The EUDR due diligence statement: why there is no template, what Annex II requires and what happens after you submit

"Is there a template for the due diligence statement?" is the most frequently asked question about the EUDR, and it points in the wrong direction, because it carries a false idea of what the statement is. There is no form to download, no Word document, no PDF you fill in, sign and file. The due diligence statement is an electronic record you enter and submit in the EU information system, and by submitting it you assume responsibility, under Article 4(3), for your product complying with Article 3 of the Regulation.

What does exist is better than a template: an exhaustive list of the items the statement must contain. It is set out in Annex II, and it is not guidance but the text of the Regulation, including the wording of the declaration itself and the format of the signature.

This article walks through that list item by item, explains how many shipments one statement may cover, describes what happens in the system after you submit, and covers the two special forms: the simplified declaration for micro or small primary operators and the aggregated statement, which has only existed since July 2026. It also sets out what downstream operators and traders do, given that under Regulation (EU) 2025/2650 they submit no statement, regardless of their size. At the end there is a preparation sheet for collecting the data before you open the system.

What the statement is in legal terms

Article 4(2) frames it as a prohibition with a condition: operators shall not place relevant products on the market or export them without prior submission of a due diligence statement. The statement is therefore not an after-the-fact report but a precondition. It is submitted before placing on the market or export, through the information system under Article 33.

It presupposes that due diligence has already been exercised. The wording is unambiguous: operators who have concluded, on the basis of the due diligence exercised under Article 8, that the products comply with Article 3, submit the statement. The order is therefore collect information under Article 9, assess risk under Article 10, mitigate risk under Article 11, and only then declare. Anyone treating the statement as the first step has the process the wrong way round.

Paragraph 3 draws the conclusion: by submitting the statement, the operator assumes responsibility for the compliance of the relevant products with Article 3. That is the actual legal act. The statement is not a record you keep but an assurance you give, and it is to be kept for five years from submission.

Paragraph 4 names the cases in which you may not declare and may not place on the market: where the products are non-compliant, where due diligence has revealed a more than negligible risk, or where the operator was unable to fulfil the obligations under paragraphs 1 and 2. The third case is the most common in practice: anyone who cannot assemble the required information may not place the product on the market. The Commission says so explicitly in its FAQ, twice in the same passage.

The five mandatory items under Annex II

In the version now in force, Annex II lists five items, because Regulation (EU) 2025/2650 deleted point 4; the remaining points keep their numbers. The list is exhaustive, and it is also the best available "template".

1. Operator and EORI number. Name and address of the operator, and for products entering or leaving the market the EORI number under Article 9 of the Union Customs Code. The EORI number is therefore mandatory only for import and export, not for purely intra-Union movements.

2. HS code, description and quantity. The HS code, a free-text description including the trade name and, where applicable, the full scientific name, and the quantity. For products entering or leaving the market the quantity is given in kilograms of net mass and, where applicable, in the supplementary unit laid down for that HS code in the Combined Nomenclature. In all other cases in net mass, net volume or number of items.

The scientific name is not optional for wood. In the July 2026 version the Implementing Regulation is explicit: where a relevant product contains or has been made using wood, users state the full scientific names of the species concerned in the statement. For mixed assortments that means several names, not one.

Which code has to be declared in the first place, and what a leading "ex" means, is covered in EUDR Annex I and CN codes.

3. Country of production and geolocation of all plots. Not some, not the main ones, but all plots of land where the relevant commodities were produced. For products containing or made using cattle, and for products fed with relevant products, the geolocation refers to all establishments where the cattle were kept. Where a product comes from several plots, the coordinates of all of them are given.

4. Deleted. This point covered the reference numbers for operators referring to an existing statement under Article 4(8) or (9). Regulation (EU) 2025/2650 deleted those paragraphs and point 4. Since then, downstream operators and traders submit no due diligence statement, and therefore none referring to another.

5. The prescribed wording. It appears verbatim in the Regulation: "By submitting this due diligence statement the operator confirms that due diligence in accordance with Regulation (EU) 2023/1115 was carried out and that no or only a negligible risk was found that the relevant products do not comply with Article 3, point (a) or point (b), of that Regulation."

Read that sentence once for what it is: a personal assurance that somebody in your company signs with their name and function.

6. The signature in a prescribed format. Annex II even lays down the layout: "Signed for and on behalf of: Date: Name and function: Signature:". Who that person is, and whether they are actually in a position to judge the due diligence, should be settled before the first statement rather than at the moment of submission.

Example: what a completed due diligence statement looks like (fictitious)

The example shows the five Annex II items as the Information System asks for them. The company and the plots are invented; the coordinates are placeholders and do not describe real land. The same example is available as a PDF download; the preparation sheet at the end of the article helps you collect the data.

What stands out: the EORI number is there because the goods are imported; for a purely intra-Union movement the field would stay empty. The plots are given as polygons because none is below four hectares; a point is enough for smaller plots. The statement lists all four plots the lot comes from, not just the largest. The harvest period (here November 2025 to February 2026) is not part of the statement but belongs in the records under Article 9.

What sits underneath: the information under Article 9

The statement is the tip. Beneath it sits Article 9, which determines what information you must have collected, organised and supported by evidence, and kept for five years from the date the products were made available or exported. That is more fields than the statement itself contains.

A description including the trade name and type of the product, for wood also the common name of the species and its full scientific name, together with a list of the relevant commodities and products contained in it or used to make it. The quantity, by the same rules as in the statement. The country of production and, where relevant, its subnational parts. The geolocation of all plots, plus the date or time range of production, which does not appear in the statement itself but must be in your records.

One sentence in Article 9 deserves particular attention, because it describes the consequence of a single problematic plot: any deforestation or forest degradation on those plots automatically disqualifies all relevant products and commodities from those plots from being placed on the market, made available on the market or exported.

Added to that are the name, email and address of the businesses that supplied you and of those you supplied, together with adequately conclusive and verifiable information that the products are deforestation-free and that production was legal.

The geolocation trap: why too much is worse than too little

There is a reflex that is wrong and can become expensive: when in doubt, declare every plot that might be the origin. The Commission has answered this unusually plainly.

Where an operator declares "too much" in the due diligence statement, it assumes full responsibility for compliance in respect of all plots for which geolocation is provided, regardless of whether those plots were involved in producing the goods that are actually placed on the market. If a single declared plot does not meet the requirements, the entirety of the declared plots is non-compliant.

So anyone declaring fifty plots as a precaution when only twenty supplied has to exercise due diligence in full for all fifty, assess the risk under Article 10(2) for all fifty, taking particular account of criteria (i) and (j), and demonstrate for all fifty that the risk is negligible. A hit on one of the thirty superfluous plots renders the whole statement worthless.

The rule is therefore: exactly the plots the declared quantity comes from. No fewer, but no more either.

How many shipments one statement may cover

This is the most consequential relief in practice, and it is less well known than it should be. A due diligence statement does not have to be submitted per shipment. The Commission has set out the rules for this in its FAQ under question 5.19.

First, a statement does not have to be submitted for individual batches or consignments; it can cover several.

Second, it applies until the declared quantity has been fully placed on the market or exported. After that a new statement is needed for additional quantities. The quantity is therefore the real control mechanism, not the date.

Third, there is an upper limit on the period. Because operators have to review their due diligence system once a year under Article 12(2), a statement should not cover shipments over a period longer than one year from submission. A longer period would also make it harder to show that the declared products and the products actually placed on the market match.

Fourth, a statement should in principle cover commodities that have already been produced, that is grown, harvested, obtained or raised. The finished product need not yet have been made. The Commission illustrates this with wooden furniture: the furniture does not have to exist yet, but the trees should have been felled by the time the statement is submitted.

Fifth, the declared quantities must correspond to those that were actually subject to due diligence and are intended for the EU market or for export. That includes the rule that a product must not be the subject of several statements submitted by the same person. Anyone who does not yet know at submission which part will be sold and which exported can declare everything with an "export" statement and document the split in their own records.

In practice this means a yearly statement covering a realistically estimated quantity per supplier and product is permissible, and for many importers considerably more efficient than a statement per container.

What happens after you submit

The process in the information system is governed by the Implementing Regulation, and several parts of it are surprising.

A risk profile you cannot see. After submission, the system automatically creates an electronic risk profile and assigns the statement a risk status. That status is expressly not communicated to the user; it is visible only to the actors of the information system, that is the authorities. You therefore do not learn how the system rates your statement.

Reference number and verification number. Immediately after the risk profiling is complete, the system assigns the statement a reference number and, at the same time, an associated verification number. The verification number is a security code that provides additional protection for the data contained in the statement. Who has to pass it to whom, and where the obligation ends, is covered in EUDR reference number.

The rejection window. Competent authorities may reject a statement where the system identifies a high risk of non-compliance. The decisive part is the closing sentence of the provision: rejection is no longer possible once the reference number of that statement is available to the user. The window for a rejection therefore lies between submission and the number being provided. A rejected product is, from the moment of rejection, treated as a product for which no statement exists, with all the consequences of Article 3, point (c).

From that follows a planning rule: do not submit statements on the day of customs clearance. Between submission and the number there is a period you do not control.

Status and archiving. In the system the statement passes through several statuses. Six months after it has been given the status "available" it automatically switches to "archived", irrespective of whether the reference number was used in a customs declaration. According to the user guide this is a purely technical step with no effect on usability; the statement remains findable through the advanced search. Anyone who can no longer find something in the system has usually just set the wrong filter.

Later scrutiny remains possible. Authorities may review statements at any stage after submission and assign a new risk status, which takes precedence over the automatically assigned one. A reference number does not end the possibility of scrutiny.

Amending, withdrawing, copying

A statement is not a final act, but its changeability has limits.

Within 72 hours after the reference number has been made available, you can amend the content or withdraw the statement if it is no longer needed (Article 5(1) of the Implementing Regulation). The user guide describes two buttons for this, "amend" and "withdraw".

Even within that period the statement is locked once the reference number has been given to customs, the product has been placed on the market or exported, or you have been notified of a check, in that case for the duration of the check (paragraph 3 of the same provision). Under paragraph 2, a due diligence statement may also no longer be amended or withdrawn after it has been used as a reference in an aggregated statement submitted by the same user. A simplified declaration may then no longer be withdrawn (Article 4a(7) of the Implementing Regulation). Aggregating therefore costs you the ability to change the individual statements involved.

A practically useful function is "copy as new". It duplicates an existing statement with the status "new", which saves a good deal of typing on recurring supply relationships.

One warning from the user guide belongs here: where a statement has been approved or refused by the authority, the authority may in some circumstances revise its decision. Great care is needed, because the statement was already available for customs clearance and may already be in use.

The aggregated statement

This option has existed only since Implementing Regulation (EU) 2026/1565 and has gone largely unnoticed in the coverage. Article 8a allows individual due diligence statements or simplified declarations to be aggregated by submitting a new statement that refers, via the reference numbers or declaration identifiers, to statements submitted earlier.

The condition is that the individual statements were submitted by the same user or for the same operator or micro or small primary operator, where applicable through an authorised representative. The system marks the statements included with a specific status, and for the purposes of the Regulation the aggregated statement takes their place. It therefore covers the placing on the market or export of all products contained in the statements it refers to.

According to recital 7 of Implementing Regulation (EU) 2026/1565, aggregation is meant to address technical limits on file size and to avoid disruption of customs procedures. Anyone with so many geolocations, for example, that a single statement would be too large spreads them across several statements and then aggregates those. After aggregation, the reference number of the aggregated statement is what goes to the first downstream actor and to customs, not those of the individual statements (Article 8a(3)). The price is losing the ability to amend the individual statements.

The simplified declaration for micro or small primary operators

Micro or small primary operators, that is natural persons or micro and small enterprises producing in a low-risk country, do not submit a full due diligence statement but a simplified declaration under Annex III. They receive a declaration identifier instead of a reference number, likewise with a verification number.

Two features matter in practice. First, the Member State makes the information available in the information system where all of it already exists in a system or database established under Union or national law; in that case the operator does not have to submit a simplified declaration of its own (Article 4a(4)). The system then assigns each micro or small primary operator a declaration identifier for that information, which the Member State communicates to them. For forest owners and farmers with well-kept plot data this is the lowest-effort route.

Second, the declaration identifier is retained when the declaration is updated. An update does, however, trigger new risk profiling of the entire updated declaration. A simplified declaration can be withdrawn as long as it has not already been used as a reference in an aggregated statement.

What non-SME downstream actors do instead of a statement

The referring statement no longer exists. Under the original text, operators and traders that are not SMEs would have had to submit their own statement even for inputs already declared, in which Article 4(9) allowed them to refer to the upstream statements. Regulation (EU) 2025/2650 deleted Article 4(8) to (10). Since then, downstream operators and traders submit no due diligence statement, regardless of their size, and the information system offers no technical means of doing so (Commission FAQ 3.10.1).

The obligations of non-SME downstream actors are set out in Article 5. Before first placing on the market, making available or exporting, they register in the information system (paragraph 2). Like all downstream actors, they collect the name, postal address and email address of their suppliers and of their business customers and, only where the supplier is an operator, the reference numbers of the due diligence statements or the declaration identifiers (paragraph 3). Without that information they may not place the product on the market, make it available or export it (paragraph 1). They keep it for at least five years and provide it to the competent authority on request (paragraph 4).

They are not required to exercise due diligence themselves or to ascertain that it was exercised upstream; that is how the Commission guidelines sum it up. Nor do they have to systematically check the validity of the reference numbers they receive (FAQ 3.4).

Besides registration, they have a duty to verify that downstream SMEs do not have. If, before placing on the market, making available or exporting, non-SME downstream operators and non-SME traders obtain information that a product does not comply, they immediately inform the competent authority. In the case of substantiated concerns, they verify that due diligence was exercised and that no or only a negligible risk was found, and they may place the product on the market, make it available or export it only if the verification shows no or only a negligible risk of non-compliance (Article 5(6)). To do so, they can view the content of the upstream statement in the information system with the reference number and the verification number; they may request the verification number from their direct supplier (FAQ 3.6.1), and they see the geolocation only if the operator has released it (FAQ 3.6). Responsibility for compliance with Article 3 stays with the operator that submitted the statement (Article 4(3)).

Who submits no statement at all

Three groups submit no statement, and that is not a grey area.

Traders, regardless of size. Under Article 5(3) they collect the identity of their suppliers and business customers and, only where the supplier is an operator, the reference numbers or declaration identifiers, keep everything for five years and inform the competent authority and the customers they supplied when they receive new information on possible non-compliance of products already supplied (paragraphs 4 and 5). Traders that are not SMEs also register in the information system and verify in the case of substantiated concerns.

Downstream operators, regardless of size. The same Article 5 obligations apply to them, for non-SMEs with registration and the duty to verify. On re-import they state the reference number of the upstream statement in the customs declaration with code C725 as an SME or C720 as a non-SME; on export they use, instead of a number, the exemption code Y188 as an SME or Y196 as a non-SME. For components not previously subject to due diligence, by contrast, they are operators, exercise due diligence in full and submit a statement.

Service providers without ownership rights. Freight forwarders, carriers and customs representatives are neither operators nor traders.

Which role you hold for which product is settled in Trader or operator? The four EUDR roles, the SME thresholds and the two deadlines.

The ten most common mistakes

1. Looking for a template. There is none. Annex II is the template, and entry happens in the system.
2. Treating the statement as the first step. It comes after information gathering, risk assessment and risk mitigation, not before.
3. Declaring too many plots. Every plot declared becomes part of your responsibility, even if it supplied nothing.
4. Declaring per shipment when you do not have to. One statement can cover several shipments, bounded by quantity and one year.
5. Covering the same goods in several statements. A product must not be the subject of several statements by the same person.
6. Leaving out the scientific name for wood. It is mandatory under Annex II, and since July 2026 the Implementing Regulation expressly requires the names of all species, so several for mixed assortments.
7. Submitting on the day of clearance. Between submission and reference number lies the rejection window.
8. Mistaking archiving for a fault. After six months that is normal and purely technical.
9. Aggregating and then wanting to amend. Once used as a reference in an aggregated statement, the individual statement is locked.
10. Wanting to submit a statement as a downstream actor. Since Regulation (EU) 2025/2650, downstream operators and traders submit none, not even at a customer's request; the information system does not allow it.

How to prepare a statement

1. 1. Settle the role and the duty. Full statement, simplified declaration or, as a downstream actor, only the obligations under Article 5.
2. 2. Fix the product and the code. HS code, trade name, and for wood the full scientific names of all species.
3. 3. Determine the quantity. In kilograms of net mass for import and export, plus the supplementary unit where applicable. Estimate realistically if the statement is to cover several shipments, and track how much has been used.
4. 4. Compile the plots. Exactly the plots the declared quantity comes from, with country of production, subnational part where relevant, and the production period for your records.
5. 5. File the evidence. Supplier and customer data, legality evidence, the risk assessment and, where needed, the mitigation. Five years.
6. 6. Name the signatory. Name and function, in the format from Annex II.
7. 7. Submit with lead time. Not on the day of customs clearance.
8. 8. Pass on and file the numbers. Reference number to the first downstream actor, verification number on request, and both carried on the shipment rather than in a list.

Whether a template is enough for your number of statements or software pays off depends on your suppliers, plots and shipments. Our comparison of 14 EUDR software providers shows which solutions submit statements directly to TRACES.

How Polygon One helps

Polygon One generates the due diligence statement from the data you keep anyway: articles with HS code, supplier, quantity, country of production and plots with geodata. The statement is therefore not a form somebody retypes but the result of the process before it, and the platform submits it through its connection to the EU information system. The reference and verification numbers come back and stay attached to the shipment.

The data before that is collected through the supplier portal: suppliers receive a secure link without needing an account, provide geodata and documents, and can pass the link along the chain. Plots can be drawn on a map where no coordinates exist, or imported as GeoJSON or a table, with validation before the import. Uploaded documents are classified and given a confidence score; anything not clear-cut lands visibly in a manual review queue.

What the platform does not do: exercise due diligence on your behalf, decide which plots belong in the statement, or sign the assurance. That stays with you, and the Regulation intends it to.

If you would like to see a statement being generated from your data, book a demo or read on at the EUDR module product page.

Download the preparation sheet

Since there is no template for the statement itself, the most useful thing is a sheet for collecting the data before you open the system. It contains all Annex II items, the additional Article 9 fields, a plot sheet with production period, a completeness check that shows what is still missing, and a log for signatory, date and reference number.

• Download: EUDR due diligence statement preparation sheet (XLSX)
• Download: worked example of a due diligence statement under Annex II, fictitious coffee import (PDF)

Frequently asked questions

Is there an official template for the due diligence statement?

No. The statement is entered and submitted in the EU information system. Annex II to the Regulation sets out exhaustively which items it must contain, including the wording of the declaration and the format of the signature.

What has to be in the due diligence statement?

Operator and EORI number, HS code with description and quantity, country of production and geolocation of all plots, the prescribed declaration wording and the signature in the prescribed format.

Do I have to submit a separate statement for every shipment?

No. One statement can cover several shipments until the declared quantity is used up, for at most one year from submission.

What happens after I submit?

The system creates a risk profile you cannot see, then assigns a reference number and a verification number. Until the reference number is available, the authority may reject the statement.

Can I amend or withdraw a statement?

Yes, within 72 hours after the reference number has been made available. Even within that period it is locked once the reference number has been given to customs or the product has been placed on the market or exported, during an announced check, and once it has been used as a reference in an aggregated statement by the same user.

What is an aggregated due diligence statement?

A statement, possible since July 2026, that refers via reference numbers to your own earlier statements and takes their place for the purposes of the Regulation.

Why does my statement disappear after six months?

It automatically moves to the status "archived". That is purely technical; the statement remains findable and usable through the advanced search.

What applies to micro or small primary operators?

They submit a one-time simplified declaration under Annex III and receive a declaration identifier. Where all the information is already held in an existing database, the Member State makes it available in the information system and no declaration of their own is needed.

Do I have to submit a statement as a trader or downstream operator?

No, regardless of your size. You collect the identity of your suppliers and customers and, where the supplier is an operator, the reference numbers, and keep them for five years. If you are not an SME, you also register in the information system.

What happens if I declare too many plots?

You assume responsibility for every plot declared. If one of them fails to meet the requirements, the entirety is non-compliant.

Is there a worked example of a due diligence statement?

Yes, above in the article as a table and as a PDF download. It shows the five Annex II items for an invented coffee import; the coordinates are placeholders. There is no official template; the fields are in the Information System.

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Articles 4, 4a, 5, 9 to 13, 26 and 33 and Annexes II and III. Implementing Regulation (EU) 2024/3084 as amended by Implementing Regulation (EU) 2026/1565, in particular Articles 4, 4a, 5, 6, 7, 8 and 8a. Commission FAQ on EUDR implementation, 5th version (published 21 August 2026). Commission guidelines C/2026/3896. Commission TARIC data on Regulation (EU) 2023/1115, revision 1 of 23 September 2026. EUDR user guide for operators, version 1.0, and EUDR Information System user guide, version 3.0 of 16 September 2026. This article describes the legal position as at September 2026 and is not legal advice.

Photos: David Clode, Vardan Papikyan, both via Unsplash.