EUDR Due Diligence Statement (DDS) Submission Process and Value Chain Responsibility Allocation
ENFORCEMENT TIMELINE
Regulation entered into force on June 29, 2023 (phased application for large operators expected from December 30, 2026)
Overview
This card focuses on the practical process of preparing and submitting a Due Diligence Statement (DDS) under the EU Deforestation Regulation (EUDR: Regulation (EU) 2023/1115), and on how responsibility is allocated among operators across the value chain.
Under EUDR, operators placing covered commodities (cattle, cocoa, coffee, palm oil, rubber, soy, and wood) and their derived products on the EU market, or exporting them from the EU, are legally required to submit and register a DDS through the European Commission's information system (TRACES NT / the EUDR Information System) before trading or shipping the goods. By submitting a DDS, an operator ultimately takes on legal responsibility for confirming that the relevant product in its value chain is deforestation-free and was produced in compliance with the laws of the country of production. The regulation sets out concrete compliance requirements, including a system for downstream operators and SMEs to reference an upstream DDS reference number under simplified arrangements, and a five-year document retention obligation.
Enforcement Timeline
June 29, 2023: EUDR (Regulation (EU) 2023/1115) enters into force, establishing the framework for DDS submission.
December 30, 2026: DDS submission and traceability obligations begin to apply to large and medium-sized operators (following the further postponement under Regulation (EU) 2025/2650).
June 30, 2027: The transition period for small operators and micro-enterprises ends (micro and small operators already covered by the EU Timber Regulation: December 30, 2026).
Five years following submission: The legal retention period for submitted DDSs and their supporting data and audit records.
Business Impact
Operators shipping covered commodity products to the EU must prepare a DDS for each shipment batch in advance and obtain a unique reference and verification number before customs clearance or sale in the EU market. Because this DDS reference number is recorded in customs and sales documentation and passed down to downstream importers and distributors, establishing a full chain of custody through to the end of the value chain is essential.
Large downstream operators are permitted to submit a simplified DDS by referencing an existing DDS reference number registered by an upstream supplier, but this does not fully exempt them from responsibility for the compliance of materials they source directly. If a submitted DDS is later found to be false or incomplete, operators face fines of at least 4% of their EU-wide annual turnover, confiscation of goods, and exclusion from EU public procurement, making it essential to build a rigorous internal DDS preparation, verification, and data-management workflow.