EUDR · Regulation (EU) 2023/1115

EUDR Due Diligence Statement Check

Answer nine questions about your commodity, supplier country and operation. Get a cited verdict on whether a DDS is required, the deadline that applies and the TRACES NT path to follow.

DDS readiness check

Reg (EU) 2023/1115 · TRACES NT

Your operation

How your answers decide the verdict

  • Headcount + net turnover + balance sheet determine size: do not exceed at least two of 50 employees, EUR 10 million turnover and EUR 5 million balance sheet. The later deadline also requires establishment as micro/small by 31 December 2024 and excludes timber in Regulation 995/2010.
  • Commodity + HS code decide whether the line is in EUDR Annex I scope at all.
  • Production country sets the country-risk class (low / standard / high) and so the depth of due diligence.
  • EU placement country + date confirm the goods enter the EU market and which deadline applies.

Two deadlines, set by Regulation (EU) 2025/2650 (OJ 23 December 2025): operators generally apply the rules from 30 December 2026. The 30 June 2027 date is only for qualifying micro/small firms established as such by 31 December 2024, excluding timber listed in Regulation 995/2010. All downstream operators and traders retain information without submitting a DDS; non-SMEs must register. Country risk (low / standard / high) follows Commission Implementing Regulation (EU) 2025/1093, in force since 23 May 2025 — its low list covers most of the world, while deforestation-frontier producers default to standard.

Large / medium30 Dec 2026Qualifying micro / small30 Jun 2027

Official sources: Regulation (EU) 2023/1115 · Reg (EU) 2025/2650 · Impl. Reg (EU) 2025/1093 · EU EUDR / TRACES · Delegated Reg. (EU) 2026/2102 (Annex I) · Directive 2013/34, Art. 3(2) (company size)

What a valid DDS needs
Information (incl. plot geolocation), a risk assessment against the deforestation-free + legality criteria, and risk mitigation until risk is negligible — then a statement lodged in TRACES NT.What it produces
A DDS reference number that downstream operators and traders reuse. An incomplete DDS blocks placement and exposes you to Art. 25 penalties. Read the methodology

TRACES NT submission workflow

  1. Confirm your operator role and the producing country; pull the Annex I HS code for each line item.
  2. Capture geolocation polygons for every production plot and document the supply chain back to the operator who first placed the goods on the EU market.
  3. Log in to TRACES NT, create a DDS record per Art. 4(2), attach the geolocation file and reference any upstream DDS numbers.
  4. Retain the submission reference, the polygons and the supporting documentation for at least five years from the placement date (Arts. 4/12 for operators; Art. 5(4) for downstream operators and traders).

EUDR Due Diligence Statement — frequently asked questions

When is the first EUDR Due Diligence Statement due?
Operators: 30 December 2026; qualifying micro/small firms established as such by 31 December 2024: 30 June 2027, except timber in the Annex to Regulation 995/2010 (30 December 2026 for every size). Traders and downstream operators do not file a DDS. These dates come from Regulation (EU) 2025/2650, the deadline-extension act published in the Official Journal on 23 December 2025. Verified 17 October 2026 against the consolidation of 18 September 2026:, no further postponement has been adopted — confirm against the current EUR-Lex text before filing.
Which commodities are in scope?
Seven: cattle, cocoa, coffee, oil palm, rubber, soya and wood — plus products derived from them (e.g. chocolate, wooden furniture, paper and certain tyres) as listed in Annex I of Regulation (EU) 2023/1115 by Combined Nomenclature code. Delegated Regulation (EU) 2026/2102 removed leather, synthetic rubber and certain rubber articles; coffee extracts (CN 2101 11 00) enter on 30 December 2027. Used goods, waste, samples and packaging accompanying another product are excluded. Confirm the exact CN description: this tool uses a partial subset.
What does my country's risk class change?
Risk class (low / standard / high) is set by Implementing Regulation (EU) 2025/1093. Low-risk sourcing allows a simplified due-diligence procedure (Art. 13) — reduced risk assessment — but you still file a DDS and submit geolocation. Standard and high require full due diligence; high-risk countries face higher inspection rates. Regulation (EU) 2025/2650 also introduced a further simplification for MICRO AND SMALL PRIMARY operators sourcing from low-risk countries: a one-off simplified declaration in place of a due-diligence statement for every shipment. The precise mechanics were not confirmed against the consolidated article text for this check — verify against the official source before relying on it.
Which countries are high risk?
Only four under Implementing Regulation (EU) 2025/1093: Belarus, North Korea (DPRK), Myanmar and the Russian Federation. The benchmarking's low list covers most other countries; any country not in the Annex is standard by default.
Is the country benchmarking final?
It is the operational list, but contested. The European Parliament adopted a non-binding objection to the methodology on 9 July 2025 (vote count unconfirmed, previous verification 13 June 2026). The classification could be revised, so confirm the current Commission Green Forum list before relying on a low/simplified outcome.
Does a low-risk country mean no Due Diligence Statement?
For operators on the standard DDS route, low risk simplifies the risk-assessment step. They still collect geolocation for each plot, submit a DDS in TRACES NT and retain records for at least five years (Arts. 4/12 for operators; Art. 5(4) for downstream operators and traders). Downstream operators and all traders instead retain Article 5 information without submitting a DDS, whatever the country risk or company size.

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