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EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence DDS Template

Standardize your DDS submissions with a repeatable structure and evidence checklist.

Use this template as the internal 'approval packet' even if submission happens via the information system UI/API.

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Author
Sorena AI
Published
Feb 22, 2026
Updated
Feb 23, 2026
Sections
7

Structured answer sets in this page tree.

Primary sources
2

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 22, 2026
Updated Feb 23, 2026
Overview

This is an internal template outline to standardize how your teams prepare an EUDR due diligence statement. The goal is consistency and auditability: every DDS is backed by an evidence pack (geolocation, legality, deforestation-free proof), a risk decision, and mitigation actions where risk is not negligible. Tailor it per commodity and supplier group.

Section 1

1) Header: DDS context (what product flow is being covered)

Start by naming the product flow you're covering: SKU group, commodity type, and whether you're placing on the market or exporting.

Link the DDS to the batch/lot identifiers that your logistics team actually uses.

  • Product group and Annex I mapping (commodity/derived product category)
  • Activity: placing on the market vs exporting (and from which Member State entity)
  • Batch/lot identifiers and shipment window covered
  • Owner and approver (operator responsibility owner)
Section 2

2) Supply chain and origin (who supplied what, and where it was produced)

EUDR evidence starts with origin and chain-of-custody. Capture it in structured fields, not free text.

If origin is multi-region or changes by lot, record it per lot.

  • Supplier identity and upstream chain (as far as needed for traceability and risk)
  • Country of production and origin per lot/batch
  • Chain-of-custody model (segregation vs mass balance) and mixing controls
  • Downstream recipients (who will receive the DDS reference number)
Section 3

3) Geolocation annex (the most common blocker)

Geolocation is a key evidence category. Treat it as a validated annex: provenance, validation checks, and linkage to lots.

For certain micro/small primary operator contexts, EUDR provides specific simplifications for geolocation fields.

  • Geolocation dataset: plot/establishment identifiers linked to lots
  • Validation: format checks, completeness, and mismatch detection
  • Provenance: who provided the geolocation and when; evidence of updates
  • Exception handling: what you do when geolocation is missing or inconsistent
Section 4

4) Legality and deforestation-free evidence annex

Your evidence pack should explicitly cover the two core conditions: deforestation-free and produced in accordance with relevant legislation of the country of production.

Keep an evidence index with document IDs and storage locations.

  • Deforestation-free evidence: monitoring sources, supplier attestations, and verification outcomes
  • Legality evidence: permits, land tenure documentation, and compliance documents appropriate to the country of production
  • Document index: each artifact has an ID, owner, and retention location
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Section 5

5) Risk assessment (Article 10) summary (auditable decision record)

Capture the risk decision explicitly: what factors were considered, what the outcome was, and who approved it.

This should be reproducible if challenged.

  • Risk inputs: origin risk, supplier risk, mixing/circumvention risk, documentation quality
  • Decision: no/only negligible risk vs not negligible risk
  • Approver identity and decision timestamp
  • Rationale summary and links to evidence artifacts
Section 6

6) Risk mitigation (Article 11) actions (if risk is not negligible)

If risk is not negligible, document what you did before placing/exporting: corrective actions, verification, and reassessment.

Mitigation should be measurable and time-bound.

  • Mitigation actions taken (supplier corrective actions, enhanced verification, segregation, monitoring)
  • Evidence produced by mitigation actions
  • Post-mitigation reassessment outcome and approval
Section 7

7) Submission and reference number handling (the operational gate)

Regardless of submission method (information system UI/API), you need a standard internal packet and a deterministic way to store and transmit reference numbers.

Make the reference number part of your ERP/logistics data model.

  • Submission method and operator/authorised representative details (if applicable)
  • DDS reference number storage fields (lot, shipment, invoice, and downstream handoff records)
  • Retention: keep DDS references and evidence pack retrievable for years
  • Release gate: no valid reference number -> no ship
Primary sources

References and citations

Related guides

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EUDR penalties explained (Article 25): Member State penalty rules.
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Risk Assessment and Mitigation | EUDR Due Diligence (Articles 10-11) Playbook
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