What Is an EUDR Due Diligence Statement?

A formal statement after due diligence

An EUDR due diligence statement is the operator's prescribed electronic declaration that due diligence has been carried out for relevant products and that no or only negligible risk was found of failure to meet the deforestation-free and legality requirements. It is submitted through the Information System before the relevant placing on the market or export, once the applicable obligation starts. Annex II specifies the information and confirmation it must contain.

A statement is therefore the documented outcome of a compliance decision. It is not the entire due diligence process, a supplier's sustainability certificate or an application for official approval of the goods. If the operator has unresolved evidence gaps that prevent the required conclusion, completing the electronic form does not remove them. The release decision must follow the evidence, rather than using the form as a substitute for it.

What it connects together

The statement connects an identified operator to described relevant products, quantities, countries of production and production locations. For products containing or made using wood, the applicable scientific-name requirements matter. The geolocation information must identify the production places required by the regulation, rather than a shipping port, supplier office or warehouse chosen because its coordinates are readily available.

This creates a useful distinction between product identity and evidence identity. An invoice may describe the commercial product. The statement must also connect it to the origins relevant to the EUDR. A tonne of coffee bought under one order can have several production plots; a neat invoice description cannot justify leaving those plots out of the record.

The Information System guide explains how the electronic record fits alongside the internal evidence file. Keep a reliable relationship between each statement and the products it actually covers so the declaration can be understood months or years after the shipment was processed.

Who makes the declaration

The ordinary statement obligation belongs to operators subject to Article 4. An authorised representative may perform the submission under a mandate, but the operator remains responsible for product compliance and the declaration made on its behalf. Internal approval by a compliance manager is a useful control; it does not change which legal person is making the statement.

Under the revised law, downstream operators and traders are dealt with separately. Their ordinary duties should not be described as a universal requirement to submit fresh statements for goods already covered upstream. Non-SME downstream registration is a distinct obligation. A qualifying micro or small primary operator has the Article 4a simplified declaration route, which produces a declaration identifier rather than the ordinary statement's reference number.

A reference number is not a finding of compliance

After the prescribed processing, the system assigns a reference number and an associated verification number. These are identifiers and security tools within the regulatory workflow. An authority can still check the evidence, inspect the relevant products and act on non-compliance. The presence of a number on a delivery note should never be presented as a Commission certification of the goods.

Consider an importer that submits the coordinates of the correct plantation but relies on an inaccurate account of when forest was cleared. The statement may exist in the system and have a number, yet its supporting conclusion can still be wrong. Submission records and substantive evidence must both survive review; one does not validate the other automatically.

How broad can a statement be?

A business should define the intended covered products and quantities clearly enough to connect the statement to its commercial activity and evidence. Whether it organises submissions around individual consignments or a wider planned flow, it must retain control over the products, origins and quantities covered. A broad statement does not authorise later sourcing from an unassessed production area.

For repeated deliveries, maintain an internal allocation record showing how commercial lots relate to the declaration. That is an operational control, not a claim that the regulation mandates one particular spreadsheet layout. If changed facts mean a statement no longer describes the intended products, review the applicable correction rules before releasing goods against it.

Read the confirmation before submitting

The Annex II confirmation concerns both due diligence and its risk conclusion. Staff should know what the operator is confirming and which evidence supports it. A submit button used as a routine purchasing step can conceal a serious governance problem when nobody has authority to stop a shipment or resolve contradictory supplier evidence.

The statement information guide explains the required fields in more detail. A useful final review asks three questions: are the products accurately described, do the locations and quantities correspond to the intended supply, and has the authorised reviewer reached the required documented conclusion? Save that review together with the submission record so the statement remains explainable after the original staff member changes roles.

A useful training exercise is to ask the proposed submitter to explain the confirmation in ordinary language using one real product. The answer should identify the relevant origins, evidence reviewed and risk decision, rather than merely describe the screen's fields. If the submitter cannot find that decision, establish where approval is recorded and who owns it before the declaration becomes a routine administrative action.