How to submit an EUDR due diligence statement in TRACES, step by step
Register in TRACES NT, gather the data Annex II requires, choose the right statement type and file. A step-by-step walkthrough of submitting an EUDR DDS.
On this page
- 01Who actually has to file
- 02Before you can submit: register in TRACES NT
- 03What the statement has to contain
- 04Which type of statement to file
- 05Submitting the statement
- 06Reference numbers, verification numbers, and what happens next
- 07Common reasons a DDS gets rejected or flagged
- 08Get your filing timeline right
You submit an EUDR due diligence statement (DDS) through the EU's Information System, built on the TRACES platform and generally called TRACES NT. In outline: register with an EU Login account, add your company and EORI number, choose your role, enter product and geolocation data for each consignment, complete a risk assessment, and submit. The system returns a reference number and a verification number once the statement is accepted.
That outline hides most of the actual work, which is data collection rather than the form itself. This guide covers both: the mechanics of the TRACES submission, and what has to be true before you can complete it.
Who actually has to file
Since Regulation (EU) 2025/2650, only the operator who first places a relevant product on the EU market, or who exports it, files a due diligence statement. That is usually the importer or the primary producer, not everyone in the chain. Downstream operators and traders no longer file their own statements — they collect and retain the reference number of the statement filed upstream, and non-SME downstream operators and traders must still register in the Information System even though they will not submit a DDS themselves. What changed under Regulation (EU) 2025/2650 covers that shift in full; this guide assumes you already know you are the filer and takes you through the submission itself.
Before you can submit: register in TRACES NT
You cannot fill in a DDS without an account, and the account setup takes longer than most businesses expect because it depends on EU-level identity verification.
- Create an EU Login account. This is the European Commission's shared authentication system, not something specific to EUDR. Use a company email address you will still hold in five years — statements and records need to stay traceable for that long.
- Add two-factor authentication. TRACES NT requires it. Register a mobile number or the EU Login Mobile app before you try to access the platform, or you will be stopped at the door.
- Register your organisation in TRACES NT and select the correct role: Operator, Trader, or Authorised Representative. An authorised representative is a person or firm you mandate in writing to file on your behalf; it does not take on your legal liability for the due diligence itself, which stays with you.
- Supply your EORI number alongside standard company details. Without a valid EORI, customs cannot match your DDS reference to a consignment at the border, so this is not optional for anyone importing physical goods.
- Link your EU Login account to the registered operator. Registration and login access are separate steps — you need both before the submission screens unlock.
Do this well ahead of your applicable date. Check which EUDR deadline applies to you: registration backlogs tend to build in the weeks immediately before each cut-off, and a rejected or incomplete registration cannot be fixed the day you need to ship.
What the statement has to contain
Annex II of Regulation (EU) 2023/1115 sets out what a DDS must include. In practice, the TRACES form asks for:
- Product description and CN code — scope is decided by customs code, not by what you call the product, so confirm the code against the current Annex I rather than assuming last year's classification still holds.
- Quantity and country of production.
- Geolocation of every plot of production. A single point for plots under 4 hectares; a polygon (as GeoJSON) describing the perimeter for plots of 4 hectares or more. Coordinates need at least six decimal places of precision.
- Supplier information, traceable back to the plot.
- Evidence the product is deforestation-free — that the land was not subject to deforestation after 31 December 2020, and that wood was not linked to forest degradation after that date.
- Evidence of legal production, against the laws of the country of production.
- A risk assessment concluding the risk is negligible, following the criteria in the regulation, together with any mitigation measures applied.
- A signed declaration from someone authorised to bind the company, taking legal responsibility for the statement's accuracy.
This is the part that actually takes time. A coffee importer, for instance, is typically chasing polygon data from smallholder farms that have never been asked for it before — see EUDR for coffee importers: what to collect from every farm for what that data-gathering exercise looks like in one commodity. Timber and furniture importers face a parallel problem tracing plots through sawmills and consolidators; EUDR for furniture and timber importers covers that chain specifically.
Which type of statement to file
TRACES NT supports more than one statement shape, and filing the wrong one either creates unnecessary paperwork or leaves you non-compliant.
| Statement type | Who can use it | What it covers |
|---|---|---|
| Individual DDS | Any operator or trader required to file | One specific consignment |
| General statement covering multiple consignments | Any filer, at the Commission's administrative discretion, to reduce the volume of separate filings | An expected volume of the same product over a stated period, rather than one filing per shipment |
| Simplified declaration (Article 4a) | Micro and small primary operators established in a low-risk country, for products they grew, harvested, raised or obtained themselves | A one-off declaration in place of a statement per consignment |
The simplified declaration is a statutory route, formalised by an implementing regulation the Commission adopted alongside the July 2026 update to product scope and IT tools. It is narrow: it applies only to micro and small primary operators sourcing exclusively from countries benchmarked low risk, producing the commodity themselves rather than trading it on. Everyone else still files per consignment or uses the general statement route, which the Commission has promoted through FAQ guidance as an administrative simplification rather than a change to the underlying Article 4 obligation. If you are not clearly inside the Article 4a criteria, do not assume the lighter route applies to you — file individually or as a general statement and take advice if you are unsure which category you fall into.
Submitting the statement
Once your data is assembled and you know which statement type applies:
- Open a new DDS in TRACES NT under your registered operator or trader profile, and select the statement type.
- Enter the product, quantity, CN code and country of production.
- Attach or enter the geolocation data — point or polygon, per plot, matching the 4-hectare threshold above.
- Complete the risk assessment fields, recording the information and mitigation measures that support a negligible-risk conclusion. If you are relying on an upstream supplier's own due diligence, you still need to be able to show you assessed it, not simply accepted their word.
- Sign and submit. The system validates the mandatory fields before it will accept the statement; incomplete geolocation or a CN code outside current Annex I scope are the most common rejection reasons.
- Record the reference number and verification number the system returns once the statement is accepted.
Reference numbers, verification numbers, and what happens next
An accepted DDS generates two numbers. The reference number identifies the statement and is what downstream customers, and customs, use to find it. The verification number is a separate security code you share only with the parties who need to confirm the statement is genuine — a downstream trader referencing your DDS, or a competent authority carrying out a check. Treat the verification number the way you would a document's confidentiality: it is not meant to circulate freely.
Once filed, the statement sits in the Information System and can be checked by national competent authorities and customs on a risk-based basis, cross-referenced against the consignment at the point it is placed on the market or exported. A rejected or flagged statement blocks the consignment until it is resolved, which is the practical reason to test your first filing well before your applicable date rather than on a live shipment.
Common reasons a DDS gets rejected or flagged
- CN code doesn't match current Annex I scope. Product scope has been amended more than once; confirm against the current list rather than an old spreadsheet. See Annex I changes under Delegated Regulation (EU) 2026/2102 for what moved in and out most recently.
- Geolocation format is wrong for the plot size — a single point submitted for a plot that needed a polygon, or coordinates given to fewer than six decimal places.
- The declared quantity doesn't reconcile with the commercial invoice or transport documents for the same consignment.
- The risk assessment is generic rather than specific to the plot and supplier, which a competent authority can challenge even where the underlying geolocation data is correct.
- The filer isn't the one who should be filing — a downstream trader submitting a statement that should have come from the first operator to place the product on the market, or vice versa.
Get your filing timeline right
The TRACES submission itself takes minutes once the data is ready. The data rarely is. Start supplier outreach and registration well ahead of your applicable date, and file a test statement on a real consignment before you are relying on it to clear goods.
Check what your business needs to do under the EUDR and get a dated plan for registration, data collection and your first filing.
General information about Regulation (EU) 2023/1115 as amended, not legal advice. EUDR scope is determined by customs (CN) code — confirm your own classifications before acting on this. Checked against primary sources on .
Frequently asked
01What is an EUDR due diligence statement?
A due diligence statement (DDS) is the record an operator or trader files in the EU's TRACES-based Information System to place a relevant product on the EU market or export it. It contains the product's CN code, quantity, country of production, plot-level geolocation, and evidence that the product is deforestation-free and legally produced, together with a risk assessment and a signed declaration.
02Who has to submit a DDS in TRACES?
Since Regulation (EU) 2025/2650, only the operator who first places a product on the EU market, or exports it, files a DDS. Downstream operators and traders retain the upstream reference number instead of filing their own, though non-SME downstream operators and traders must still register in the Information System.
03How do I register in TRACES NT?
Create an EU Login account, add two-factor authentication, register your organisation with your EORI number, select your role (Operator, Trader or Authorised Representative), and link your EU Login account to the registered operator. Do this well before your applicable date, as verification takes time.
04What is the difference between a DDS reference number and a verification number?
The reference number identifies an accepted statement and is what downstream customers and customs use to locate it. The verification number is a separate security code shared only with parties who need to confirm the statement is genuine, such as a downstream trader referencing it or a competent authority carrying out a check.
05Can I file one due diligence statement to cover a whole year's shipments?
You can file a general statement covering multiple consignments of the same product over a stated period, which the Commission has promoted as an administrative simplification. A distinct, narrower route — the Article 4a simplified declaration — lets micro and small primary operators sourcing only from low-risk countries file a one-off declaration instead. Most filers still need one statement per consignment or the general-statement route; check which applies before assuming a single annual filing covers you.
06What geolocation format does TRACES require?
A single point, given as latitude and longitude to at least six decimal places, for plots under 4 hectares. For plots of 4 hectares or more, a polygon describing the plot's perimeter, submitted as GeoJSON.
07What happens if a DDS is rejected or flagged for inspection?
A rejected statement cannot be used to place the consignment on the market or clear customs until it is corrected and resubmitted. A flagged statement may trigger a check by a national competent authority or customs before the consignment can proceed, which is why testing a filing before your applicable date matters more than the form itself.
08Do I need an EORI number to submit a DDS?
Yes, if you are importing or exporting physical goods. Customs authorities match a DDS reference number to a consignment using the EORI number recorded against your TRACES registration.
Sources
- [1]Regulation (EU) 2023/1115 on deforestation-free products (EUR-Lex)
- [2]Council: targeted revision to simplify and postpone the deforestation regulation
- [3]European Commission — Information System of the Deforestation Regulation (Green Forum)
- [4]European Commission — Commission updates product scope and tools to support EUDR (13 July 2026)
- [5]European Commission — Deforestation-free products