When Must a Due Diligence Statement Be Submitted?

Before the covered placing or export

An operator subject to the ordinary EUDR statement regime must complete the required due diligence and make the statement available through the Information System before placing the relevant products on the market or exporting them. The sequence matters: evidence collection and assessment support the conclusion, then the operator makes the required declaration, and only then can the covered transaction proceed in accordance with the applicable rules.

This is not a rule to upload a statement a fixed number of days after delivery. Nor does it require every business to submit an ordinary statement for every movement in a warehouse. Identify the relevant operator activity, product and applicable date before placing a release control in the purchasing or logistics system.

Start with the applicable obligation date

The main obligations generally apply from 30 December 2026. Most qualifying micro and small operators benefit from the later date of 30 June 2027, subject to the exact Article 38 conditions and exceptions. Certain timber cases and products with their own deferred scope dates require separate treatment. Do not use the later date merely because a company calls itself a small business.

The Information System can be used for preparation before the substantive obligations apply. Registration, staff training and testing are sensible early tasks, but the date a business created an account is not its statutory application date. Keep those dates separately in the readiness plan so staff do not confuse technical access with the start of the legal obligation.

Complete due diligence before making the confirmation

The ordinary statement confirms that due diligence was carried out and found no or only negligible risk regarding the deforestation-free and legality conditions. Submit after the evidence and risk conclusion are ready, rather than using the platform to reserve a number while hoping to resolve a missing production origin later. A number obtained through an unsupported declaration cannot cure the absent assessment.

For example, an importer that knows the supplier and shipment weight but has not established the production plots has not resolved the location evidence simply because the goods are near the EU border. Procurement should identify those gaps early enough to prevent a last-minute choice between delaying the transaction and making a declaration the business cannot support.

The Information System workflow places submission between the documented decision and the transaction. Use that sequence to assign responsibilities and define what must be visible to the person authorising release.

Plan for processing rather than instant availability

The implementing rules provide for risk profiling and the assignment of identifiers. Authorities can delay their availability within the legal framework. An automated submission request that returns a transport acknowledgement is not necessarily a completed regulatory outcome. Your workflow should recognise the difference between transmitting data, receiving a system response and obtaining the identifier and state required for the intended use.

Build operational time into the process without inventing a statutory deadline such as “submit exactly 48 hours before arrival”. The necessary lead time depends on the business and circumstances, while the legal requirement concerns completion before the relevant placing or export. Record unresolved statuses and give staff a clear escalation route when the intended transaction is approaching.

Customs and physical logistics

For relevant products entering or leaving the market, the statement or declaration identifier interacts with the customs process under Article 26. Coordinate the operator, customs declarant and logistics team so the identifier relates to the goods actually declared. A bill of lading or shipping instruction does not replace the prescribed Information System record.

Also distinguish physical movement from the legally relevant activity. Goods may be transported or held under arrangements whose EUDR analysis depends on their customs and commercial status. A rule based only on the truck's arrival at a warehouse can miss the correct legal trigger. Document the transaction sequence for each flow, including when goods become subject to the intended release or export procedure.

Repeated shipments and changed facts

When a statement is used for a planned flow involving multiple deliveries, maintain controls over its product and origin coverage. New suppliers, new plots or different goods can mean that the existing submission does not describe the later delivery. Do not infer continuing coverage merely because an internal purchase agreement or supplier account number remains unchanged.

The amendment and withdrawal guide explains why a submitted record cannot always be corrected freely. The standard amendment window is subject to lockouts, including market placement, export, customs presentation and grouping conditions. Resolve predictable data changes before goods are released, and use the legally available correction route rather than editing only the commercial paperwork after the declaration has already been relied on.

Use a rehearsal to measure the business's actual lead time. Start with a realistic supplier dataset, complete the review, prepare the submission and reconcile the result to a sample transaction. Record where delays arise, such as missing units, uncertain entity identity or incorrectly structured geometry. Improving those upstream tasks is more useful than setting an arbitrary deadline that repeatedly leaves staff trying to finish the legal decision after logistics has already committed the goods.