What is a due diligence statement?
Under the EU Deforestation Regulation (EUDR), operators and traders who place certain commodities, including palm oil, on the EU market or export them must exercise due diligence. A core requirement is to submit a due diligence statement to the relevant competent authority before the goods are placed on the market or exported. The statement confirms that the operator has carried out due diligence and that the products are deforestation-free and legal according to the laws of the country of production.
For procurement managers and first-time palm-product buyers, the due diligence statement is not just a customs form; it is a formal declaration that links each consignment to its production plots and supply chain evidence.
What the statement typically contains
A due diligence statement generally includes:
- Operator or trader identification and Economic Operators Registration and Identification (EORI) number.
- Commodity and product description, including Harmonized System (HS) code and quantity.
- Country of production and, where relevant, geolocation coordinates of all plots of land where the commodity was produced.
- Confirmation that the due diligence system was followed and no or negligible risk was found.
- Reference to the due diligence documentation set, such as risk assessments and mitigation measures.
Exact fields may vary by EU member state, as national authorities implement the regulation, but the core elements are consistent.
Practical steps for buyers
1. Map your supply chain. Identify the origin of palm oil and its derivatives down to the plot or plantation. For first-time buyers, start with direct suppliers and request geolocation data early. 2. Collect evidence. Gather documents proving legality (land rights, environmental permits) and deforestation-free status (satellite imagery, supplier declarations, certification where available). 3. Assess risk. Evaluate the risk of non-compliance based on country of production, prevalence of deforestation, and supplier reliability. If risk is not negligible, take mitigation measures. 4. Prepare the statement. Ensure all required fields are accurate and match the underlying evidence. The statement is submitted electronically through the relevant member state system. 5. Keep records. Retain the due diligence statement and supporting documents for the period required by the regulation or national law.
Common pitfalls to avoid
- Incomplete geolocation data: For palm oil, plot coordinates must cover the actual production area. Missing or imprecise polygons can lead to rejection.
- Relying solely on certification: While certification schemes can be part of a due diligence system, they do not automatically satisfy EUDR obligations. Buyers must still verify and submit statements.
- Treating the statement as a one-time task: Due diligence must be repeated for each consignment or, where allowed, covered by a periodic statement for recurring supplies under stable conditions.
- Ignoring legality requirements: Deforestation-free is not enough; products must also comply with relevant laws in the production country.
Conclusion
For procurement managers and first-time palm-product buyers, the due diligence statement is the visible tip of a larger due diligence system. Start early, collect geolocation and legality evidence before purchase, and treat every consignment as requiring a complete and accurate declaration. This neutral overview does not constitute legal advice; consult your EU member state's competent authority for specific operational requirements.