EUDR: DDS or simplified declaration 2026/2027? Roles and traceability

Short answer: Following amending Regulation (EU) 2025/2650, it is normally the responsible operator that must conduct due diligence and submit a due diligence statement (DDS) before a relevant product is placed on the EU market or exported. Certain micro and small primary producers in low-risk countries use a simplified one-off declaration instead, in accordance with Article 4a. Downstream operators and traders have other obligations, primarily to be able to trace suppliers and customers. The category to which the company belongs therefore determines which tasks must be performed and records kept.

Last fact-checked: October 19, 2026. Verified against EUDR (EU) 2023/1115 as amended by (EU) 2025/2650, as well as the European Commission's 2026 guidance. The guide provides general information, not an individual EUDR assessment.

EUDR 2026/2027: which application dates apply?

The EUDR entered into force in 2023, but the most important operational requirements have been postponed. According to Article 38 as amended by (EU) 2025/2650, key provisions begin to apply on December 30, 2026. For an operator established as a micro or small enterprise by December 31, 2024, the date is in many cases June 30, 2027, but this deferral does not apply to products covered by the annex to the older Timber Regulation, Regulation (EU) No 995/2010. Role, product, and transitional rules must therefore be assessed on an individual basis.

Operator, primary producer, downstream, or trader?

Start by checking whether the commodity or processed product is in Annex I to the EUDR, with the correct CN/HS code. The commodities in the regulation are cattle, cocoa, coffee, oil palm, rubber, soy, and wood, but not every item containing these commodities is covered. Subsequently, the operator's actual role for the relevant product flow is identified.

Special case: If an operator outside the EU first places a relevant product on the Union market, the first EU-established actor who then makes the goods available may also be classified as an operator. Therefore, do not automatically assume that "the first supplier has done everything." See the Commission's guidance on roles.

What is a due diligence statement (DDS)?

The DDS is the electronic declaration in the EU's EUDR Information System that the relevant operator normally submits after having conducted due diligence and before the relevant products are placed on the market or exported. By submitting it, the operator takes responsibility for the product complying with Article 3. A DDS is not a standalone certificate that replaces underlying investigation or evidence.

Check the documentation before submission

1. Product and classification: ensure the goods fall under Annex I and register the relevant code, product description, and quantity.
2. Production and geolocation: collect data on the country of production and the plots of land or facilities concerned in accordance with Article 9.
3. Deforestation-free and legality: check documentation showing compliance with Article 3, including the cut-off date of December 31, 2020.
4. Risk: assess the applicable Article 10 criteria and take Article 11 measures when required. For production exclusively in low-risk countries, Article 13 may provide simplified due diligence if its conditions are met.
5. Internal attestation: document who assessed the risk, which version of the documentation was used, and which deviations have been closed.
6. Declaration and reference: submit data in the EU information system and save the reference number, which must be provided to the direct downstream recipient.

Simplified one-off declaration under Article 4a

Article 4a was introduced by (EU) 2025/2650. It applies to a specific group of micro or small primary producers who themselves produce relevant commodities in the low-risk country where they are established. Instead of submitting a DDS for each relevant flow, they can normally submit one one-off declaration with information according to Annex III. The information system then assigns a declaration identifier which is forwarded to the first downstream recipient.

The information in Annex III includes the producer's identity, the products and codes in question, the estimated annual quantity, the country of production, and the production site. Under the specific rules, the producer may provide a sufficiently precise postal address of the production site instead of geolocation coordinates. This exemption does not automatically apply to larger operators or regular retailers.

If equivalent data is already available in a relevant public system under Article 4a.4, the obligation to submit the one-off declaration can be fulfilled through the specific authority model. Even then, an assigned identifier is required. Changes that are material to the declaration's information must be handled according to Article 4a.

Downstream operators and traders: what is required?

The amended Article 5 means that downstream operators and traders generally do not need to repeat the upstream operator's due diligence or submit their own DDS. Instead, information is required about the actors who supplied them with relevant products and about the downstream actors or traders they supply to.

The first downstream operator or trader receiving from an operator must also keep the DDS reference number or the identifier for a simplified declaration. It is not a general requirement that every subsequent link in the chain forwards the same reference number to their own customers. Follow the exact information chain in Article 5 and the Commission's guidance on roles.

Company size affects registration requirements: downstream operators and traders that are not SMEs must register in the information system. In cases of substantiated concerns, such larger actors also have specific inspection obligations. Information about suspected non-compliance can trigger information obligations for all categories according to Article 5.

Which EUDR documentation must be kept for five years?

According to Article 4.3, the operator keeps records of submitted DDSs for five years from the submission date. Article 5.4 requires that downstream operators and traders keep prescribed supplier and customer information for at least five years from the date of placing on the market, making available, or export. Other documentation requirements, including those under Articles 9 and 12, must also be managed.

Practical examples: three different EUDR roles

EUDR checklist before placing on the market or export

1. Verify the product's CN/HS code against the current Annex I.
2. Document whether the company is an operator, micro/small primary producer, downstream operator, or trader for this specific transaction.
3. Assess the correct application date and any timber-related transitions.
4. If the company is an operator: gather Article 9 evidence and conduct a risk assessment, with any Article 13 simplification.
5. Choose the right electronic flow: DDS or, where all conditions are met, an Article 4a declaration.
6. Create traceability between deliveries, recipients, and relevant references.
7. Distribute responsibility for deviations, new risk information, contact with authorities, and document retention.

Frequently asked questions about DDS and simplified EUDR declaration

Must all companies submit a DDS?

No. Usually, it is the operator that submits the DDS. Certain micro/small primary producers are covered by Article 4a, while downstream operators and traders normally have information and traceability obligations instead.

Does a simplified declaration apply to all small companies?

No. The regime is intended for qualified micro/small primary producers who produce the goods themselves in a low-risk country. A small import company or a small trading business may not automatically use that model.

Is the supplier's certificate that the product is deforestation-free sufficient?

No, not as a general guarantee for the operator's obligations. The operator responsible under Articles 8–12 must have documentation that satisfies the information requirements and, if necessary, a documented risk assessment and risk mitigation strategy.

Must geolocation coordinates always be submitted?

Article 9 sets geolocation requirements for operators. However, the special Article 4a regime allows authorized micro/small primary producers to instead provide a sufficiently locatable postal address for the production sites concerned.

What should a smaller company that is a trader save?

Information about suppliers and concerned recipients according to Article 5. The first downstream actor must also retain the received DDS reference number or simplified declaration identifier. The minimum retention period for the Article 5.3 information is five years according to Article 5.4.

Related EUDR guides and document templates

For basic background, product scope, and geolocation: EUDR 2026/2027 – which companies are covered and how do you conduct due diligence?. Also read EU compliance for companies 2026/2027 and supplier agreements and traceability in the supply chain.

For step-by-step control of geographical production data, coordinates, polygons, and retention periods: read EUDR Article 9: geolocation, point and polygon requirements. This guide complements that review of DDS and simplified declarations.

Primary legal sources and official guidance

• Regulation (EU) 2023/1115 – EUDR, particularly Articles 2–5, 8–13 and 38, and Annexes I–III.
• Regulation (EU) 2025/2650 – amended division of roles, Article 4a, Article 5, and application dates.
• European Commission's EUDR guidance, July 20, 2026 (guidance, not a replacement for binding legal text).
• European Commission – Roles and responsibilities under EUDR.
• Commission's EUDR Information System – simplified declaration.