What a Due Diligence Statement Contains, and Who Files It

Everything else in EUDR compliance — geolocation, legality documents, risk assessment — exists to support one filing. This is that filing.

Who files it

The operator: the company that first places the commodity on the EU market. For green coffee that is the importer.

Your Indian exporter does not file it, cannot file it, and has no access to the EU system in which it is filed. What they can do is give you the information the statement rests on.

If you buy through a European importer or trader who imports on their own account, they are the operator for that transaction. If you import yourself, you are.

Where it is filed

In TRACES, the EU's information system. The filing produces a reference number.

That reference number is the operative output. It travels with the shipment documents, and customs use it. Without a valid DDS reference number, the goods cannot legally enter the EU — which makes this a shipping-documents problem as much as a sustainability one.

What it asserts

In substance, a DDS states that you have:

1. Collected information — geolocation of the plots, quantity, supplier details, country of production, and evidence of legality.
2. Assessed the risk that the commodity is not compliant.
3. Mitigated that risk where it was more than negligible.

And that on the basis of all three you conclude there is no more than a negligible risk that the coffee is non-compliant.

You are signing that conclusion. That is why the quality of what your supplier gives you is your commercial problem, not theirs.

The information behind it

Only two rows of that table are things you can produce alone. The rest has to arrive from origin, in time.

Timing

The DDS is filed before the goods are placed on the EU market. In practice that means the reference number needs to exist before the shipment clears, which means the underlying data needs to be in your hands well before the vessel arrives — and realistically before it sails.

The single most useful contractual change you can make this season is to move the geolocation and legality pack to the pre-shipment sample milestone rather than the invoice. Evidence that arrives with the invoice arrives too late to be useful and too late to fix.

Risk assessment, briefly

This is the part that is easy to under-do because it produces no document from origin.

You have to assess whether the information you were given is complete, accurate and plausible — not merely whether it exists. Practically:

• Does the geolocation actually resolve to farmland, and does the drawn area match the stated area?
• Does the imagery show established tree cover before 31 December 2020?
• Is there a plausible chain from those plots to the bags you are buying, through curing and bagging?
• Is the origin country or region flagged as higher risk under the EU benchmarking?

Where anything is more than negligible, mitigate before filing — more evidence, independent verification, satellite checks — and record what you did.

Simplifications

The regulation has been amended more than once, and some simplification has been introduced — including proposals that certain downstream actors and smallholder producers be relieved of submitting statements themselves. The direction of travel has been towards reducing duplicate filings rather than removing the operator's core obligation.

Because this has moved repeatedly, check the current text rather than relying on a summary written at any particular moment, including this one.

Dates

What to do now

Send your suppliers the origin checklist, agree a delivery milestone in the contract, and get one full pack through the process on a real shipment before the deadline rather than after it.

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A working summary for buyers, not legal advice.