EUDR from 30 December 2026: who files the due diligence statement, and can one DDS cover a year of shipments?

2026-11-04 · IberTrust Global

From our files · questions from non-EU suppliers and EU sellers preparing for the EUDR, October–November 2026, anonymised

“Our buyer in Germany says we need a DDS number before the December container leaves. Do we file it in our name or theirs? And do we need a new one for every shipment?”

With the EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) applying from 30 December 2026, the question is no longer “does it apply?” but “who submits the statement, and how often?”. Here are the answers, from the Regulation, the Commission’s FAQ (version 5, April 2026) and our own intake work.

The dates that apply now

• 30 December 2026: large and medium-sized operators and traders, plus micro and small operators for timber products already covered by the old EU Timber Regulation.
• 30 June 2027: other micro and small operators and natural persons established as such by 31 December 2024.
• 30 December 2027: products newly added by Delegated Regulation (EU) 2026/2102, such as soluble coffee and certain palm oil derivatives.

Who is the “operator” that submits the DDS?

The due diligence statement (DDS) is submitted by the operator: the person who places the relevant product on the EU market or exports it. For imports, that is whoever releases the goods for free circulation, whether or not it is established in the EU (FAQ 3.18).

Two roles are often confused with the operator. A customs representative is never the operator (FAQ 3.15). An EUDR authorised representative submits on the basis of a written mandate, must be established in the EU, and the operator keeps full responsibility (Articles 2(22) and 6). So a non-EU supplier cannot file “for” its EU buyer: it can only access the Information System as an operator, with an EU-issued EORI number (FAQ 3.7).

Can one DDS cover several shipments?

Yes. One DDS may cover several batches and products placed on the market over time, and the same reference number can be quoted on several customs declarations (FAQ 5.19 and 5.20). The conditions:

1. Submit before the first customs declaration. The declarant must quote the reference number on every import declaration (Article 26).
2. Declare the full quantity. When it has been used up, a new DDS is needed.
3. Maximum one year. Because due diligence systems are reviewed annually (Article 12(2)), a DDS should not cover more than a year from submission.
4. The commodity should already exist. In principle, trees or crops must already be harvested; the furniture made from them need not be. Stable plots are an exception.
5. One product, one DDS. Keep records matching declared and actual quantities for five years.
6. 25 MB limit per DDS, geolocation included.
7. Shared risk. Interim measures may hit every batch under the same DDS.

A submitted DDS can only be amended or withdrawn within 72 hours after the reference number is issued (FAQ 7.6). After that, you submit a new one.

Data checklist: what the supplier must provide

1. Operator name, address and EORI number.
2. HS code and product description; for wood, scientific and common species names.
3. Net mass in kilograms.
4. Country of production: where the commodity was grown or harvested, not where it was processed.
5. Geolocation of every plot, with at least six decimal digits; polygons for plots over 4 hectares (except cattle).
6. Date or period of production.
7. Names, postal and email addresses of suppliers and EU customers.
8. Evidence of deforestation-free production (cut-off 31 December 2020) and legality in the country of production.
9. A signed mandate, if an authorised representative submits.
10. Planned quantity and shipment schedule, if one DDS will cover several batches.

On low-risk origins: Implementing Regulation (EU) 2025/1093 classifies China, for example, as low risk. Where all commodities come from low-risk countries, simplified due diligence lets you skip risk assessment and mitigation unless there are warning signs, but the information above, coordinates included, must still be collected and a DDS still submitted (Article 13).

What we changed in our own intake form

When we rebuilt our EUDR data sheet in October 2026, the older template we started from asked for one coordinate or address per product and listed “paper and wooden furniture” as a separate commodity. Both were wrong: every plot needs geolocation, and paper and furniture fall under wood. We also moved one question to the top: “Who is the importer of record?” The mandate and the DDS must carry the operator’s name and EORI, not the supplier’s.

Common mistakes

• The supplier files in its own name while the EU buyer is the importer.
• “Sign this template and you get a DDS number.” We have seen this promise in sales messages. A DDS needs the EORI, HS code, net mass, country of production and all plot coordinates, plus confirmation that due diligence was done.
• Giving the factory’s country instead of the country of production.
• An “annual DDS” without quantities, or one still used after the quantity or the year has run out.
• Asking the customs broker to be the operator.
• Demanding a DDS from traders. Downstream operators and traders cannot submit one (FAQ 3.10.1).

Member States must set maximum fines of at least 4% of the operator’s total annual EU turnover (Article 25).

Who this does not apply to

• Products outside Annex I, including books, newspapers and printed pictures (removed in December 2025), and packaging used only to support, protect or carry another product.
• Consumers buying for private use.
• Downstream operators and traders: they keep records but submit no DDS.
• Micro and small primary producers in low-risk countries selling their own produce: they file a one-off simplified declaration instead.
• Most micro and small operators: not before 30 June 2027.

FAQ

Do we need a new DDS for every container?

No. One DDS can cover several shipments for up to a year, if the declared quantity covers them all and the reference number is quoted on each customs declaration.

Can our supplier outside the EU submit the DDS for us?

Not as authorised representative, because that role requires EU establishment. A non-EU company submits only if it is itself the importer, using an EU-issued EORI number.

Is a DDS valid for twelve months?

No fixed validity applies, but a DDS should not cover more than one year from submission, and it ends earlier once the declared quantity is used up.

Can we correct a DDS after submitting it?

Only within 72 hours after the reference number is issued. After that, submit a new DDS.

Our raw material comes from a low-risk country. Do we still need plot coordinates?

Yes. Simplified due diligence removes risk assessment and mitigation, not the information requirements or the DDS.

Preparing for 30 December 2026?

IberTrust Global S.L. prepares and submits EUDR due diligence statements as an EU-established authorised representative, and prepares traceability and risk reports for one product category. Tell us who imports the goods and we will tell you who has to file, and when.

Ask about EUDR DDS submission →
Need the supply-chain evidence first? Ask about a traceability report or write to contact@ibertrust.info.

Sources: Regulation (EU) 2023/1115, consolidated text (Articles 2, 5, 6, 7, 9, 12, 13, 25, 26, 38, Annexes I and II); Regulation (EU) 2025/2650; Delegated Regulation (EU) 2026/2102; European Commission, EUDR FAQ version 5 (April 2026), FAQ 3.7, 3.10.1, 3.15, 3.18, 3.19, 5.19, 5.20 and 7.6; Implementing Regulation (EU) 2025/1093; European Commission, Regulation on deforestation-free products; Council press release, 18 December 2025; IberTrust files (anonymised). General information, not legal advice.