Reviewed 31 August 2026 · next review 30 November 2026
How a due diligence statement is prepared
A statement is the last step, not the first. Everything that makes it difficult happens earlier: deciding your role, defining the lot, and getting plot data out of suppliers who have never been asked for it.
Last updated · Written and reviewed by Jonatan Tensetti · Tensetti Tools
Step 0 — confirm you are the one who files
Not every company in a supply chain submits a statement. Operators who first place a relevant product on the EU market, or export it, perform due diligence and submit. Qualifying upstream micro and small primary operators use a one-off simplified declaration instead. Downstream operators and traders generally do not submit their own statement under the December 2025 simplifications — they collect and keep supplier and buyer information for at least five years, and the first downstream actor retains the upstream reference.
If you are in that last group, do not buy a filing service. What you need is traceability discipline and a reliable way to store references. Work out your role first.
| Step | What you do | What stops people |
|---|---|---|
| 1. Define the lot | Decide the unit the statement covers: consignment, batch, or a defined period for a stable supply line. | Mixed shipments from several plots, and lots defined by finance rather than by traceability. |
| 2. Collect Article 9 information | Product description and quantity, country of production, plot geolocation, supplier and buyer details, production dates, legality evidence. | Geolocation held by an intermediary who treats it as commercially sensitive. |
| 3. Assess risk | Weigh country benchmark, chain complexity, mixing risk, and the reliability of the evidence you actually hold. | Treating a low-risk country benchmark as a conclusion rather than one input. |
| 4. Mitigate until negligible | Request more data, verify independently, or change supplier. Record what changed the conclusion. | Mitigation described in general terms with no evidence trail. |
| 5. Submit and keep the reference | Submit in the Information System before placing or exporting, then pass the reference down the chain. | Reference numbers stored in email rather than in a system anyone else can find. |
| 6. Retain | Keep statements, evidence and supplier and buyer information for at least five years. | Retention policies that delete purchasing records earlier than five years. |
Getting geolocation out of suppliers
Ask early, ask in writing, and ask for a specific format. A supplier who has never provided plot coordinates will not produce a polygon because a contract clause exists. What works: a short data request that names the fields, states the format, explains what it is used for, and commits to how it will be protected. See the geolocation requirements.
What "negligible risk" has to mean
Negligible risk is a conclusion you can defend with evidence, not an absence of contrary information. If your file amounts to a supplier declaration and a certificate, say so in your own record and treat it as a gap to close, rather than as a completed assessment.
Before your first submission
Register the entity, sort authorisations, and run one dry pass on a single product line with real data before doing it at volume. The first submission guide lists the practical arrangements. This page is a preparation aid, not legal advice, and not an official submission channel.
Primary sources
Reviewed 31 August 2026. Always confirm against the current official text.
- Regulation on deforestation-free products — implementation overview — European Commission. Current application dates, implementation overview and links to Commission resources.
- Commission update on product scope and implementation tools — European Commission. 13 July 2026 Commission update on proposed product-scope changes, the Information System, simplified declarations and the revised operating model. Product-scope changes described there must be checked against the delegated act's current legal status before being treated as effective.
- Regulation (EU) 2025/2650 — EUR-Lex. In-force December 2025 amendment covering revised operator/trader obligations, application-date provisions, the micro/small primary-operator route and removal of the former Annex I Chapter 49 printed-products entry.
- EUDR Information System resources — European Commission. Official implementation page linking the current Information System and related technical resources.
- Consolidated Regulation (EU) 2023/1115 — EUR-Lex. Current consolidated text at the 31 August 2026 review date. Use it for the in-force Annex I baseline and verify whether EUR-Lex has published a later consolidation before making a material decision.
- FAQ on EUDR implementation — European Commission. Commission implementation FAQ page refreshed in August 2026 and available in EU languages.
- Commission Delegated Regulation C(2026)4920 — Annex I amendment — EUR-Lex / European Commission. Adopted by the Commission on 13 July 2026. At the 31 August 2026 review date EUR-Lex still displayed an unnumbered delegated regulation rather than a published Official Journal act. Track this source for status changes before applying its proposed Annex I additions, removals and technical exclusions.
No account, no supplier documents, no evidence uploads. Answers stay in your browser.
This is a self-service readiness and documentation tool based on the information you provide and the sources listed for assessment version 1.0.0. It is not legal advice, an audit, certification, conformity assessment or an official filing. It does not submit a due diligence statement, validate Annex I classification or geolocation, certify deforestation-free status or determine negligible risk. Verify material decisions with the relevant authority or a qualified adviser.
Frequently asked questions
- What data does a due diligence statement need?
- Product and Annex I code, quantity, supplier and country of production, the geolocation of the plots of land, and the risk assessment and mitigation record behind your negligible-risk conclusion.
- What counts as negligible risk?
- A conclusion you can defend with evidence, not simply the absence of contrary information. If your file is one supplier declaration and a certificate, record that as a gap rather than as a completed assessment.
- Do we need polygons or are points enough?
- Point coordinates are accepted for plots below the size threshold; larger plots need polygons. Agree the choice per plot early, because renegotiating it with suppliers late is what breaks timelines.
- Is this an official submission channel?
- No. This is preparation material. Statements are submitted in the EU Information System by the responsible entity, and this guide only helps you arrive there with the data assembled.