An EUDR Due Diligence Statement for Indonesia must carry, under one unique reference number, the exact commodity and product, its net quantity, the supplier and country of production, plot-level geolocation for every farm, proof the goods are deforestation-free after the 31 December 2020 cut-off, evidence of Indonesian legality, and a documented risk assessment with any mitigation applied.
The Due Diligence Statement (DDS) is the single filing that lets your coffee, cocoa, rubber, or wood and furniture cross the EU border under the EU Deforestation Regulation, Regulation 2023/1115, which entered into force on 29 June 2023. Leave a field blank and the shipment can stall at customs. Here is what belongs inside, section by section.
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/legal adviser before acting.
What are the core fields every DDS must contain?
The regulation asks for a fixed set of data points. For an Indonesian operator or trader, they translate as follows:
| DDS field | What to enter for Indonesia |
|---|---|
| Operator / trader identity | Legal name, address, and EORI or registration of the party filing |
| Commodity and HS code | Coffee, cocoa, rubber, or wood; plus the customs code of the actual product |
| Product description | Green coffee beans, cocoa nibs, natural rubber (SIR grades), sawn timber, plywood, LVL, veneer, or furniture |
| Quantity | Net mass in kilograms (volume or unit count where relevant) |
| Country of production | Indonesia, with the specific plots that supplied the lot |
| Geolocation | GPS coordinates or polygons for every plot of land (see below) |
| Supplier / producer | Names and addresses of farms, collectors, and processors in the chain |
| Deforestation-free confirmation | Statement that production land was not deforested after 31 December 2020 |
| Legality confirmation | Statement that production complied with Indonesian law |
| Reference numbers | Any earlier DDS reference numbers you are relying on upstream |
Once filed, the DDS generates a unique reference number. That number must be quoted on the EU import or export customs declaration and shared with the logistics operator before the goods clear customs in the EU. No reference number, no clearance.
How does the geolocation requirement work for Indonesian plots?
Geolocation is the field most exporters underestimate, and it is where many Bali and wider Indonesian supply chains are still catching up. The rule scales with plot size:
- Plots under 4 hectares — a single GPS point coordinate (latitude and longitude) is accepted.
- Plots of 4 hectares and above — polygon boundaries that trace the full outline of the plot are required.
For a smallholder coffee grower or a village cocoa cooperative, one accurate point usually does the job. For a larger rubber estate or plantation block, you need the mapped polygon. If you are assembling this data for the first time, structured Due Diligence Statement preparation can turn a spreadsheet of farmer names into the plot registry, coordinates, and evidence pack the DDS actually needs.
EU buyers typically also ask for a supply-chain map showing partner farms, collection points, and processing sites. Helpfully, the European Commission’s practical guidance notes that operators do not have to publish exact coordinates publicly. A regional map labelled with sub-district (kecamatan) names and an area scale reassures a compliance team while protecting individual farmer privacy — the precise coordinates stay inside your due-diligence records.
What proves your goods are deforestation-free and legal?
Three conditions must ALL be met before goods can enter or leave the EU market: the goods must be deforestation-free, legal under Indonesian law, and covered by the filed DDS. Two of those conditions have to be evidenced inside the statement.
Deforestation-free means the commodity was not produced on land deforested after the 31 December 2020 cut-off date. In practice this is proven by satellite and remote-sensing checks of each plot against the December 2020 baseline, backed by land-use maps and dated imagery.
Legality means production followed Indonesian rules on land tenure, permits, labour, and taxes. Evidence here includes legal certificates, land-tenure and land-use-rights documents, and farmer contracts that show the producer had the right to farm the land.
What goes in the risk assessment and mitigation section?
A DDS is not just data — it has to show you thought about risk. The regulation requires a negligible-risk assessment for the supply base, plus mitigation measures wherever the risk of non-compliance is not negligible.
A workable structure looks like this:
- Describe the supply base — commodities, plots, volumes, and the country and regions involved.
- Assess the risk — deforestation history near the plots, complexity of the chain, reliability of documents, and any mixing with unverified material.
- Conclude the risk level — negligible, or not negligible.
- Apply mitigation — where risk is not negligible, add steps such as extra field checks, independent surveys, supplier audits, or additional imagery before you can file.
Do SVLK, ISPO, FSC, or Rainforest Alliance replace a DDS?
No — and this trips up many first-time filers. Indonesian and voluntary schemes support your case but none is an automatic pass:
| Scheme | What it helps with | What it does not do |
|---|---|---|
| SVLK | Timber and furniture legality | Prove deforestation-free status against the 2020 baseline |
| ISPO | Palm oil legality and standards | Replace plot geolocation |
| FSC / Rainforest Alliance | Voluntary sustainability data that can feed due diligence | Substitute for the DDS itself |
These certificates can feed the due-diligence system as supporting evidence, but deforestation-free proof against the 31 December 2020 baseline plus geolocation are still required on top. Treat them as inputs, not exemptions.
What supporting evidence should you keep on file?
The DDS references evidence that you must be able to produce during an enforcement inspection. Retain, at minimum:
- Legal certificates and permits
- Land-tenure and land-use-rights documents
- Farmer contracts and cooperative agreements
- Plot geolocation data (points and polygons)
- Field photos and independent surveys
- Satellite or remote-sensing analysis against the December 2020 baseline
- Audit results and any mitigation records
Records must be kept and produced on request. Usefully, a single DDS can in practice cover repeat shipments of the same verified supply base, as long as the underlying data stays current — you do not always rebuild everything for each container.
What happens if the DDS is incomplete?
Penalties for non-compliance can reach up to 4% of an operator’s EU-derived turnover, on top of rejected shipments and goods blocked at EU customs. On timing: as announced, large and medium operators must comply by 30 December 2026 and micro and small operators by 30 June 2027. Enforcement timing has shifted before — several Indonesian sources still cite 30 December 2025 and a 30 June 2026 transition — so treat every date as of 2026, subject to change, and confirm the current position with the European Commission at environment.ec.europa.eu and your EU importer. Build the DDS now; do not wait for the deadline to test whether your farmer data holds up.
Frequently Asked Questions
Do I need a separate DDS for every shipment from Indonesia?
Not necessarily. A single Due Diligence Statement can in practice cover repeat shipments of the same verified supply base, provided the underlying plot, legality, and deforestation-free data stays current. Each DDS still carries a unique reference number that must be quoted on the customs declaration. Confirm current rules with your EU importer and the European Commission.
What geolocation format does a DDS need for a smallholder plot under 4 hectares?
For plots under 4 hectares, a single GPS point coordinate — one accurate latitude and longitude for the plot — is accepted. Plots of 4 hectares and above need polygon boundaries that trace the full outline of the land. Most Indonesian smallholder coffee and cocoa plots fall under the 4-hectare threshold and qualify for the point-coordinate option.
Does my SVLK certificate cover the legality section of the DDS?
SVLK supports the legality condition for timber and furniture and is strong supporting evidence, but it does not complete the DDS on its own. You still need plot geolocation and deforestation-free proof against the 31 December 2020 baseline. Keep the SVLK documents on file as part of your evidence pack rather than as a standalone pass.