akar.earthWriting an EUDR Due Diligence Statement
How an EUDR due diligence statement works: who files it, what data it needs, how Indonesian suppliers feed it, and why statements get rejected.
An EUDR due diligence statement (DDS) is the declaration an operator files in the EU Information System before placing a covered product on the EU market or exporting it. It confirms that due diligence was carried out and that the risk of the product being non-compliant is no more than negligible, and it carries the product, quantity, supplier and plot geolocation data behind that claim.
Who files it
Since the December 2025 amendments, full due diligence responsibility rests with the operator who first places a covered product on the EU market. That operator files the DDS. Downstream operators and traders have lighter duties, mainly collecting and passing on DDS reference numbers so that the chain stays traceable. Micro and small primary operators can use a one-off simplified declaration instead. See operators and traders for the split.
Indonesian exporters are not normally operators under the EUDR, because they sell to the EU rather than placing on the EU market. But the operator cannot file without data from upstream, so in practice the Indonesian exporter does much of the groundwork.
What goes into a statement
The exact fields are set out in the Regulation and the Information System. Broadly, a DDS covers:
| Element | What the operator needs | Who in Indonesia usually holds it |
|---|---|---|
| Operator details | Name, address, identifiers such as EORI | EU importer |
| Product | Description, HS code from Annex I, quantity | Exporter and importer |
| Country of production | Indonesia, and sub-national area where relevant | Exporter |
| Geolocation | Points or polygons for every plot of production | Cooperatives, collectors, mills, field teams |
| Deforestation-free and legality confirmation | Result of due diligence, backed by evidence held on file | Exporter, with plot screening results |
| Upstream references | Reference numbers of earlier statements where products were already covered | Previous operators |
The evidence itself, such as satellite screening, land documents and supplier maps, does not all go into the statement. It sits in the operator’s files and must be available to competent authorities. Records must be kept for five years.
The due diligence behind the statement
A DDS is the output of a process, not a replacement for it. The process has three steps:
- Information collection. Geolocation, supplier details, quantities, and evidence on deforestation status and legality.
- Risk assessment. Checking that information against the risk criteria, including the country benchmark, presence of forest, indigenous peoples, supply chain complexity and the risk of mixing with unknown origin.
- Risk mitigation. Additional evidence, independent audits, or support for suppliers until the risk is negligible.
If the risk cannot be brought down to negligible, the operator must not file and must not place the product on the market.
How Indonesian suppliers feed the DDS
What a strong supplier data package looks like:
- A plot register. One row per plot with a unique ID, farmer or company name, village, crop, area, and a link to its geometry. See polygon requirements.
- Geometry in GeoJSON. Points with six decimal places for small plots, polygons for plots over 4 hectares, in WGS84.
- Screening results. For each plot, whether it shows tree cover loss after 31 December 2020, and how flagged plots were resolved.
- Legality file. Land documents such as SHM or SKT, STDB registration for smallholder estate crops, permits for companies, and SVLK documents for wood.
- Shipment links. Which plots supplied which lot or container. Mass balance is not accepted, so this link must be real.
Our AKAR Dashboard keeps this register in one place and exports it in the formats buyers ask for.
Why statements get rejected or questioned
Common problems seen in submissions:
- Invalid geometry, such as self-intersecting polygons, points in the sea, or coordinates swapped between latitude and longitude.
- A polygon missing for a plot over 4 hectares.
- The wrong HS code for the product.
- Quantities that do not match the shipment or the plausible yield of the declared plots.
- Evidence that contradicts the claim, for example a plot that shows clear tree loss in 2022.
Most of these are data quality issues that can be caught upstream. Validating geometry and cross-checking yield per hectare before export saves rework.
Practical tips
- Agree a data template with your EU buyer early. Each buyer may ask slightly differently.
- Give every plot a stable ID and never reuse it.
- Keep farmer consent records for data sharing. See farmer registration and consent.
- Store your evidence so you can answer an authority’s question years later.
For the wider topic map, see the EUDR hub. For hands-on help with mapping and data packaging, see our EUDR compliance services or message us on WhatsApp.
Frequently asked questions
What is an EUDR due diligence statement?
It is a declaration filed in the EU Information System before a covered product is placed on the EU market or exported, confirming that due diligence was done and found no or only negligible risk of non-compliance.
Do Indonesian exporters file the due diligence statement?
Usually not. The EU operator that first places the product on the market files it. Indonesian exporters supply the data behind it, especially plot geolocation and legality evidence.
How long must records be kept?
Operators must keep due diligence records and statements for five years.
Does certification replace the statement?
No. Certification schemes can support risk assessment, but they do not replace the operator's own due diligence or the statement.