EUDR due diligence statement DDS filing in TRACES

How to File Your EUDR Due Diligence Statement in TRACES NT: A Step-by-Step Guide

Last updated · June 11, 2026

All the supplier data is collected. The risk assessment is done. Now comes the moment compliance actually becomes real: filing the Due Diligence Statement (DDS) in the EU's information system. Until that declaration is submitted and a reference number lands in your inbox, your goods cannot legally enter or leave the EU market. This guide focuses entirely on that act - registering in TRACES NT and walking through the submission itself.

What a DDS Is - and What You Get Back

A Due Diligence Statement is a legally binding electronic declaration confirming that the products you are placing on, or exporting from, the EU market are deforestation-free, legally produced, and backed by a documented risk assessment. It is not a form you fill in for the record; it is the gate that opens or closes EU market access.

The DDS must be filed before the product enters or leaves the EU market. There is no grace period after arrival at port.

When you submit successfully, the system issues two identifiers:

Reference number - the public-facing ID that must accompany the customs declaration and be passed to your direct downstream buyer.
Verification number - a security token known only to the declarant and competent authorities. Downstream actors can use it to verify the authenticity of the upstream DDS and, where the submitter has authorised it, to view the stored geocoordinates of production areas.

The two numbers are inseparable. Storing and sharing the reference number without the corresponding verification number renders both meaningless for downstream verification purposes.

Before You Can Submit: Register in TRACES NT

TRACES NT (Trade Control and Expert System) is the European Commission's centralized digital platform and the mandatory submission interface for every EUDR Due Diligence Statement.

You cannot submit a DDS without an active account. Registration is a two-step process:

Create an EU Login account at webgate.ec.europa.eu. This is the Commission's single sign-on system; if you already use it for other EU services, you do not need a new one.
Register as an EUDR Operator inside the TRACES platform. Search for your company; if it is not listed, create it using the "+ Create a new operator" button. You will need to provide your EORI number (Economic Operators Registration and Identification number) if you import or export regulated products.

Allow 1–3 weeks for account setup. EORI validation and role approval by a local administrator take time. Without a validated account you cannot submit a DDS even if all your supplier data is ready — so register well before your first shipment deadline.

EU operators without an EORI number can register using alternative TRACES-supported identifiers, but importers and exporters will need the EORI. Non-EU companies can also access TRACES NT provided they hold a valid EORI number.

The Five-Step DDS Submission Walkthrough

Once your account is active, the submission flow inside TRACES NT follows five stages:

Enter shipment details, HS/CN codes and quantities

Select the product type from the interactive HS code tree, or search by keyword. Add the commodity description, quantity (net mass in kg), and country of production — meaning where the commodity was grown or harvested, not necessarily the country of export. The declared quantity must match your customs and shipping documentation; discrepancies can trigger inspections.

Upload geolocation data

Indicate the exact origins of your products by drawing areas on the built-in map, entering coordinates individually, or uploading in bulk. Bulk uploads use the GeoJSON standard format — the only geospatial file format the system accepts. The platform also lets you copy or re-use location data from previous submissions, which saves significant time for repeat sourcing relationships.

Confirm negligible risk

Declare that your due diligence process found no, or only negligible, risk of deforestation or illegality. This is the legal heart of the DDS. You are not just ticking a box — you are making a legally binding statement that supporting documentation exists and can be produced for a competent authority at any time.

Submit

Click submit. The system issues a DDS reference number and a verification number. Capture both immediately and link them to the relevant shipment record. The reference number must be included in the customs declaration's supporting documents section.

Pass the reference number downstream

Proactively share the reference number (and, where requested, the verification number) with your direct downstream buyer and with customs. Operators and traders are required to retain both numbers for at least five years.

Geolocation Upload Options in Detail

Geolocation is the most technically demanding part of the DDS. The system gives you three routes:

Method	Best for
Draw on map (GeoEditor)	Small numbers of plots; no file preparation needed
Enter coordinates individually	A handful of precise points or polygons
Bulk GeoJSON upload	Large supplier bases; multiple plots per shipment

Coordinates can be provided in bulk in a file using the GeoJSON standard format. If your traceability system exports in a different geospatial format (KML, Shapefile, etc.), you will need to convert before uploading. The Commission's information system page includes guidance on the most common GeoJSON technical issues.

For companies sourcing from multiple locations, the copy and re-use function is worth knowing: location data entered for one DDS can be pulled into subsequent submissions, avoiding repeated manual entry for the same production areas.

The Timing Rule: File Before Market Entry or Exit

The DDS must be filed in TRACES before placing products on or exporting them from the EU market. In practice this means:

Imports: before the customs declaration is lodged.
Exports: before the goods leave EU territory.
Domestic placements: before the product is first made available on the EU market.

Filing too close to shipment is one of the most common causes of customs delays. Build DDS submission into your pre-shipment checklist, not your post-arrival workflow.

If You Are Downstream: Reference, Don't Re-File

Under the amended regulation, the due diligence obligation rests exclusively with the operator placing the product on the EU market for the first time. Downstream operators and traders do not submit a new full DDS - but they are not off the hook entirely.

Downstream operators can reference upstream DDS reference numbers rather than re-collecting data. A chocolate producer in Italy using cocoa already imported into Europe, for example, can include the reference numbers of the upstream declarations in their own submission rather than repeating the full geolocation and risk assessment process.

What downstream actors must do:

Register in the TRACES system.
Collect and retain the reference number (and verification number) from their direct supplier.
Pass those numbers on to their own downstream buyers.
Keep records for at least five years.

Use the Sandbox Before You Go Live

The Commission operates two separate environments:

LIVE server - where real, legally binding DDS submissions are made. Statements here are subject to checks by competent authorities.
ACCEPTANCE server - a replica training platform where companies can simulate the entire DDS submission process without legal consequences.

Use the ACCEPTANCE server before your first live submission. It mirrors the production interface exactly, so your team can practise the full workflow — account setup, HS code selection, GeoJSON upload, and submission — without any compliance risk. The Commission encourages all operators to use it.

Note that as of February 2026, the Commission applied temporary access restrictions to both servers to update the system for the amended regulation. The LIVE server returned in read-only mode; the ACCEPTANCE server was temporarily unavailable. Both are expected to be fully operational again in summer 2026, with additional functionalities following. Check the Commission's information system page for the current status before planning your practice sessions.

Common Pitfalls to Avoid

Based on the most frequent DDS rejection and delay causes:

Invalid GeoJSON polygons. Polygons must be closed - the first and last coordinate must match. An unclosed polygon will fail validation.
Wrong HS code. Misclassification is one of the most common rejection reasons. Cross-check codes against Annex I and verify with your customs broker before filing.
Quantity mismatch. The declared quantity must match your customs and shipping documentation exactly.
Country of production ≠ country of export. The system requires the country where the commodity was grown or harvested, not where it was shipped from.
Late filing. Submitting the DDS after goods have already arrived at the border is non-compliant. Build submission into pre-shipment workflows.
Not storing both numbers. The reference number without the verification number - and vice versa - is incomplete for downstream use.

What Changes at the December 2026 and June 2027 Dates

The confirmed application dates are 30 December 2026 for large and medium operators and traders, and 30 June 2027 for micro and small operators. The Commission has confirmed it will not reopen the EUDR text.

The delay does not change what is required - it changes when enforcement begins. Core DDS obligations (geolocation, risk assessment, TRACES submission) remain fully intact. What the extra time gives you is the window to:

Register in TRACES and validate your account.
Run practice submissions in the ACCEPTANCE server.
Convert your geolocation data to GeoJSON format.
Establish the internal workflow for filing before each shipment.

For micro and small primary operators, the amended regulation introduces a one-time simplified declaration in place of a full DDS per shipment - but the TRACES registration requirement still applies.

What to Do Next

If you have not yet confirmed which products and roles apply to your business, work through the EUDR Obligations Checker before diving into TRACES. Once you know you need to file, the EUDR Readiness Checklist walks you through every step from data collection to a submitted DDS.

This is guidance to help you understand the DDS submission process, not legal advice. Confirm with the official sources linked above or a qualified adviser before filing.