Filing a due-diligence statement in the EU Information System

What the statement actually is

A short declaration, submitted electronically, in which you state that you have exercised due diligence and found no or only negligible risk. It identifies the operator, the product, the quantity, the country of production and the plots. By submitting it you assume legal responsibility for the product's compliance.

It is short because the evidence does not go in it. The plot screening, the imagery, the supplier correspondence, the risk determination, all of that stays with you, available on request for five years. The statement asserts a conclusion; your files justify it.

Before the goods move, not after. The statement must be submitted before the product is placed on, or exported from, the market. Customs are wired into the information system, and a consignment arriving without a reference number is a consignment that does not clear. Filing is not a monthly reconciliation exercise.

Filing, step by step

• Register in the information system Access runs through the Commission's EU login and the TRACES-based information system. You need an economic operator registration and the right user roles assigned. This is administrative rather than difficult, but it takes longer than people plan for, do it well before your first consignment.
• Assemble the Article 9 information Description of the product, trade name and type, including the commodity and the common species name for wood Quantity, net mass, and where relevant volume or number of units Country of production, and where relevant the parts of it Geolocation of every plot, with production date or time range Name, postal address and email of suppliers, and of whoever you supplied Adequately conclusive and verifiable evidence that the goods are deforestation-free and legally produced
• Complete the risk assessment Unless you qualify for simplified due diligence in a low-risk country, run the Article 10 assessment and record the determination. If the risk is more than negligible, mitigate under Article 11 until it is not. You cannot file your way past an unresolved risk.
• Submit the statement Through the web interface for low volumes, or via the API for anything operational. Manual entry stops scaling somewhere around a few statements a week; if you are filing per consignment across multiple origins, plan for the API from the start rather than retrofitting it in November.
• Capture the reference number The system returns a reference number and a verification number. These travel with the consignment: to customs, and to whoever you sell to. Downstream operators and traders reference them in their own filings, so a lost reference number is a real commercial problem, not just an administrative one.
• Retain the evidence Five years, retrievable. See record-keeping.

How reference numbers flow downstream

The design intent is that plot-level work happens once, at the point of first placing. Note how short the chain of custody for the reference number actually is: the operator passes it to the first downstream operator or trader, and that is where it stops. Everyone further down keeps records of their direct supplier and direct customer instead.

• An operator files a statement and receives a reference number.
• A downstream operator does not file. There is no legal obligation for any downstream operator or trader to submit a statement, and the information system does not offer the technical means to do so. Where all your inputs are already covered, you are downstream, and you keep records rather than filing.
• A large trader does not file either. Being outside the SME thresholds brings registration and record duties under Article 5, not a statement.
• A micro or small trader keeps the numbers and the direct supplier and customer records, and nothing more.

Referencing carries a duty. A downstream operator must ascertain that due diligence was in fact exercised upstream, receiving a number is not the same as being entitled to rely on it. If the underlying work was fabricated, the exposure travels with the reference.

What rejects or fails

• Coordinate order. GeoJSON is longitude first. Reversed pairs either reject or place your plots in the wrong hemisphere.
• Unclosed polygon rings. First and last coordinate must match exactly.
• Quantity mismatches. Net mass on the statement that disagrees with the customs declaration draws attention immediately.
• HS code mismatches. The code on the statement must correspond to what is actually being declared. Re-check scope after the May 2026 changes with the lookup.
• Missing species names for wood. Common name and, where required, scientific name, a frequent omission for composite wood products.
• Vague country of production. "Various" is not a country. Where a consignment draws on several, they all have to be stated.

What changed in May 2026

The simplification package altered filing mechanics, particularly at the small end:

• A simplified statement for micro and small primary operators.
• Relief from continuous DDS submission for micro and small primary operators located in low-risk countries.
• Voluntary grouping, allowing businesses to file collectively rather than one by one.
• An upgraded information system, addressing the technical problems that drove the second postponement.

None of this moved the application dates. See current status.

Run a dry filing before December. Take one real consignment and take it all the way through, registration, plot data, screening, risk determination, submission. Everything missing will surface, and it is far cheaper to discover a supplier gap in August than at a border in January.

Related

• Operator, trader, or downstream operator?
• Geolocation and GeoJSON formatting
• Record-keeping and annual reporting