What a due diligence statement contains, how it is filed in the EU information system, what comes back and how long you keep it.
Summary
The due diligence statement (DDS) is the document in which the operator declares that the product is deforestation-free, legal in the country of production and checked for risk. It is submitted to the EU information system, TRACES NT, before the product is placed on the market or exported.
Each statement returns a reference number. That number travels with the goods: downstream actors keep it and pass it on, and authorities use it to find the statement. Submitting a statement is therefore not only a formality, it is the link on which the whole supply chain depends.
The operator keeps the statement and its supporting information for five years. This page also describes how our platform builds the submission package. Those descriptions are our practice and not part of the Regulation.
What goes into the statement
The statement identifies the operator, the product by tariff code and quantity, the country of production and the geolocation of the plots, or of the establishments in the case of cattle. It also records that due diligence was carried out and that the risk was assessed as negligible.
The statement is only as good as the data behind it. A plot that has not been validated, an operator number that is missing or a product without a tariff code will stop the package before it leaves our system.
Filing through TRACES NT
Statements are filed in the EU information system. The Commission publishes technical specifications for connecting business systems to it. We have not yet checked the current specification, so we do not describe the interface format as a requirement here.
Where the products enter or leave the Union market, the statement carries the operator's EORI number (Annex II). A company that acts through an authorised representative needs a written mandate under Article 6.
The reference number and what you receive back
The system returns a reference number for each statement. Keep it with the delivery note, the production order and the invoice so that every sale can be traced to a statement.
In our staging tests the platform generates a placeholder number in the form EUDR.2026.HR.XXXXXXXX. That form belongs to our simulation and is not the format used by TRACES NT. Do not treat it as an official identifier.
Need to verify your EUDR compliance?
We check your tariff codes, plot geolocation and batch traceability against the EUDR obligations, and prepare the due diligence statement for you. Send us your product and supplier list and we will tell you where the gaps are.
How the Pixel & Proof platform prepares the package
The platform assembles the statement as an XML document and wraps it in a SOAP 1.2 envelope for the staging environment. It stores a SHA-256 fingerprint of the exact package, so that you can later show that the submitted content was not changed. Live submission needs credentials from the Commission, until then staging runs in simulation mode.
A statement that has been submitted cannot be submitted again. If you try, our API answers with HTTP 409 and returns the reference number already issued. A correction is handled as a new version of the data, not by overwriting the filed package.
Five years of retention
Keep the statement, the plot data, the risk assessment and the supplier documents for five years from the date of submission. Store the exact package that was filed, its fingerprint and the reference number together, so that an inspection can be answered from one record.
Submission duties at a glance
| Article | Duty | Who | Date rule |
|---|---|---|---|
| 4, 33 | File the statement in the EU information system before placing on the market or export, and obtain the reference number. | Operator placing on the market or exporting | From 30 December 2026; from 30 June 2027 for micro and small operators established by 31 December 2024 (not for timber). |
| 4, 9 | Keep the statement and supporting information for five years. | Operator | Same dates as above. |
| 2, 4 | Pass the reference number on to downstream actors; they do not file their own statement. | Operator and downstream actors | Same dates as above. |
| 38 | Application date for operators and traders in general. | Operators and traders | 30 December 2026. |
| 38 | Later application date for micro and small operators established by 31 December 2024 (not for timber). | Micro and small operators | 30 June 2027. |
Data needed before filing
| Item | Commodity or HS/CN | Where it comes from | Rule |
|---|---|---|---|
| Tariff code | HS 44, 4819, 0901, 1801, 0201, 4001 | Product master data | Every product line has a code |
| Plot geolocation | All commodities except cattle | Supplier plot data | Six decimals, WGS-84 |
| Establishment geolocation | HS 0201 and other cattle products | Farm and slaughterhouse records | Location and identifier |
| Risk assessment record | All commodities | Platform review log | Kept with the statement |
Exemptions and simplifications
Two groups file differently or not at all.
- Micro and small primary operators file a one-time simplified declaration instead of a statement.
- For products from low-risk countries the statement is still filed, but the risk assessment and mitigation steps are simplified.
Acts that can change the process
We have not verified the adoption status of these acts.
- Implementing act and technical specification for the EU information system (TRACES NT).
- Commission simplification review, due by 30 April 2026, which may lead to a legislative proposal.
Frequently asked questions
What do I get back after submitting a DDS?
The EU information system returns a reference number for the statement. Downstream actors pass it on in the supply chain.
How long must DDS records be kept?
Five years from the date of submission (Article 4(3)). The information collected under Article 9(1) is kept for five years from placing on the market or export.
Book a 15-minute EUDR audit
We look at your product list, tariff codes and plot data and tell you where the gaps are. Write to us through the contact page; a booking slot is offered here when it is available.
Sources
- Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on deforestation-free products (EUDR), OJ L 150, 9.6.2023. Read in the Official Journal text on 10 November 2026.
- Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115 (application dates, downstream operators, simplified declaration, scope). Read in the Official Journal text on 10 November 2026.
- Legal commentary and Commission guidance as reported by law firms (EY, Linklaters, VinciWorks, Lexgo), read on 10 November 2026. Indicative only.
Facts last checked against the Official Journal text on 10 November 2026.
This page is general information, not legal advice. It reflects the Official Journal text of Regulation (EU) 2023/1115 as amended and Commission guidance as read on 10 November 2026; items marked as expected are not confirmed. Obligations depend on your role, product and Member State. Check the current official text on EUR-Lex.