How to Submit a Due Diligence Statement (DDS) on the EUDR Portal
Most guides to the EUDR spend their time explaining why the regulation exists. Far fewer explain what actually happens when someone sits down to file the paperwork — which portal to open, what data format it expects, and why submissions get rejected.
That gap matters more than it looks. An exporter can have flawless farm-level data, a clean risk assessment, and a fully mapped supply chain, and still watch a shipment stall at customs because the Due Diligence Statement itself was filed incorrectly.
The submission step is where good compliance work either gets recognised or gets lost in translation. It deserves its own walkthrough, separate from the broader "what is EUDR" conversation.
Think of it this way: farm mapping, supplier verification, and risk scoring are the raw ingredients. The DDS is the dish that gets served to customs. Get the ingredients right but plate it wrong, and the shipment still doesn't clear.
The platform at the centre of all this is TRACES NT — short for Trade Control and Expert System, New Technology. It existed long before EUDR, originally built for plant and animal health certificates, and the European Commission repurposed it to host the Registry of Due Diligence Statements rather than build something new from scratch.
That history explains a few of its quirks. The interface still carries traces of its old use case, and its validation logic is strict in ways that surprise first-time filers, particularly around geolocation formatting and reference-number chaining between upstream and downstream statements.
It's also worth being clear about what TRACES NT is not. It does not run a deforestation check on your data, it does not verify your risk assessment, and it does not confirm your land documentation is legitimate. It checks that a submission is complete and correctly formatted, then records it. The legal weight of accuracy sits entirely with whoever hits submit.
Geolocation data sits at the centre of nearly every rejection, which is why it's worth pairing this guide with our dedicated EUDR geolocation data guide — and if you're sourcing cocoa specifically, our Ghana cocoa compliance guide shows how that data gets collected at farm level before it ever reaches this submission stage.
What follows is a practical walkthrough built for African exporters specifically — not a generic EU compliance overview, but the actual sequence of decisions and data points a Ghanaian, Kenyan, or West African exporter needs to get a DDS accepted on the first attempt.
What a DDS Actually Proves
A Due Diligence Statement is a legally binding declaration that a specific batch of goods is deforestation-free, legally produced, and traceable to plot level. It is not a certificate, a summary, or a good-faith letter — it is a formal filing that carries legal liability for whoever submits it.
Once accepted, the statement generates two identifiers: a reference number and a security token known only to the filer and the competent authority. The reference number is what gets passed downstream — to a buyer, a processor, or a customs authority — so that party can verify the statement without needing to see the underlying supporting evidence themselves.
This is a deliberate design choice. The DDS keeps sensitive supply-chain detail confidential between the filer and the regulator, while still giving downstream buyers something concrete to check. Our EUDR compliance checklist for coffee and cocoa exporters walks through exactly which underlying documents need to exist behind that reference number, even though they never appear in the statement itself.
It also means liability doesn't dilute as the reference number passes downstream. If an audit later finds the underlying data was inaccurate, the party who filed the original statement carries the legal exposure, not the downstream buyer who simply cited the reference number in good faith. That asymmetry is exactly why EU importers are often cautious about accepting supplier data at face value, and why exporters who can show a clean, well-documented data trail tend to win more repeat business than those who can't.
Who Must File: Operators, Traders, Exporters
Filing responsibility depends on where you sit in the chain, and this is where African exporters most often get confused. The regulation's language was written around EU-based "operators" and "traders," not around exporters sitting outside the EU altogether.
| Role | Filing Obligation | Practical Note for African Exporters |
|---|---|---|
| EU importer (operator) | Must file a full DDS before placing goods on the EU market | Usually the party actually submitting through TRACES NT |
| Non-EU exporter | Cannot access TRACES without a valid EU or Northern Ireland EORI number | Typically supplies data to the EU importer rather than filing directly |
| EU-based representative | Can file on behalf of a non-EU exporter | Useful where an exporter wants direct control over filing |
| Downstream trader | References an existing DDS rather than filing a new one | Must still register in TRACES and retain reference numbers |
In most cases, the practical answer for a Ghanaian or Kenyan exporter is this: your EU buyer files the DDS, and your job is to supply them with accurate, complete, well-formatted geolocation and supply-chain data ahead of time. Some exporters choose to appoint an EU-based representative so they retain more control over the filing itself, particularly when working with several buyers who each want the statement handled differently. Our step-by-step cocoa compliance guide covers how this data hand-off typically works in practice.
There's a nuance worth flagging here, since sources on this point don't always agree cleanly: a non-EU operator can technically gain TRACES access if it holds a valid EORI number issued by an EU member state or by the UK specifically for Northern Ireland. A standard Great Britain EORI number does not work for this purpose. In practice, very few African exporters hold either, which is why routing the filing through the EU buyer or a representative remains the default path for most.
None of this changes where the actual due diligence work happens, though. Filing is an administrative last step. The data behind it — farm coordinates, land tenure evidence, supply chain mapping — still has to be collected and verified by someone close to the source, which in nearly every case means the exporter or their upstream partners, not the EU buyer sitting at the other end of the shipment.
What You Need Before You Start
Filing fails most often not because of the portal itself, but because the filer sits down without the right data assembled first. Five categories of information need to be ready before anyone opens TRACES NT.
| Data Category | Required Detail |
|---|---|
| Company identification | Legal name, address, and EORI number of the filing entity |
| Product description | Product name, Harmonised System code, and commercial description |
| Geolocation data | GPS point or polygon coordinates for every plot of origin |
| Supply chain linkage | Names of known parties handling the product through the chain |
| Risk assessment outcome | Documented conclusion that risk is negligible, with supporting evidence retained |
Note the distinction in the geolocation row: a single GPS point is acceptable for very small plots, but larger plots require a full polygon boundary rather than a centre point. Exporters working across commodity types will recognise this same requirement in our coffee compliance guide, since the geolocation standard doesn't change between crops — only the scale of the mapping challenge does.
The supply chain linkage category is the one most often assembled poorly under time pressure. It's not enough to name the exporting company; the filing needs to reflect every known party the product passed through, in sequence, from farmgate onward. Gaps here don't always trigger an outright rejection, but they do invite closer scrutiny during any later audit, since an incomplete chain is exactly what the regulation is designed to catch.
It helps to assemble all five categories into a single internal record before opening the portal at all, rather than gathering pieces as the filing form asks for them. Filers who work shipment by shipment, hunting for a missing coordinate mid-submission, are the ones most likely to submit incomplete or rushed data under deadline pressure.
Step-by-Step: Submitting on TRACES NT
Once the underlying data is assembled, the filing sequence itself is fairly consistent across commodities and shipment types.
- Create or access a TRACES NT account. The filing entity registers at the EU's TRACES portal, which requires a valid EORI number tied to an EU member state or Northern Ireland.
- Select the correct commodity and HS code. The system routes the filing differently depending on the product category, so an incorrect code here can misdirect the entire submission and force a full refiling.
- Upload geolocation data in the required format. Coordinates or polygon boundaries must be submitted as structured geographic data, not as an address or a general place name, and the file format needs to match the portal's accepted specification exactly.
- Enter supply chain details. List the known operators and traders who handled the product, in sequence, from point of origin to the current filer, without skipping intermediate aggregation points.
- Attach the risk assessment conclusion. Confirm the assessed risk level as negligible, referencing the underlying evidence retained internally rather than uploading it in full, since the portal expects a conclusion, not a case file.
- Reference any prior DDS where applicable. If the shipment incorporates material already covered by an earlier statement, cite that reference number instead of re-filing from scratch, and double-check the number is still valid before submission.
- Submit and record the reference number and security token. Both must be retained and shared with downstream parties who need to verify the statement without accessing your full data set.
Exporters diversifying into other regulated commodities should note that this sequence holds regardless of product. Our timber and wood compliance guide follows the identical seven-step logic, adjusted only for how origin data is captured at the concession or plantation level rather than the smallholder plot level.
The Three DDS Types Explained
Not every DDS carries the same weight. The regulation distinguishes between three situations, and mixing them up is one of the more common filing mistakes.
| DDS Type | When It Applies | Due Diligence Required |
|---|---|---|
| Placing on the market | First time the product enters the EU market, whether by import, export, or domestic sale | Full due diligence: geolocation, legality, and risk assessment |
| Making available | Supplying a product that already carries a valid DDS from an earlier stage | Reference existing statement rather than repeating full assessment |
| Downstream processing | A processed product incorporating previously declared raw material | New statement referencing all upstream DDS numbers used |
The third type trips up processors more than exporters, but it's worth understanding either way. A chocolate manufacturer using cocoa that already carries a valid upstream DDS still has to file a new statement of their own — it simply references the earlier one rather than repeating the geolocation and risk work from scratch. Palm oil supply chains follow the same layered logic, which our palm oil compliance guide breaks down in more detail for mill-to-refinery transactions.
A short worked example makes the distinction clearer. Say a Ghanaian cooperative's beans are shipped to an EU importer for the first time — that's a "placing on the market" DDS, requiring the full geolocation and risk package. If that same importer later resells the unprocessed beans to a domestic buyer within the EU, referencing the same shipment, that's "making available" — a lighter filing citing the existing reference number. If a chocolate manufacturer then buys those beans and produces a finished product for EU sale, that's the downstream processing case, requiring its own new statement that cites every upstream reference number used. Three filings, three different obligations, one continuous supply chain.
Common Rejection Reasons and Fixes
Most rejected filings fail for a small, repeatable set of reasons rather than anything exotic. Knowing them in advance saves a filing from bouncing back and forth between exporter and buyer.
Incomplete geolocation data is the single most frequent cause, usually because a plot was mapped as a point when its size required a full polygon. Mismatched HS codes are the second most common issue, particularly for processed or blended products that sit between two plausible classifications.
Reference-number errors round out the top three: citing an incorrect or expired upstream DDS number when filing a downstream or "making available" statement. This is especially common in smallholder-heavy supply chains, where the same challenges described in our soya compliance guide and our rubber compliance guide for smallholders apply just as directly to cocoa and coffee — fragmented origin data simply travels less cleanly through the chain than a single large plantation record does.
Beyond these three, a slower but equally costly failure mode is submitting data that's technically valid but out of date — a plot boundary that no longer matches the farmer's actual planted area, or a supply chain link that's missing a party added since the last filing. TRACES NT won't flag this on its own, since it checks format, not freshness. The safest habit is treating every shipment's underlying data as due for a quick review before filing, rather than assuming last quarter's records still hold.
- A DDS is a legally binding per-shipment filing, not a one-time certificate or general declaration.
- TRACES NT is the only portal for filing, and non-EU exporters generally need an EU or Northern Ireland EORI number, or an EU-based representative, to file directly.
- Most African exporters supply data to their EU buyer, who files the actual statement, rather than filing themselves.
- Geolocation formatting errors — points instead of polygons, or vice versa — are the leading cause of rejected filings.
- The three DDS types (placing on the market, making available, downstream processing) each carry different due diligence obligations.
- A rejected DDS can hold a physical shipment at port, making pre-filing checks far cheaper than post-rejection fixes.
Frequently Asked Questions
Only with a valid EU or Northern Ireland EORI number, which most African exporters don't hold. In practice, most rely on their EU buyer to file, or appoint an EU-based representative to submit on their behalf, especially when they sell to several EU buyers with different filing preferences.
The shipment can be held at the EU border until a corrected, accepted statement is in place, since customs clearance is directly tied to a valid DDS reference number. This is why exporters are increasingly asked to share draft geolocation and supply-chain data with their buyer well before the vessel departs, not after.
Generally yes for goods being placed on the market for the first time. Downstream parties referencing an already-declared shipment can file a lighter "making available" statement instead of repeating full due diligence, but a fresh filing is still typically required per shipment rather than per buyer relationship.
A single GPS point is accepted for smaller plots, while larger plots require a full polygon boundary. Submitting the wrong format for the plot size is one of the most common rejection reasons, and it's worth confirming the size threshold with your buyer or compliance partner before mapping begins.
No. TRACES NT validates formatting and completeness, not the underlying truth of the data. The filer remains legally liable for the accuracy of everything submitted, regardless of what the portal accepts, which is why internal record-keeping matters just as much as the filing itself.
The DDS is the moment where months of farm mapping, supplier verification, and risk assessment either convert into a clean, reusable reference number or stall at the last step. Exporters who treat the filing stage as seriously as the fieldwork behind it are the ones whose shipments keep moving without surprises. That habit, more than any single tool or template, is what separates exporters who file once and move on from those stuck resubmitting the same shipment three times over.