Under the EU Deforestation Regulation (EUDR), a due diligence statement is a formal submission that must be lodged in the EU information system before covered palm products are placed on the EU market or exported from it. For procurement managers and first-time buyers, this statement is not a commercial document: it is a regulatory declaration tied to the specific consignment.
What the due diligence statement contains
A complete statement identifies the operator or trader, the commodity and product code, the quantity, the country of production, the geolocation coordinates of all plots where the oil palms were grown, and the suppliers involved. It also records the conclusion of the due diligence process: after checking legality, deforestation and traceability requirements, the submitting company must state that the risk of non-compliance is negligible or has been adequately mitigated.
Who submits what
If your company first places palm oil, palm kernel oil or derivatives on the EU market, you are generally an operator and must submit your own due diligence statement. If you buy from an EU-established supplier and do not transform the product, you may be a downstream trader: you can, in many cases, rely on the reference number of an upstream statement, but you must still verify that it exists and corresponds to your consignment. Procurement teams should clarify their role in the supply chain before ordering.
Practical workflow for buyers
- Ask suppliers early for geolocation data at plot level, not just mill or refinery locations.
- Request the due diligence statement reference number and check it in the EU information system where access is available.
- Map every tier between the plantation and your purchase; indirect sourcing is a common gap.
- Keep a documented risk assessment, including evidence of legality checks in the country of origin.
- Include clear contractual clauses requiring suppliers to provide accurate statement data and to inform you of changes.
Common pitfalls to avoid
Do not assume that a sustainability certificate alone satisfies EUDR. Certifications can support due diligence but do not replace the legal statement. Avoid accepting group-level declarations that do not cover the actual plots supplying your product. Do not submit a statement with incomplete or estimated geolocation data, and update the statement if the supply base or product composition changes before delivery.
Retain all supporting evidence for the retention period required by the regulation. A disciplined internal process, with one owner for due diligence data and a single checklist used across procurement categories, reduces errors and last-minute delays.