EUDRDDS evidenceEU

EUDR due diligence statement evidence file

Use this page to assemble the records that should sit behind an EUDR due diligence statement before a relevant product is placed on the EU market or exported.

It focuses on Article 9 information and evidence, geolocation, supplier records, risk assessment and mitigation support, information-system references, and retention.

Author
Sorena AI
Published
May 9, 2026
Updated
May 25, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 25, 2026
Overview

Under the EU Deforestation Regulation, the due diligence statement is not the evidence itself. It is the filing that follows a due diligence process showing that the relevant product is deforestation-free, produced in accordance with relevant legislation in the country of production, and covered by the required statement or declaration. The evidence file should let a company reviewer or competent authority connect the product, commodity, plots or establishments, supplier chain, risk conclusion, mitigation work, and DDS reference records without relying on unsupported narrative.

Section 1

What belongs in the evidence file behind an EUDR due diligence statement?

Start the file with the product and actor facts: the relevant commodity or Annex I product, the operator or trader role, the placing-on-market or export event, and whether the product is supported by a due diligence statement or, where the simplified regime applies, a simplified declaration identifier.

Then connect those facts to Article 9 information collection. The file should preserve the information and evidence used to show the product is deforestation-free and legally produced, including plot or establishment location evidence, supply-chain information, and the records provided to competent authorities on request.

  • Product scope record: commodity, derived product, CN or company SKU reference where used, market event, and actor role.
  • Article 9 information pack: supplier identities, country of production, quantity or batch link, and evidence demonstrating deforestation-free and legal production.
  • Geolocation record: plot-level or establishment location data for production, with the applicable simplified-rule substitute recorded only where the EUDR grounding supports it.
  • DDS filing record: due diligence statement submission, Article 33 information-system reference number, and any simplified declaration identifier passed through the supply chain.
  • Authority-response pack: the version of the evidence file that can be provided to competent authorities when requested.
Recommended next step

Review the evidence behind your EUDR DDS process

Use this EUDR evidence guide to check whether Article 9 information, geolocation records, supplier evidence, risk conclusions, DDS references, and retention controls are connected before a statement is filed.

Section 2

Article 9 information and evidence records

Treat Article 9 as the intake checklist for the DDS evidence pack. The operator should be able to show what information was collected, where it came from, who checked it, and how it was preserved before the risk assessment was completed.

The strongest record links each product lot or shipment to the supplier evidence, geolocation evidence, and legality evidence used for that specific due diligence conclusion. A broad supplier policy or annual sustainability report is not a substitute for product-linked evidence.

  • Supplier record: direct supplier, upstream supplier data available to the operator, and the person or team that validated the supplied evidence.
  • Production-location record: country of production and geolocation of plots of land or establishments, with postal-address substitution recorded only for micro or small primary operators where applicable.
  • Deforestation-free support: maps, plot records, harvest or production records, or other evidence tied to the relevant product and production location.
  • Legal-production support: documents used to show production complied with relevant legislation in the country of production.
  • Evidence availability record: where the Article 9 information is stored and how it can be provided to competent authorities on request.
Section 3

Risk assessment and mitigation evidence

The due diligence statement should not be filed while risk remains unresolved. The evidence file should show the risk assessment conclusion and the facts behind it: whether the assessment found no or only negligible risk of non-compliance, or whether mitigation was required before the product moved.

When risk is not negligible, keep the mitigation evidence with the same product record. The reviewer should see the original concern, the mitigation action, the revised conclusion, and the approval to proceed. If the product is produced in a low-risk country or part of a country, the file should still document the supply-chain complexity and circumvention or mixing checks that support simplified due diligence.

  • Risk assessment memo: product, supplier, production location, evidence reviewed, risk factors considered, and no-or-negligible-risk conclusion.
  • Mitigation log: extra supplier information, independent checks, segregation or chain-of-custody controls, corrective actions, and residual-risk approval.
  • Stop condition: if the risk assessment does not reach no or negligible risk after mitigation, do not file the DDS for that product movement.
  • Low-risk production file: country or part-of-country classification used, supply-chain complexity review, and documentation showing negligible risk of circumvention or mixing.
Section 4

Geolocation and supplier evidence controls

Geolocation data should be managed as controlled compliance evidence, not as a free-text supplier attachment. The record needs enough structure to show which plots or establishments supplied the relevant product and which DDS or declaration record used that data.

Supplier evidence should also preserve the supply-chain handoff. Downstream operators and traders need the required supply-chain information, including supplier details and, when the supplier is an operator, the due diligence statement reference number or declaration identifier.

  • Link each geolocation dataset to the supplier, product batch or shipment, production period used by the company, and evidence version.
  • Record whether the geolocation evidence is plot-level or an allowed postal-address substitute for a micro or small primary operator.
  • Keep supplier-provided evidence separate from validation notes so reviewers can see what was received and what was checked.
  • Pass DDS reference numbers or simplified declaration identifiers downstream with the product information rather than burying them in email threads.
  • Flag supplier evidence for escalation when the location, commodity, product identity, or reference number cannot be matched to the shipment.
Section 5

Reference numbers, declaration identifiers, and retention

A DDS evidence file should close with the filing identifiers and retention record. For operators, keep the due diligence statement record for five years and communicate DDS reference numbers to downstream operators and traders. Where the simplified declaration regime applies, keep the declaration identifier instead of treating the simplified filing as an ordinary supplier certificate.

For downstream operators and traders, preserve the Article 5 supply-chain information for at least five years and make it available to competent authorities on request. If new information indicates possible non-compliance, the evidence file should show who was informed, what verification happened, and whether the product was stopped before placement, making available, or export.

  • DDS log fields: product, supplier, operator, Article 33 submission, DDS reference number, evidence-file version, and downstream recipients informed.
  • Simplified declaration fields: micro or small primary operator status check, declaration submission, declaration identifier, and supporting Article 9 substitute data where applicable.
  • Verification or tracking number fields: keep them as pointers to the official DDS reference number or declaration identifier unless the source system clearly labels a different official filing identifier.
  • Downstream information fields: supplier details, upstream DDS reference number or declaration identifier, downstream recipient details, and authority-response owner.
  • Retention control: five-year record clock for operator DDS records and at-least-five-year retention for Article 5 downstream supply-chain information.
  • New-information control: substantiated concern, non-compliance signal, authority notice, downstream notice, verification result, and placement/export hold decision.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Identifies the implementing act represented in the grounding data for the EUDR information system used for due diligence statements.
"Commission Implementing Regulation (EU) 2024/3084 on the EUDR information system."
eur-lex.europa.eu
Referenced sections
  • Supports retention and authority-access expectations for downstream operators and traders under Article 5.
"They keep the Article 5 information for at least five years."
environment.ec.europa.eu
Referenced sections
  • Supports the practical proof expectation for operators and traders placing relevant commodities on the EU market or exporting them.
"Operators and traders must be able to prove that the products do not originate from recently deforested land."
eur-lex.europa.eu
Referenced sections
  • Supports the core Article 3 conditions that relevant products must be deforestation-free, legally produced, and covered by the required statement or declaration.
"Relevant commodities and relevant products must not be placed or made available on the market or exported unless they are deforestation-free."
Related guides

Explore more topics

EU Deforestation Regulation FAQ
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
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
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
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
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
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
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
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
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
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
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
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 filing workflow
A grounded workflow for filing EUDR due diligence statements: prerequisites, Article 33 information-system use, reference numbers, role handoffs, and records.
EUDR Due Diligence Statement Template
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
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
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
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
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
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
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?
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
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
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
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
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
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
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?
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
What supplier evidence to collect for EUDR Article 9 information, geolocation, risk assessment, due diligence statements, and downstream recordkeeping.
EUDR Supplier Onboarding Template
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
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?
EUDR FAQ on competent authority checks, evidence requests, due diligence records, and grounded non-compliance consequences.