When must the due diligence statement number under the European Union (EU) Deforestation Regulation (EUDR) exist: before shipping or before the customs declaration?

It must exist before the customs declaration is lodged. The Commission says due diligence must be done, the statement submitted and the reference number obtained before the EU customs declaration. The customs declarant must put the reference number or declaration identifier on that declaration for each relevant product.

What the Commission says

• For imports, the due diligence statement (DDS) reference number, or the declaration identifier for simplified declarations, must be made available to customs authorities.
• The person lodging the customs declaration, the customs declarant, must include that number on the declaration lodged for that product.
• So due diligence must be carried out, the DDS submitted, and the number obtained "before the lodging of the customs declaration".
• Where one DDS covers several shipments, the same number can be referred to in several customs declarations. One customs declaration can also carry several DDS numbers.

Our reading for your shipping plan

1. Agree with your buyer who files the DDS and who lodges the customs declaration.
2. Give the buyer the full plot file and legality records before the goods leave the port, not after they land. The operator cannot do due diligence without them.
3. Ask for the DDS reference number in writing before the customs declaration is lodged, and keep it with the shipping papers.
4. Treat a missing number as a hold on the shipment, not a paperwork gap to fix later.

If you are the operator

The Commission says the operator may place the product on the market only once the DDS is accepted in the Information System. If you are the party importing, the same order applies to you. See the page on whether an Indian exporter counts as an operator.

A shipment timeline, example

• Day 1: lot packed, plot file and land records sent to the buyer
• Day 3: buyer submits the DDS to the Information System and receives a reference number
• Day 4: number added to the customs declaration at the EU border by the declarant
• If Day 3 slips, Day 4 slips with it: the number comes first

Days are an example only.

What Senseible does here

Senseible reads the HS code on each purchase invoice and keeps every invoice dated, so you can show your buyer what came in, from whom and when. Plot coordinates come from your growers and your buyer files the statement. We do not file statements or certify deforestation-free status.

• What an Indian supplier gives the EU importer for the statement
• Do I count as an EUDR operator if I import?
• Does EUDR apply to my Indian exports?
• EUDR readiness: what applies to your goods

Sources: European Commission Green Forum, Understand due diligence under the EU Deforestation Regulation, European Commission Green Forum, EUDR roles and responsibilities

Last reviewed 2026-11-05. Timing rules are from the Commission due diligence page. Customs practice for your port and incoterm is for your customs agent to confirm.