The Due Diligence Statement and the EU Information System, end to end

Everything else in the EUDR is preparation for one act: submitting a due diligence statement. It is a short document, it takes a few moments to file, and it is the point at which a large amount of evidence becomes a legal assertion by a named person in your organisation.

That last part is worth dwelling on before the mechanics, because it is easy to lose in the discussion of file formats. By submitting, the operator assumes responsibility for the compliance of the product. It is not a data upload. It is a declaration.

What goes into a statement

The content is prescribed rather than open-ended. In substance a statement carries:

• Who the operator is, including EORI where relevant.
• What the products are, by customs classification code, with description and quantity.
• The country of production.
• The geolocation of all plots where the commodity was produced, with the date or time range of production.
• A declaration that due diligence was carried out and that no more than negligible risk was found.

The geolocation is the part that carries the weight and the part that most often fails. Everything else in that list already exists somewhere in a normal import process; plot coordinates generally do not.

The reference number

A successful submission returns a reference number. Since the 2025 amendment moved the filing obligation to the party first placing goods on the market, that number has become the connective tissue of the whole regime.

It is quoted in the customs declaration, so goods can be linked to the statement covering them. It is passed to downstream operators and traders, who retain it rather than filing again. And it is what an authority will use to pull your file.

The practical consequence is that reference numbers have to be handled as first-class supply chain data — attached to consignments, surviving splitting and consolidation, and retrievable years later. Most ERP configurations have nowhere obvious to put one, and a free-text comment field is not a place you can query under time pressure.

The 2026 rebuild

Access to the Information System was restricted from mid-February 2026 while it was reworked to carry the amended regulation, with a staged reopening from June. It was a substantial change rather than maintenance.

By hand or by API

For a handful of consignments a year, the web interface is fine. Beyond that it stops being viable quickly — not because typing is slow, but because manual submission means your statement content is assembled by a person from several systems, and that is where inconsistencies enter.

The case for integrating early is not throughput. It is that the integration forces you to discover, months before the deadline, that your plot data does not fit the expected structure — a discovery that is cheap in September and very expensive in late December.

Where customs fits

The statement and the customs declaration are separate acts that have to line up. When relevant products are declared for release for free circulation or for export, the reference number of the due diligence statement is quoted in the customs declaration, and customs authorities can hold goods where that link is missing or does not resolve.

The consequence for planning is that filing is not a back-office task that can happen at month end. It sits on the critical path of the shipment, and it has to complete before the goods can clear. Any process that assembles plot data manually, per consignment, becomes a bottleneck at the border rather than an administrative inconvenience.

Timing, and getting it wrong

The statement is submitted before placing on the market or export, not after. Filing retrospectively to cover goods already released does not repair the position — the obligation was to have done the diligence first, and the timestamp records whether you did.

If something later proves incorrect, the answer is to act on it rather than to leave it: correct the record, and where non-compliance is established, take the steps the regulation requires and inform the competent authority. A statement that is known to be wrong and left standing is a considerably worse position than one that was corrected.

What to do before December

1. 1

   Register now

   Registration is administrative and can be done long before you file anything. It is also a dependency for everything else.

2. 2

   Submit test statements against real data

   Not sample data. Real plots from a real supplier, which is what exposes structural problems.

3. 3

   Decide where the reference number lives

   A queryable field on the consignment, before the first live submission rather than after the hundredth.

4. 4

   Name who signs

   Submission is a declaration of responsibility. Someone in your organisation is making it, and they should know that before they do.

When the system is unavailable

Any process with a hard dependency on an external system needs an answer for the day that system is not there, and the rebuild added defined contingency procedures for exactly that. It is worth knowing what they are before you need them, because the alternative is an unplanned halt at the border with no agreed fallback.

The same applies to your own side of the integration. A submission pipeline that fails silently — queuing statements that never actually reach the system — is worse than one that fails loudly, because goods keep moving on the assumption that filing happened. Alerting on unacknowledged submissions is not optional at volume.

The statement itself is genuinely straightforward. If filing feels hard, the difficulty is almost never in the form — it is that the form asks for a link between goods and land that the supply chain was never built to maintain.

Published August 11, 2026 · Updated August 12, 2026 · Last reviewed August 12, 2026 against the sources listed above.