Filing a due diligence statement in TRACES: a walkthrough for timber importers

Timber importers will file due diligence statements electronically under Regulation (EU) 2023/1115 before products enter the EU market. For most operations teams, the hard part is not pressing submit in TRACES. It is making sure the supplier data, geolocation files, product scope, and internal checks are lined up before customs clearance starts moving.

What the statement actually is

A due diligence statement, often shortened to DDS, is the formal declaration that the operator has carried out due diligence under the EUDR for the products being placed on the EU market or exported. For timber importers, that means you have collected information about the product and supply chain, assessed the risk that the timber is linked to deforestation or illegality, and applied mitigation measures where needed.

The statement is submitted electronically through the EUDR module in the EU TRACES system. Once submitted, the system generates a reference number tied to that declaration. Customs authorities use that reference during import procedures.

The DDS is not a substitute for the underlying evidence. Authorities can still ask for supplier records, harvest information, geolocation data, risk assessments, transport records, invoices, and mitigation documentation. Those records must be retained for five years.

Who files it, and when in the shipment timeline

The operator placing the timber products on the EU market is generally responsible for filing the due diligence statement. In practice, that is usually the EU importer of record. If you are buying timber products from outside the EU and importing them yourself, the filing responsibility will normally sit with your organisation.

The statement needs to be submitted before the products are placed on the market. Operationally, most importers aim to file before customs clearance reaches the point where the declaration reference is needed. Leaving it until the shipment is already at the port creates avoidable pressure, especially when geolocation data or supplier evidence still needs review.

The compliance date for timber under Regulation (EU) 2023/1115 is 30 December 2026. There is no SME grace period for timber products. Smaller operators importing timber need to prepare on the same timeline as larger businesses.

Setting up access before you need it

TRACES access is an administrative task that many companies postpone until the first shipment is approaching. That usually causes delays. Internal roles, user permissions, company identifiers, and supplier coordination take time to sort out.

At minimum, importers should identify:

Who will prepare and review due diligence data.
Who will submit statements in TRACES.
Who will maintain supplier evidence and geolocation records.
Who will coordinate with customs brokers and freight teams.

It also helps to test your data structure early. A large share of filing problems comes from inconsistent supplier names, missing species information, mismatched product descriptions, or geolocation files in unusable formats.

If your suppliers have never collected harvest plot coordinates before, start those conversations well ahead of the deadline. Geolocation requirements are one of the areas where supply chains often discover gaps late in the process.

What you enter when you file

The exact fields in TRACES may evolve over time, but the core information required under the EUDR is already clear. The operator submitting the DDS is expected to provide information identifying the products, the supply chain, and the origin of the timber.

Typical information includes:

Product descriptions and relevant commodity details.
Quantity information.
Country of production.
Supplier and operator identification details.
Scientific and common names for timber species where applicable.
Geolocation data for harvest plots.
References to supporting due diligence documentation.

Geolocation requirements deserve close attention. For harvest plots larger than 4 hectares, the EUDR requires polygon coordinates describing the plot boundaries. For plots at or below 4 hectares, a single point coordinate is allowed.

Many importers are using the JRC Global Forest Cover map as one of their screening references during risk assessment. It is a free tool and can help identify obvious inconsistencies between declared harvest locations and forest cover data. It does not replace supplier verification or legal review, but it is useful as an operational screening layer.

Before filing, operations teams should also confirm that shipment documents, invoices, and product classifications match the DDS data. Small inconsistencies are often what trigger internal confusion later when customs brokers or auditors compare records.

The reference number and where it goes

Once the due diligence statement is submitted in TRACES, the system generates a reference number. That number is important because it links the import declaration to the DDS.

The reference number is included in the customs declaration. Importers should make sure customs brokers receive the correct number and understand which shipment lines it applies to.

In larger operations, one practical issue is version control. Teams sometimes circulate spreadsheets with multiple draft reference numbers or old shipment allocations. A simple internal tracking process helps avoid attaching the wrong DDS reference to the wrong customs entry.

Mixed shipments and multiple suppliers

Many timber importers do not receive neat consignments built from one supplier, one species and one forest source. Containers may contain products from several mills, several forest sources, or multiple countries.

That increases the data management burden because the DDS still needs to trace products back to the relevant production plots and suppliers. If one shipment contains products tied to different harvest areas, the geolocation records and supporting evidence need to stay linked to the correct product lines.

Operations teams usually handle this by building shipment level data files that map:

Product line.
Supplier.
Species.
Country of harvest.
Harvest plot coordinates.
Supporting documentation references.

Without that mapping structure, mixed containers become difficult to audit later. Problems also appear when suppliers consolidate material from different origins without preserving source level records.

When something changes after filing

Changes after filing are common in international trade. Quantities shift, containers are rolled to later vessels, invoices are corrected, or suppliers replace material before loading.

The right response depends on what changed and whether the original DDS information is still accurate for the products being imported. If the source material, supplier information, harvest location data, or product scope changes materially, the filing may need updating or replacing before the products are placed on the market.

Operations teams should avoid treating the DDS as a static customs form. It is part of the due diligence record. If the commercial reality of the shipment changes, the compliance file may also need adjustment.

Keeping a clear audit trail matters here. Save prior versions of supplier declarations, coordinate files, and shipment records so there is a record of what changed and when.

What goes wrong most often

The most common problems are usually operational rather than technical. Importers often discover that supplier information was never standardised across purchase orders, invoices, forestry records, and customs paperwork.

Frequent issues include:

Missing geolocation data.
Coordinates that do not match harvest areas.
Species names entered inconsistently.
Supplier documents that cannot be linked to shipment lines.
Late requests to suppliers for forestry evidence.
Customs brokers receiving the wrong DDS reference number.

Another recurring issue is underestimating the time needed for supplier onboarding. Some suppliers already collect GIS data and legality documentation in structured formats. Others still rely on scanned paper records and informal spreadsheets.

The EUDR penalty framework is also significant. Penalties can include fines of at least 4% of EU turnover, confiscation of products and revenues, and exclusion from public procurement. That is one reason many importers are treating data quality and auditability as core operational issues rather than side compliance tasks.

Records after filing

Submitting the DDS is only part of the requirement. Importers also need to maintain the underlying records demonstrating that due diligence was carried out.

Evidence must be kept for five years. In practice, that usually means maintaining a structured archive containing supplier documents, geolocation files, risk assessments, mitigation actions, shipment records, and copies of submitted DDS references.

Searchability matters. If authorities request evidence linked to a shipment from several years earlier, teams need to retrieve the relevant records quickly. Shared drives with inconsistent folder naming tend to become difficult once shipment volumes increase.

Many importers are therefore building centralised compliance records tied directly to purchase orders or shipment identifiers. The goal is straightforward: if someone asks where a product came from, which plot supplied it, and which DDS covered it, the answer can be assembled without rebuilding the file from scratch.

goEUDR helps timber importers prepare supply chains, supplier data, geolocation records, and due diligence workflows ahead of the 30 December 2026 EUDR deadline. The service is designed for operations teams that need practical control over shipment level compliance data and TRACES filing preparation.

This content is general information and does not constitute legal advice.