What Goes in an EUDR Due Diligence Statement, and What Stays Behind It?
The statement is what you submit before placing or exporting. The Article 9 information is what you collect and keep. Two five-year clocks, two events.
Jump around this page
In 60 seconds
The statement is the short thing you submit and the evidence is the large thing you keep. They are governed by different articles and they contain different material. Submitting the statement is the moment you assume responsibility for the product's compliance, which makes it the assertion that the proof exists rather than the proof.
- Article 4(2) of Regulation (EU) 2023/1115: submit the statement through the Article 33 information system before placing on the market or exporting. Annex II sets its content.
- Article 9(1) requires a longer set of information in eight categories, kept for five years from the placing on the market or the export.
- Statements are kept for five years from submission under Article 4(3). Two five-year clocks, started by two different events.
- Under Article 4(3), submitting the statement means assuming responsibility for the product's compliance with Article 3.
- Article 9(1) covers plot geolocation with the date or time range of production and the names and contact details of both suppliers and customers.
Article 4(2) of Regulation (EU) 2023/1115 requires an operator to submit a due diligence statement to the competent authorities, through the information system referred to in Article 33, before placing a relevant product on the market or exporting it. The statement contains the information set out in Annex II.
Article 9(1) requires the operator to collect a different and much longer set of information, and to keep it for five years.
Most EUDR programmes that go wrong go wrong here. A team builds the submission, files it and treats the filing as the compliance. Article 4(3) says the opposite: by making the statement available to competent authorities, the operator assumes responsibility for the product's compliance with Article 3.
The two lists, side by side
| What it is | Where it lives | How long | |
|---|---|---|---|
| The statement | The declaration submitted before placing or exporting, containing the Annex II information | Submitted through the Article 33 information system | A record of statements kept five years from submission, Article 4(3) |
| The evidence | The Article 9(1) information the operator collects to reach the statement | Wherever the operator keeps it | Five years from the placing on the market or the export, Article 9(1) |
Two five-year clocks, started by two different events. A programme that runs one retention rule for both will keep the wrong thing for the wrong period on at least one of them.
What Article 9(1) requires you to collect
Eight categories, lettered in the Regulation:
- (a) the product description, including trade name, type and species name;
- (b) the quantity;
- (c) the country of production, and parts of it;
- (d) the geolocation of all plots of land where the relevant commodities were
produced, and the date or time range of production;
- (e) the name and contact details of suppliers;
- (f) the name and contact details of customers;
- (g) the information demonstrating that the commodities and products are
deforestation-free;
- (h) the information demonstrating that production was in accordance with the
relevant legislation of the country of production.
Point (d) is the one that drives the cost, and the Regulation is specific about the form it has to take. That is a question of its own, on what precision EUDR asks a plot geolocation for.
On points (e) and (f): a due diligence programme that maps upstream and stops has collected half of what the article asks for.
What this page does not list
It does not list Annex II item by item.
Annex II is the Regulation's own specification of what the statement itself must contain. It's short, and a summary here would add a second, less reliable copy of a list that already exists in one authoritative place. Read Annex II in the consolidated Regulation.
What Annex II cannot tell you on its own: the statement's contents and the Article 9 information are not the same set, and that having the second is what entitles you to submit the first.
The information system
Article 33 establishes an information system containing the due diligence statements submitted under Article 4(2).
The Regulation does not give it a trading name. It refers to it throughout as the information system referred to in Article 33. Bear that in mind when a supplier proposal names a system and asserts it is the one the law means.
What submitting one commits you to
Article 4(3):
- You assume responsibility for the product's compliance with Article 3.
- You keep a record of the statements for five years from the date the statement is submitted.
Article 3 is the substantive prohibition. So the statement is not a filing obligation that sits alongside a compliance obligation. It is the moment the compliance obligation attaches to you by name.
What this page will not do
It will not tell you whether your product is in scope. Scope runs through Annex I and the Combined Nomenclature, and it is owned by the EUDR page.
It will not give you a template. A template that does not come from the Regulation's own Annex II and the current information system is a guess with formatting.
It will not treat the statement as evidence. Nothing in Article 4 describes it that way, and the parent page says the same thing for the same reason.
What would change this answer
Recheck if:
- Annex II is amended;
- Article 4 or Article 9 is amended, particularly the retention periods;
- Article 33 is amended, or the Commission publishes binding technical specifications for
the information system that change what a submission contains.
Last verified 12 September 2026.
Keep exploring
The questions this page usually raises next.
- CompareNext questionEUDR: Dates, Geolocation Data and What Product Teams Actually NeedEUDR is already in force, with the main application point for the first cohort on 30 December 2026.
- CompareNext questionHow Precise Does an EUDR Plot Geolocation Have to Be?At least six decimal digits of latitude and longitude, a point up to four hectares and a polygon above it.
- CompareNext questionDoes Traceability Prove Supply-Chain Due Diligence?Understand why supply-chain traceability can support due diligence without replacing risk assessment, mitigation and other…
- CompareNext questionAre Furniture, Flooring, Panels and Wooden Packaging in EUDR Scope?Many wood products remain within EUDR Annex I, but scope must be decided from the current CN entry and its wording, not from the…
Sources and legal basis
Does this reach your products?
Give ActivateDigital one product and it works out which obligations apply from the product's own character, and says which it cannot decide.