One of the most practical questions surrounding the EUDR is how due diligence statements (DDS) will be managed through the EU information system. For many companies, terms such as TRACES, DDS, production server, test server or statement reference are already part of compliance conversations.
But one point should be clear from the outset: TRACES does not replace a company’s due diligence system. It is the tool through which certain statements are submitted, but the real preparation happens beforehand.
Before reaching the statement stage, the company must have identified its affected products, understood its role in the chain, collected origin information, assessed risks, documented evidence and defined how traceability will be maintained.
What does TRACES mean within the EUDR?
The EUDR information system is integrated into the TRACES platform. It allows operators, traders subject to obligations and authorized representatives to create and submit due diligence statements and simplified statements to the competent authorities.
Its function is to record that the company has exercised due diligence in the relevant products before placing them on the market, making them available where applicable or exporting them. However, the system is not designed to perform due diligence by itself. The company must arrive at TRACES with the analysis completed and information prepared.
What is a DDS?
A DDS, or due diligence statement, is the declaration through which a company states that it has exercised the due diligence required by the EUDR on a relevant product.
Through that statement, the company declares that it has found no risk of noncompliance or that the risk identified is negligible after applying the necessary measures. For this reason, a DDS should not be understood as a simple form. It is the result of a prior process of information collection, risk assessment, traceability and evidence retention.
Why is the DDS not the starting point?
One of the most frequent mistakes is to start by asking, “How do I fill in the statement?” before knowing whether the company is prepared to support it.
The right question comes earlier: do we have the information needed to submit a DDS safely? This means checking whether the product is affected, what role the company plays, which supplier is involved, the country of production, the available geolocation data, what legal documentation is retained and how the risk has been assessed.
What information should be ready before using TRACES?
Before submitting a DDS, the company should have sufficient information about the product, its origin, suppliers and specific operation.
It should also provide evidence on geolocation, compliance with the applicable legislation in the country of production, risk assessment and mitigation measures where necessary. Additionally, this information must be organized so it can be linked to the corresponding product or lot.
What is the role of geolocation?
Geolocation is one of the EUDR’s core elements because it connects the product with the place where the raw material was produced.
In simple chains, this information may seem easier to collect. However, for chains with several suppliers, intermediaries, origins or lots, data management can be much more complex. That is why geolocation must be integrated into a traceability system.
What is a test server and legally valid server?
The EUDR information system has different environments. The test server allows users to become familiar with the system, review functionalities and prepare teams. The production server is the environment where statements with legal value are submitted when the regulation’s obligations apply.
This distinction is important. Testing the system is not the same as complying. It helps to anticipate needs, understand how information is structured and detect possible difficulties, but the strength of compliance will depend on prior due diligence work.
Who must submit the DDS?
Submission of the statement will depend on the company’s role in the chain. Operators, certain traders and authorized representatives may intervene in the system.
However, delegating an administrative task does not remove the company’s responsibility for the information and product compliance. It is therefore advisable to define internally who collects data, who validates the information, who assesses the risk, who submits the statement and who retains the evidence.
What happens with references to previous statements?
In operations with downstream actors in the chain, references to previous statements may be relevant. A company may need to retain and use due diligence references provided by suppliers or previous actors.
But that reference must be correctly linked to the company’s own operation. In other words, it must be clear which product, lot, supplier or commercial flow it refers to.
What is the difference between submitting a DDS and having a due diligence system?
Submitting a DDS is a specific action within the EUDR process. Having a due diligence system is much broader.
A due diligence system involves collecting information, assessing risks, applying mitigation measures where appropriate, retaining evidence, reviewing suppliers, updating procedures and ensuring that the company can demonstrate its reasoning in the event of a review. The DDS is the final declaration of that process.
What are the common mistakes when preparing TRACES and DDS?
One of the most common mistakes is expecting TRACES to resolve questions about scope, roles or obligations. The platform can be used to submit statements, but it does not replace the technical and operational analysis each company must carry out.
Another common mistake is preparing the statement without first reviewing supplier data, product codes, geolocation, legal documentation and traceability. It may also happen that different areas of the company work with information that is not aligned.
How do you prepare your company before using TRACES?
Preparation should start with a map of affected products and operations. Then, it is useful to identify the company’s role in each case and review what information currently exists.
Next, it is useful to identify gaps: incomplete origin data, suppliers without sufficient information, lack of geolocation, documentation not linked to lots or internal systems that do not allow references to be retained.
How do you move from the statement to solid preparation?
TRACES and DDS are key elements of EUDR compliance, but they should not be treated as an isolated formality. Real preparation consists of building a system capable of supporting the statement: reliable data, sufficient traceability, documented risk assessment and organized evidence.
In other words, the question is not only “How do I submit a DDS?” but “If I have to submit a DDS tomorrow, can I confidently demonstrate everything I am declaring?”
How can SGS help?
We can help organizations prepare before using TRACES and submitting due diligence statements by reviewing affected products, roles, available information, suppliers, traceability, documentation and due diligence system maturity.
Through EUDR gap analysis and specialized traceability and chain of custody services, we provide an independent technical perspective to identify gaps, prioritize actions and prepare compliance in an orderly way.
Because in EUDR, TRACES is the point where the statement is submitted. But confidence in a DDS is built earlier: in the data, processes and traceability the company has prepared.
For further information, please contact:
Jan Pierre Jarrin Peters
Product Manager EUDR
t: +31 (6) 10881016
About SGS
SGS is the world’s leading Testing, Inspection and Certification company. We operate a network of over 2,500 laboratories and business facilities across 115 countries, supported by a team of over 100,000 dedicated professionals. With more than 145 years of service excellence, we combine the precision and accuracy that define Swiss companies to help organizations achieve the highest standards of quality, compliance and sustainability.
Our brand promise – when you need to be sure – underscores our commitment to trust, integrity and reliability, enabling businesses to thrive with confidence. We proudly deliver our expert services through the SGS name and a portfolio of trusted specialized brands, including Applied Technical Services, Brightsight, Bluesign and Nutrasource.
SGS is publicly traded on the SIX Swiss Exchange under the ticker symbol SGSN (ISIN CH1256740924, Reuters SGSN.S, Bloomberg SGSN SW).
