EUDR DDS and Traceability for Non-EU Exporters: Four Practical Scenarios

Generally, you still need to prepare due diligence documentation for the finished products being exported. Simply passing on an upstream DDS reference number or a company-stamped declaration is not sufficient.

First, check what the supplier has actually provided: a declaration bearing the supplier's company stamp or a third-party verification certificate is not equivalent to a due diligence statement (DDS) submitted through the EUDR Information System in TRACES. These documents may serve as supporting evidence, but they cannot replace the DDS required for the finished products.

For the common supply route of "raw material origin → processing outside the EU → EU", an upstream DDS reference number alone does not exempt the importer of the finished products from its obligations. You need to provide the relevant plot geolocation data, harvesting period, and evidence of legality and deforestation-free status, and explain which raw materials were used in which finished products.

Existing, accurate plot geolocation data can be reused. Processing does not, in itself, require the plots to be mapped again.

An exemption from submitting a new DDS under the re-importation rules may apply only where the raw materials were previously placed on the EU market and underwent due diligence before being exported for processing and subsequently returned to the EU, with customs, transport and processing records substantiating that sequence.

Not necessarily. A single DDS can cover multiple shipments, so a new submission is not required for every shipment.

You can prepare information in advance on the products, quantities, raw material sources and due diligence evidence for planned supplies to a particular EU customer, allowing that customer to coordinate the DDS submission.

Check every shipment: does the quantity remain within the declared amount, and do the products and raw material sources match the DDS? For example, if the original DDS covers plots A and B, but the next shipment uses raw materials from plot C, which is not covered, you should provide additional due diligence documentation in advance and notify the customer so that it can arrange the corresponding DDS submission—even if the cumulative quantity remains within the declared amount.

Quantities may be estimated using a substantiated supply plan. If the actual quantity supplied is lower, retain an explanation of the difference. Do not arbitrarily inflate the declared quantity for convenience.

A single DDS should not cover a shipment period extending beyond one year from its submission date. Further supplies beyond that period require a new DDS. Where the coordinates remain accurate and unchanged, there is no need to remap the plots every year.

For relevant commodities other than cattle, the requirement generally depends on the size of the plot, with the threshold being "more than 4 hectares".

• Plots of 4 hectares or less: a single geolocation point may be provided.

• Plots of more than 4 hectares: the plot boundaries must be provided as a polygon.

Latitude and longitude coordinates must be specified to at least six decimal places.

Cattle are subject to traceability at establishment level: geolocation points must be provided for every establishment where the cattle were kept. A polygon is not required merely because an establishment exceeds 4 hectares, and providing only the location of the final farm is not sufficient.

All coordinates must identify the actual production plots or relevant establishments. The location of a supplier's office or the centre of a village cannot be used as a substitute.

For bulk data submission, GeoJSON is recommended. The system also supports manual coordinate entry and drawing on the map.

First, identify the relevant commodity category under which the finished product is listed in Annex I. Then trace all relevant sources of that commodity.

For example:

• Wooden furniture made from several types of wood: trace all sources of the wood concerned, rather than checking only the main type of wood.

• Palm oil blended from several plantations: providing information for only one plantation is not sufficient.

• Chocolate containing cocoa and palm oil: conduct due diligence for the chocolate listed under "Cocoa" in Annex I. The presence of palm oil in the recipe does not automatically mean that palm oil must also be traced for that chocolate DDS.

The rule is therefore neither "trace every ingredient without distinction" nor "trace only the raw material used in the largest quantity". Check the finished product's customs code, the product description in Annex I and the corresponding relevant commodity category.