Under Article 8 of the EU Deforestation Regulation (EUDR, Regulation 2023/1115), the due-diligence system is a three-step process — gather information, assess risk, then mitigate risk — that an operator must finish before filing a Due Diligence Statement (DDS). The DDS is the signed declaration that proves the system ran and lets goods enter or leave the EU market.
This is general guidance, not legal advice; confirm current EUDR requirements with the European Commission at environment.ec.europa.eu, your EU importer, and a licensed customs or legal adviser before acting.
EUDR entered into force on 29 June 2023 and covers seven commodities plus their derivatives: cattle, cocoa, coffee, oil palm, rubber, soya, and wood. For most Indonesian exporters the four practical categories are coffee, cocoa, rubber, and wood or furniture. Three conditions must all be met before a shipment moves: the goods must be deforestation-free (not grown on land cleared after the 31 December 2020 cut-off), legal under Indonesian law, and covered by a filed DDS. The due-diligence system is how you build the case for the first two conditions; the DDS is how you declare it.
What does the Article 8 due-diligence system actually require?
Article 8 bundles three obligations that run in order. You cannot skip to the statement — the system produces the evidence the statement rests on. Indonesian exporters handling coffee, cocoa, rubber, and wood often lean on managed EUDR due diligence services to run these steps consistently across many smallholder plots, but the legal duty stays with the operator placing goods on the EU market.
The three steps map to Articles 9, 10, and 11 of the regulation:
| Step | Regulation article | What you do | Output |
|---|---|---|---|
| 1. Gather information | Article 9 | Collect commodity and product description, quantity, country of production, plot geolocation, supplier details, and proof goods are deforestation-free and legal | A complete data file per plot |
| 2. Assess risk | Article 10 | Weigh country and region risk, deforestation signals against the December 2020 baseline, supply-chain complexity, and evidence reliability | A documented risk conclusion |
| 3. Mitigate risk | Article 11 | Where risk is not negligible, add data, field surveys, satellite checks, audits, or drop unverifiable plots | Residual risk reduced to negligible |
Only when residual risk is negligible can an operator file the DDS and move the goods. If risk stays above negligible after mitigation, the shipment should not proceed.
How do the three steps of due diligence work?
Step one, information gathering under Article 9, is the heaviest lift. You collect the commodity and product description, quantity, country of production, and the plot-level geolocation of every plot the material came from, plus supplier and buyer details and documents showing the goods are legal and deforestation-free. The DDS sets a clear geolocation rule by plot size:
| Plot size | Geolocation required |
|---|---|
| Under 4 hectares | GPS point coordinates |
| 4 hectares or larger | Polygon boundary coordinates |
Step two, risk assessment under Article 10, weighs that information. You examine the country and region risk classification, presence of forests, deforestation signals against the December 2020 baseline, complexity of the supply chain, and the reliability of your evidence. The result is a documented conclusion: negligible risk, or not.
Step three, risk mitigation under Article 11, applies when risk is not negligible. Measures can include collecting more data, commissioning independent field surveys, running satellite or remote-sensing checks, auditing farmers, or dropping a plot that cannot be verified. You repeat until the risk is negligible.
Where does the Due Diligence Statement fit in?
The DDS sits at the end. It is a formal declaration, submitted through the EU Information System, confirming that due diligence was carried out and that the goods meet all three conditions. Each DDS carries a unique reference number. That number must be quoted on the EU import or export customs declaration and shared with the logistics operator before customs clearance in the EU — without it, goods can be blocked at the border.
A single DDS can in practice cover repeat shipments of the same verified supply base, provided the underlying data stays current. That is why the system and the statement are not one-off paperwork: they are a living record you refresh as farms, plots, and suppliers change.
Penalties for non-compliance can reach up to 4% of an operator’s EU-derived turnover, on top of rejected shipments and goods held at EU customs — a strong reason to treat the due-diligence file as seriously as the export contract itself.
What evidence feeds the file, and do Indonesian schemes help?
EU buyers typically ask for a supply-chain map showing partner farms, collection points, and processing sites. The European Commission’s practical guidance notes operators do not have to publish exact coordinates publicly; a regional map with sub-district (kecamatan) names and an area scale reassures compliance teams while protecting farmer privacy.
Supporting evidence that strengthens the system includes:
- Legal certificates and export permits
- Land-tenure and land-use-rights documents
- Farmer contracts and purchase records
- Field photos and independent survey reports
- Audit results and satellite or remote-sensing verification against the December 2020 baseline
Indonesian legality schemes help but do not replace the system. SVLK supports timber and furniture legality, ISPO supports palm, and voluntary schemes such as FSC and Rainforest Alliance can feed the due-diligence process. None alone guarantees EUDR compliance, because deforestation-free proof against the 2020 baseline plus plot geolocation are still required.
On timing: as announced, large and medium operators must comply by 30 December 2026 and micro and small operators by 30 June 2027. Enforcement dates have shifted before — several Indonesian sources still cite 30 December 2025 and a 30 June 2026 transition for smaller operators — so treat every date as of 2026, subject to change, and confirm current deadlines with the European Commission and your EU importer before you plan around them.
Frequently Asked Questions
Is the due-diligence system the same thing as the Due Diligence Statement?
No. The due-diligence system is the three-step process under Article 8 — gathering information, assessing risk, and mitigating risk. The Due Diligence Statement is the final declaration you file once that process shows negligible risk. The system produces the evidence; the DDS declares the result and carries the reference number EU customs needs.
Can one Due Diligence Statement cover several shipments?
In practice a single DDS can cover repeat shipments from the same verified supply base, provided the underlying data stays current and the plots and suppliers do not change. If your sourcing shifts, or new plots enter the chain, you re-run the relevant due-diligence steps and file an updated statement. Confirm current rules with the European Commission and your importer.
What happens if risk is not negligible after assessment?
You move to Article 11 risk mitigation before filing anything. That can mean collecting more plot data, commissioning independent surveys or satellite checks, auditing farmers, or excluding a plot you cannot verify. You repeat until residual risk is negligible. Only then can you file a DDS; if risk stays above negligible, the shipment should not proceed.