EUDR Voluntary Grouping: How to Bundle Due Diligence Statements Without Losing Track of Them

Grouping lets you create one due diligence statement that references several statements you already filed, so you are not submitting a fresh DDS for every shipment that shares the same verified data. It is entirely optional, it is built into the EU Information System, and it comes with one trade-off worth understanding before you use it: once a statement is grouped, you cannot amend or withdraw it on its own.

What grouping actually is

The EU Information System's own documentation defines it plainly: grouping is "the voluntary act by an Information System user of creating a new DDS or SD that references previously submitted declarations via their reference numbers." In other words, you are not merging data by hand. You point the system at the reference numbers of statements you already filed, and it builds a new statement that stands in for all of them.

The grouped statement:

• receives its own standard reference number, like any other DDS or simplified declaration (SD);
• automatically inherits the geolocation data from every statement it references; and
• represents all of the referenced statements for regulatory compliance purposes.

Who should actually use it

Grouping is built for a specific pattern: many similar consignments covered by shared due diligence, for example several deliveries drawn from one verified plot, or a master statement covering a batch of shipments that all trace back to the same underlying data. If that describes your shipping pattern, grouping can meaningfully cut the number of individual filings you manage.

It is less useful, and arguably not worth the complexity, if your consignments come from different plots, different suppliers, or different risk profiles shipment to shipment. Grouping does not simplify your due diligence; it consolidates statements whose underlying due diligence was already the same. If the underlying data differs between shipments, grouping them together does not make that difference go away, it just makes it harder to see.

The catch: grouped statements lock

This is the part worth planning around. Once a previously filed statement is referenced inside a grouped DDS or SD, it receives GROUPED status. A statement with GROUPED status cannot be individually withdrawn or amended while the grouped statement that references it remains active.

Practically, that means:

• Fix errors before you group, not after. If a reference number you are about to fold into a group has a mistake in its geolocation or legality evidence, correcting it later means unpicking the group first, not just editing the one statement.
• Group statements you are confident belong together. Because you lose the ability to touch the individual statements independently, grouping works best once you are sure the consignments genuinely share the same plot-level data, not as a way to tidy up statements you have not fully reviewed yet.
• Keep your own record of which reference numbers went into which group. The system tracks this, but your own supplier and shipment records should mirror it, so a downstream trader or customs query can be traced back to the right underlying declarations.

Where grouping fits in the wider 2026 system changes

Grouping arrived as part of a broader relaunch of the EU Information System, alongside a simplified declaration form for micro and small primary operators outside the timber sector, refreshed API specifications for operators who file programmatically, and a formal contingency procedure for system outages. The underlying Implementing Regulation (EU) 2026/1565 entered into force on 17 July 2026. None of this changes the application deadlines: large and medium operators and traders still need to be ready by 30 December 2026, and micro and small enterprises that qualified as such by 31 December 2024 have until 30 June 2027.

Grouping does not replace any of your due diligence steps. You still need to collect geolocation, assess and mitigate risk where required, and confirm legal production before any statement, grouped or not, is filed. What it changes is the filing mechanics once that work is done.

This is general guidance, not legal advice. The exact screens and workflow inside the EU Information System can change between releases, so check the current operator guidance before you plan a filing process around grouping.

What to do next

• Review the EUDR Checklist to confirm your due diligence data is complete before you consider grouping anything.
• See the obligations checker if you are unsure whether you file DDSs directly or simply hold upstream reference numbers as a trader or downstream operator.
• If you file programmatically, check the current API specification through the EU Information System operator documentation before building grouping into your integration.