Under EUDR, the due diligence statement is not a reporting afterthought. It is the operational gate that allows relevant products to be placed on the market or exported. Operators submit a DDS unless the Regulation gives them access to the simplified declaration route. Your job is to build an evidence pipeline that produces a defensible submission, stores the right artifacts for years, and makes DDS reference numbers or declaration identifiers flow downstream reliably.
1
Section 1
1) What is a DDS and why it should be a hard shipping gate
A DDS is the formal mechanism by which operators take responsibility for compliance for relevant products they intend to place on the market or export. Treat it as a hard gate in your process: no reference number, no ship.
Design the gate so it is enforceable in ERP/logistics systems, not just in policy.
Define where the gate lives (purchase order release, warehouse picking, customs/export docs, etc.)
Store DDS reference numbers at batch/lot level and link them to shipments and invoices
Build exception handling: supplier non-response, data quality failures, corrections
2
Section 2
2) Who submits and who remains responsible
Operators may mandate an authorised representative to submit the DDS or simplified declaration on their behalf, but the operator retains responsibility for Article 3 compliance.
Micro or small primary operators follow the simplified declaration route in Article 4a, while other operators still need the full DDS route. If you delegate submission, you still need the evidence and the internal approvals.
Document delegation: which role submits vs which role approves risk outcome
Document whether the flow uses a DDS reference number or a declaration identifier
Keep an internal approval trail: scope, risk decision, and mitigation actions
Ensure access controls and audit logs for the submission process
3
Section 3
3) Evidence categories you should always be able to produce (Articles 9-11 structure)
Due diligence includes information collection, risk assessment, and risk mitigation. Build your evidence pack around that structure so it's easy to defend.
Geolocation and legality evidence are common blockers-design them as first-class artifacts.
Information collection: geolocation of plots/establishments (as applicable) and documentation demonstrating deforestation-free and legal production
Risk assessment: model inputs (origin, supplier, mixing/circumvention), decision record, and approval
Risk mitigation: actions taken when risk is not negligible and the reassessment outcome
Traceability: batch/lot linkage from input commodity to finished goods
Recommended next step
Keep EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence DDS and Evidence Pack in one governed evidence system
SSOT can take EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence DDS and Evidence Pack from reusing this material inside a governed evidence system to a reusable workflow inside Sorena. Teams working on EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence can keep owners, evidence, and next steps aligned without copying this guide into separate documents.
4) Reference number handoff and Article 5 downstream duties
Operators must keep a record of due diligence statements for five years and communicate DDS reference numbers or declaration identifiers further down the supply chain.
Downstream operators and traders must keep the Article 5 information set for at least five years as well. Make this deterministic: downstream recipients should receive structured identifiers, not screenshots or PDFs.
Add DDS reference numbers to invoices, ASNs, and product passports/traceability records where relevant
Require structured handoff in B2B integrations (EDI/API fields, not free text)
Retain downstream recipient history showing who received which reference numbers or declaration identifiers and when
5
Section 5
5) Retention and audit-readiness: make evidence retrievable fast
Retention is not just storage-it's retrieval. Your evidence pack must be queryable by lot, shipment, supplier, and production site.
Build a 'competent authority request drill': can you produce the evidence within hours, not weeks?
Retention policy aligned to the Regulation's retention expectations (DDS references and related evidence)
Indexing: lot/shipment -> supplier -> production site -> geolocation -> evidence documents
Immutable logs: who accessed/changed evidence and when
Operator obligation to submit a DDS before placement or export, simplified declaration rules for Article 4a operators, and due diligence structure in Articles 8 to 11, including geolocation and evidence collection in Article 9 and retention and communication of identifiers.