- A Due Diligence Statement (DDS) is the electronic declaration you submit via the EU's TRACES system before placing timber products on the EU market.
- It must contain 8 categories of information: operator identity, EORI, HS code, product description, quantity, country of harvest, geolocation of all harvest plots, and your risk-assessment conclusion.
- Who files: the "operator" — the entity that first places the product on the market. If your supplier already filed, you're a downstream operator and just pass the reference number.
- Retention: all DDS records must be kept for at least 5 years.
- Penalties for missing it: fines up to 4% of annual EU turnover, product confiscation, market exclusion.
- Deadline: 30 Dec 2026 (large/medium operators); 30 Jun 2027 (micro/small).
What Is a Due Diligence Statement?
You've heard "EUDR" and "due diligence" in every industry newsletter for the last two years. But when you sit down to actually do something, the first question is concrete: what exactly do I submit, and where?
The Due Diligence Statement (DDS) is the answer. It's the formal electronic declaration that an operator submits through the EU's TRACES-NT information system before a covered product — including sawn lumber, logs, and even wood chips — is placed on the EU market or exported from it.
The DDS is not a one-off form. It's the output of a three-step process the regulation calls "due diligence":
- Information collection. Gather data on the product: what it is, where the raw material was harvested, when, and by whom.
- Risk assessment. Evaluate whether there's a risk that the product is linked to deforestation (post-31 Dec 2020) or was produced illegally.
- Risk mitigation. If the risk is non-negligible, take additional steps — independent audits, satellite imagery checks, supplier verification — until the risk becomes negligible.
Only when all three steps are done — and you conclude the product is compliant — do you submit the DDS. Think of it as the compliance receipt: proof that you did the work, filed in a system the authorities can check.
Who Files: Operator, Trader, or Downstream?
EUDR creates three roles. Your obligations — and whether you file a DDS at all — depend on which one you are.
| Role | Definition | DDS obligation |
|---|---|---|
| Operator | The entity that first places the product on the EU market (import) or exports it from the EU. | Full due diligence + DDS filing. You collect the data, run the risk assessment, and submit the DDS in TRACES. |
| Trader | A commercial entity that makes a covered product available on the market after it has already been placed by an operator. | No DDS filing. You collect and store the upstream DDS reference number and pass it to your customers. |
| Downstream operator | An entity that places on the market or exports a product already covered by an existing DDS. | No DDS filing. You register in the system, collect the upstream DDS reference number, and maintain traceability. No separate due diligence required. |
4 Sawmill Scenarios — Who's the Operator?
The abstract definitions become concrete when you map them to how sawmills actually buy wood. Here are the four most common configurations:
| Scenario | Who is the operator? | Your DDS obligation |
|---|---|---|
| 1. You buy logs from a forest-owner association or wood-procurement company that has already filed a DDS. | The association/procurement company | Downstream operator. Collect and store the DDS reference number. No filing. |
| 2. You buy standing timber directly from a private forest owner who has not filed. | You (the sawmill) | Operator. You do the full due diligence and file the DDS yourself. |
| 3. You import logs from outside the EU. | You (the importer) | Operator. Full DDS required before the product clears customs. |
| 4. You do contract/toll sawing — you saw someone else's timber as a service. | The timber owner | Not in scope. Service production is not placing on the market. No DDS, no geolocation obligation on you. |
Most EU sawmills fall into Scenario 1 or 2. The deciding factor is whether your log supplier has already filed. Ask them — in writing — before December 2026.
The 8 Required Fields (Annex II)
When you are the operator and need to file, the DDS requires the following information (per Regulation 2023/1115, Annex II):
| # | Field | What to enter | Where you get it |
|---|---|---|---|
| 1 | Operator name & address | Your company's legal name, registered address | Company registration |
| 2 | EORI number | Economic Operators Registration and Identification number | National customs authority |
| 3 | HS / CN code | Harmonised System code for the product (e.g., 4407 for sawn wood) | EU Combined Nomenclature |
| 4 | Product description | Textual description including trade name, species | Your commercial documentation |
| 5 | Quantity | Net weight, volume (m³), or number of units | Delivery/invoice records |
| 6 | Country of production | Country where the timber was harvested | Supplier declaration / CoC |
| 7 | Geolocation of harvest plots | GPS point (for plots <4 ha) or polygon boundaries (for plots >4 ha) for every harvest plot | Supplier / forest-management data |
| 8 | Risk-assessment conclusion | Your documented assessment that the risk of deforestation / illegality is negligible | Your due-diligence process |
In TRACES, you also indicate the date or period of production and can draw harvest areas on a map, upload coordinates in bulk, or reuse location data from previous submissions.
Download the DDS worksheet and supplier form — a free, pre-formatted workbook covering these fields plus the Article 9 evidence checklist, geolocation sheet, and inbound/outbound registers, so you are not building this table from scratch.
How to File: TRACES Step-by-Step
The EU Information System for EUDR is built on TRACES-NT — the same platform used for sanitary and phytosanitary certificates. Here's the filing workflow:
- Register your company in TRACES-NT (one-time setup). You'll need your EORI number and a company administrator with an EU Login account.
- Create a new DDS. Select the product type, enter the HS code, product description, and quantity.
- Add geolocation data. Three options: draw areas on the built-in map, enter coordinates manually, or upload in bulk (CSV/GeoJSON). You can also reuse locations from previous DDS submissions.
- Complete the risk assessment. Document your conclusion — negligible or non-negligible risk. If non-negligible, you must describe the mitigation measures taken.
- Submit the DDS. The system generates a unique reference number. This number follows the product through the supply chain — pass it to every downstream buyer.
One DDS can cover multiple shipments and can even be filed annually if the products share the same origin and risk profile. The system also supports a machine-to-machine API for operators with high volumes who want to automate submission.
Simplified declaration for small/micro primary producers
If you're a small or micro primary producer (e.g., a small forest owner selling roundwood), you can file a simplified declaration under Annex III instead of the full DDS. Key difference: the geolocation requirement can be met with your business address rather than plot-level GPS data, and you receive a one-time identification number. This does not apply to sawmills or traders — only to primary producers at the forest level.
What to Keep and for How Long
EUDR requires you to retain all due-diligence documentation for at least 5 years from the date the product was placed on the market. This includes:
- The DDS itself (or the reference number if you're downstream)
- Geolocation data for all harvest plots
- Supplier declarations and certificates (FSC/PEFC, legality docs)
- Risk-assessment records and mitigation evidence
- Delivery notes, invoices, and quantity records that link to the DDS
Format is flexible. The regulation does not mandate a specific storage system — paper, ERP, cloud, or a dedicated compliance tool all work. The requirement is rapid retrievability: if a competent authority asks for a DDS and its supporting documents, you need to produce them quickly.
For a sawmill processing 200,000 m³/year across 50+ suppliers, "rapid retrievability" effectively means a digital system. Spreadsheets work at small scale, but they break when an auditor asks you to trace Pack #4,372 back to the harvest plot and DDS reference.
Mini-Case: A Nordic Softwood Sawmill
A real softwood sawmill in the Nordics — ~80,000 m³ annual intake, buying from a regional forest-owner association and 12 private forest owners — mapped its DDS obligations in Q1 2026:
| Source | Volume share | Who files the DDS? | Sawmill's obligation |
|---|---|---|---|
| Forest-owner association | ~70% | The association (operator) | Downstream: collect and store the DDS reference number per delivery |
| 12 private forest owners | ~30% | The sawmill (first placer) | Operator: collect GPS data from each owner, run risk assessment, file DDS |
Result: for 70% of intake, the sawmill's work is administrative — store a reference number. For 30%, the sawmill had to build a lightweight intake process: a one-page form for forest owners with GPS coordinates, species, and harvest date. Within 8 weeks, all 12 owners had provided the data. The mill filed its first DDS in TRACES in May 2026 as a test.
The hardest part: explaining to private forest owners why they needed to provide GPS data — the same friction point we've seen in every market. A one-page explainer letter, sent with the purchase contract, solved it for 10 of 12 owners. The other two needed a phone call.
What Happens If You Don't File
EUDR is not a guideline — it's a regulation with enforcement teeth. Penalties are set by each EU member state but must meet a minimum standard:
- Fines up to at least 4% of annual EU turnover. This is the minimum ceiling; member states can set higher.
- Product confiscation — goods can be seized at the border or at point of sale.
- Temporary exclusion from public procurement — government contracts become off-limits.
- Criminal liability for serious or repeated violations, depending on member-state law.
The most immediate operational risk for most sawmills isn't the fine — it's shipment blocking. If your product lacks a valid DDS reference at customs, it does not clear. Demurrage, delayed deliveries, and lost contracts follow.
Competent authorities are already being designated across member states: the BLE in Germany, Ruokavirasto in Finland, MITECO in Spain, Masaf in Italy, Skogsstyrelsen in Sweden. Each will run checks — and they can request your DDS and supporting documents at any time within the 5-year retention window.
What This Is NOT
- This is not a form you fill out once and forget. Every time you place a new product on the market from a new source, or from a source whose risk profile has changed, you need a new or updated DDS.
- This is not a certification replacement. A DDS is a regulatory filing, not a voluntary certification. Having FSC/PEFC helps your risk assessment, but the DDS itself is your obligation as an operator. (See our FSC vs EUDR article for the full breakdown.)
- This is not legal advice. We're summarizing publicly available regulatory text. For your specific supply chain — especially if you import from high-risk countries — consult a compliance specialist.
Week-1 Checklist
- Classify yourself. For each supplier, determine: are you the operator (first placer) or a downstream operator? Write it down. If in doubt, ask the supplier in writing whether they've filed or plan to file a DDS.
- Register in TRACES-NT. Go to the TRACES-NT portal, create your company profile, and assign a company administrator. This is free and takes ~30 minutes.
- Run the EUDR Self-Check to map which of the 8 required fields you already have in your records.
- Send a geolocation request to any private suppliers where you are the first placer. Template: "Please provide GPS coordinates (lat/long) for each harvest compartment supplying timber to us."
- Choose a record-keeping system. Decide where you will store DDS reference numbers, geolocation data, and risk assessments for 5 years. If you're above ~20 suppliers, a spreadsheet won't scale.
- File a test DDS. TRACES is now open. Submit a test declaration for one product line to learn the interface before the December deadline creates pressure.
Frequently Asked Questions
What is a Due Diligence Statement (DDS) under EUDR?
A DDS is the formal electronic declaration that an operator submits via the EU's TRACES information system before placing a covered product on the EU market or exporting it. It confirms that the operator has completed the three-step due diligence process (information collection, risk assessment, risk mitigation) and that the product is deforestation-free and legally produced.
Who has to file a DDS — the forest owner, the sawmill, or the buyer?
The entity that first places the product on the EU market — the "operator" — files the DDS. For domestic EU timber, this is typically the forest owner, forest-owner association, or the wood-procurement company that first sells the logs commercially. If your sawmill buys from an operator who has already filed, you are a downstream operator: you receive the DDS reference number and pass it along, but you do not file a new DDS yourself.
Does my sawmill need to file a DDS if I only buy domestic certified timber?
It depends on whether your supplier has already filed. If you buy from a forest-owner association or procurement company that filed the DDS at first placement, you are a downstream operator and only need to collect and store the reference number. But if you buy standing timber directly from a private forest owner who hasn't filed, you become the first placer — and you file the DDS.
What happens if I don't file a DDS by the deadline?
You are non-compliant. Each EU member state sets its own penalties, but the regulation requires them to be "effective, proportionate and dissuasive," with maximum fines of at least 4% of the operator's total annual EU turnover. Additional sanctions include product confiscation, temporary exclusion from public procurement, and criminal liability for serious or repeated violations.
Can one DDS cover multiple shipments?
Yes. A single DDS can cover multiple shipments and even be filed once per year, as long as all products it covers meet the requirements (deforestation-free, legal, with valid geolocation). The key is that every product placed on the market is covered by a DDS — not that each shipment has its own.
How long do I have to keep DDS records?
At least 5 years from the date the product was placed on the market. This includes the DDS itself, geolocation data, supplier documentation, risk-assessment records, and any mitigation evidence. Storage format is flexible — no specific system is mandated — but rapid retrievability is required.
Is the EU Information System (TRACES) operational yet?
The system was temporarily restricted from February 2026 and reopened in June 2026 with the core features needed under the revised regulation. Additional functionalities are being rolled out through summer 2026. Operators can register, create DDS drafts, and submit via the web interface or the machine-to-machine API.
What about contract sawing — does toll milling trigger a DDS?
No. If you saw another party's timber as a service (contract/toll sawing), you are not placing the product on the market — the timber owner is. Service production is outside the EUDR scope: no DDS, no geolocation obligation on the sawyer. The obligation stays with the party who owns and sells the product.
- European Parliament & Council. Regulation (EU) 2023/1115 — full text of the EU Deforestation Regulation.
- European Commission. Information System of the Deforestation Regulation — TRACES-NT status and user guides.
- European Commission. EUDR Implementation — guidance documents and country benchmarking.
- ImpactBuying. EUDR Due Diligence: How to Prepare, Document and Submit a Compliant DDS.
- TracExTech. How to File Due Diligence Statement for EUDR.
- Coolset. What is an EUDR Due Diligence Statement? — overview and template guidance.
- ComplianceGate. EUDR Due Diligence Statements: An Essential Guide.
- BLE (Germany). EUDR-Sorgfaltspflicht im Überblick.
- Ruokavirasto (Finland). FAQ: Deforestation Regulation (EUDR).
- SawmillSmart. EUDR for Sawmills: What's Changing, When, How to Keep Records.
- SawmillSmart. Does FSC Certification Cover EUDR? 5 Gaps Sawmills Must Close.