDR Supplier Evidence FAQ](/artifacts/eu/deforestation-regulation/faq/supplier-evidence.md): What supplier evidence to collect for EUDR Article 9 information, geolocation, risk assessment, due diligence statements, and downstream recordkeeping.
- [EUDR Supplier Onboarding Template](/artifacts/eu/deforestation-regulation/supplier-onboarding-template.md): A practical EUDR supplier onboarding template for Annex I product scope, supplier roles, geolocation evidence, risk inputs, mitigation records, DDS references, and five-year records.
- [EUDR vs CSDDD: product due diligence vs corporate due diligence](/artifacts/eu/deforestation-regulation/eudr-vs-csddd.md): Compare EUDR product-level deforestation controls with high-level corporate due-diligence workstreams, focusing on scope, actors, due diligence statements, geolocation, country benchmarking, and evidence.
- [How is the EU Deforestation Regulation enforced?](/artifacts/eu/deforestation-regulation/faq/enforcement.md): EUDR FAQ on competent authority checks, evidence requests, due diligence records, and grounded non-compliance consequences.


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