EUDR Due Diligence Statement for Coffee Imports

By Viet Coffee Source Export Guides

An EUDR Due Diligence Statement for coffee imports is the electronic declaration submitted by the responsible operator after completing due diligence and before the relevant coffee is released for free circulation in the European Union. The statement confirms that the operator assessed the coffee against the EU Deforestation Regulation, found no risk or only a negligible risk of non-compliance and accepts responsibility for the accuracy of the declaration and the compliance of the product. It is not a substitute for farm records, geolocation, legal-production evidence or risk analysis. It is the formal result of the due diligence process supported by those records.

For imported coffee, the Due Diligence Statement, commonly abbreviated as DDS, must be submitted through the EUDR Information System early enough for its reference number to be included in the customs declaration. A shipment should therefore not arrive at the customs-clearance stage while the importer is still trying to identify farms, collect coordinates or reconstruct lot movements. The origin data, compliance evidence and risk conclusion must already be complete and internally approved.

What is an EUDR Due Diligence Statement?

The DDS is an electronic statement through which the operator declares that due diligence has been exercised in accordance with the EUDR and that no or only a negligible risk was found that the relevant products fail to meet the Regulation’s deforestation-free and legal-production conditions.

For coffee imports, the statement connects the imported product with:

The EU operator responsible for placing it on the market
The relevant customs classification
The commercial product description
The quantity covered
The country of production
Every production plot contributing to the coffee
The completed due diligence assessment
The customs declaration and import shipment

Submitting a DDS does not mean that the European Commission or the Information System has approved the coffee. The operator remains responsible for the declaration and must be able to provide the complete supporting file to competent authorities.

Who submits the DDS for imported coffee?

The main responsibility normally belongs to the first operator established in the European Union that places the imported coffee on the EU market under the customs procedure for release for free circulation. In many transactions, this is the EU importer named in the commercial and customs documentation.

The responsible party should be identified before the purchase contract is finalised. Possible participants include:

The EU importer purchasing directly from an exporter
An EU trading company importing on its own account
An EU roaster importing green coffee directly
An EU manufacturer importing roasted or processed coffee
An authorised representative acting within the limits permitted by the Regulation
A customs representative lodging the customs declaration without becoming the EUDR operator

A freight forwarder, shipping agent or customs broker does not automatically become the operator merely because it handles logistics or files a customs declaration. The commercial role, ownership or equivalent rights, contractual structure and customs procedure must be reviewed to identify the actual operator.

Role of the non-EU coffee exporter

A Vietnamese or other non-EU exporter generally does not submit the EU import DDS solely because it produced or shipped the coffee. However, the exporter must provide the information and evidence the EU operator needs to complete due diligence.

The exporter’s data package may include:

Farmer, farm and plot registers
Plot coordinates or polygons
Production and harvest periods
Land-use and legal-production evidence
Deforestation-screening results
Collection and processing records
Lot-composition records
Quantity reconciliations
Warehouse and container records
Commercial invoice and packing list data

If the exporter cannot provide reliable plot-level information, the importer may be unable to reach a negligible-risk conclusion and therefore may be unable to submit a valid DDS for the shipment.

When must the statement be submitted?

The due diligence process must be completed and the DDS submitted before the relevant coffee is placed on the EU market. For imported goods, the DDS reference number must be available before the customs declaration for release for free circulation is lodged.

The practical sequence is:

The importer confirms that the product falls within the EUDR scope.
The origin supply chain and all contributing production plots are identified.
Required information and supporting evidence are collected.
Deforestation-free and legal-production conditions are assessed.
Risk is evaluated.
Any non-negligible risk is mitigated.
The final shipment quantity and lot composition are confirmed.
The DDS is submitted through the Information System.
The system provides a reference number.
The customs declarant includes the required reference information in the customs declaration.

Submitting the statement after the customs declaration has already been lodged would not satisfy the required import sequence.

EUDR application dates for coffee imports

Under the current timetable, the main EUDR obligations apply from 30 December 2026 to large and medium-sized operators. For qualifying micro and small operators established within the legally defined period, the main application date is generally 30 June 2027.

Operator category	Main application date	Import implication
Large and medium operators	30 December 2026	Relevant coffee imports must be covered by completed due diligence and the required DDS before customs clearance.
Qualifying micro and small operators	30 June 2027	A later date generally applies, but supplier mapping, geolocation and data systems should be prepared in advance.

The application date is different from the deforestation cut-off date. The application date determines when the legal obligations apply to the operator. The cut-off date of 31 December 2020 determines whether the production land can qualify as deforestation-free.

Which coffee imports require a DDS?

The requirement depends on whether the imported product is listed in the applicable version of EUDR Annex I under its customs classification. The commercial name on the invoice is not sufficient for determining scope.

Products requiring classification review include:

Green coffee beans
Roasted coffee beans
Ground roasted coffee
Decaffeinated coffee
Soluble or instant coffee
Coffee extracts and concentrates
Three-in-one coffee
Composite products containing coffee
Samples intended for sale, testing or analysis

The importer should confirm the exact HS or Combined Nomenclature code, the product composition, the customs procedure, the date of import and the version of Annex I applicable at that time.

Information required in the DDS

The statement contains the information prescribed by the EUDR and its electronic system. For a coffee import, the core fields include:

Operator’s legal name
Operator’s address
EORI number for products entering the EU market
HS code
Free-text product description and trade name
Quantity covered by the statement
Country of production
Geolocation of all production plots
The prescribed confirmation that due diligence was completed and no or only negligible risk was found
Date, name, function and signature information of the person acting for the operator

The information in the DDS must be supported by the operator’s internal due diligence file. A technically complete form does not create compliance when the underlying evidence is missing or unreliable.

Operator identity and EORI number

The name and address in the DDS should match the legal entity acting as the operator. For imported coffee, the operator’s EORI number must also be connected with its registration profile and customs activity.

Common identity problems include:

Using a group name instead of the importing legal entity
Using the exporter’s details in place of the EU operator
Entering an EORI number belonging to another group company
Using different legal names in the DDS and customs declaration
Failing to update the Information System after a legal-entity change

The importer, customs broker and compliance team should agree on the exact legal-entity data before the statement is submitted.

HS code and product description

The product classification in the DDS should match the classification used in customs documentation. The free-text description should be specific enough to identify the coffee covered.

A useful description may include:

Green, roasted, ground or processed form
Caffeinated or decaffeinated status
Species or blend where commercially relevant
Origin
Processing method
Quality grade
Packaging format
Commercial lot number

Descriptions such as “food product,” “coffee material” or “agricultural goods” are too general for strong product identification. The invoice, packing list, DDS and customs declaration should describe the same product.

Quantity declared in the statement

For coffee entering the EU market, quantity is generally expressed in kilograms of net mass and, where applicable, in any supplementary unit required for the relevant customs classification.

The declared quantity should be reconciled with:

Commercial invoice
Packing list
Bill of lading
Container-loading record
Warehouse release record
Customs declaration
Weight certificate where used

Normal operational tolerances should be controlled before submission. Unexplained differences between the DDS quantity and customs quantity may lead to questions, delays or the need to correct the documentation.

Country of production

The country of production is the country where the coffee commodity was grown, not the country where it was traded, stored, re-exported, roasted or packed.

For example, coffee grown in Vietnam, stored temporarily in Singapore and shipped from another port remains Vietnamese in terms of production origin. The logistics route must not replace the actual country of production.

If a product contains coffee grown in more than one country, the operator must preserve the relevant information for all contributing origins and production plots.

Geolocation of all coffee plots

The DDS must connect the coffee with all plots of land where the relevant coffee was produced. A regional coordinate, exporter’s address, cooperative office or processing-factory location cannot replace the production plots.

For smaller plots, point coordinates may be used in accordance with the applicable requirements. For plots larger than four hectares, polygon data is generally required to describe the full boundary.

The geolocation file should be linked with:

Farmer ID
Farm ID
Plot ID
Plot area
Production period
Delivered quantity
Origin lot
Final export lot

When coffee from many smallholders is combined, every contributing plot must be included. Mapping only a sample of farms does not cover the remaining coffee in the shipment.

Production date or production period

The operator’s information file must identify when the coffee was produced. Depending on the supply chain, this may be recorded as a harvest date, harvest period, crop year or another sufficiently precise production interval.

The declared period should be consistent with:

Regional harvest calendars
Farm harvest records
Cherry or parchment delivery dates
Drying and processing dates
Warehouse intake records
Export-lot formation

An impossible timeline, such as coffee entering a warehouse before the stated harvest, should be investigated before the DDS is submitted.

The DDS follows due diligence, not the other way around

The statement can be submitted only after due diligence has been completed. Due diligence consists of three connected stages:

Collection of the required information and evidence
Assessment of the risk of non-compliance
Mitigation of any risk that is more than negligible

The importer should not prepare a conclusion first and then search for documents to support it. The risk conclusion must result from the evidence collected for the actual coffee covered by the statement.

Information collection before submitting the DDS

The supporting file should include enough information to identify the product and demonstrate compliance.

Typical records include:

Supplier details
Product specifications
Country and region of production
Farmer and plot registers
Geolocation files
Production periods
Deforestation-screening evidence
Legal-production evidence
Lot and batch records
Quantity reconciliations
Processing records
Warehouse records
Shipping documents

Importers sourcing from several Vietnamese regions can use an understanding of Vietnam’s coffee origins and production structures to design origin-specific controls.

Assessing deforestation-free status

The operator must determine whether the coffee was produced on land that was not subject to prohibited deforestation after 31 December 2020.

Possible evidence includes:

Historical satellite imagery
Official forest or land-cover maps
Historical farm registrations
Planting records
Earlier plot surveys
Dated photographs
Independent land-use assessments

Map results should be reviewed in context. Image resolution, cloud cover, shade-grown coffee, mixed farming and local land-cover characteristics can affect interpretation.

Assessing legal production

The coffee must also have been produced in accordance with the relevant legislation of the production country.

Relevant legal areas may include:

Land-use and tenure rights
Property and lease rights
Environmental rules
Forest-protection and conservation laws
Third-party rights
Labour requirements
Human rights protected by applicable law
Rights of Indigenous Peoples and local communities
Tax and trade requirements
Customs and anti-corruption rules

The appropriate document depends on the local legal system. A legally recognised land-use right may be valid even where the farmer does not hold a private ownership title in the form commonly used in Europe.

Risk assessment before declaration

Where full due diligence applies, the importer must assess whether the evidence indicates a risk that the coffee is not compliant.

The assessment may consider:

Country risk classification
Forest presence near the plots
Regional deforestation patterns
Reliability of geolocation
Land-right disputes
Document authenticity
Supply-chain complexity
Risk of mixing with unknown coffee
Supplier history
Quantity anomalies
Substantiated concerns from third parties

The conclusion should explain why no risk or only negligible risk remains. A generic “low risk” label without analysis is not a sufficient basis for the statement.

Risk mitigation before submission

If the assessment identifies more than negligible risk, the importer must reduce that risk before submitting the DDS and importing the coffee.

Mitigation measures may include:

Requesting missing documents
Correcting coordinates
Remapping plots
Obtaining higher-resolution imagery
Conducting field verification
Commissioning an independent audit
Separating uncertain farms
Rechecking production capacity
Suspending a supplier
Removing an affected source from the lot
Rejecting the shipment

If the risk cannot be reduced to a negligible level, the operator must not submit a positive DDS and proceed with placing the coffee on the market.

Low-risk countries and simplified due diligence

When all relevant coffee originates from countries or parts of countries classified as low risk and no warning information exists, simplified due diligence may be available. This reduces the standard risk-assessment and mitigation burden, but it does not remove the obligation to collect the required product, origin, geolocation, production and legal-compliance information.

A low-risk classification is not a blanket approval of every farm or lot. If the importer knows or has reason to believe that documents are false, plots are incorrectly mapped, illegal production occurred or unknown coffee was mixed into the shipment, the concern must be investigated.

Vietnamese coffee and the low-risk classification

Vietnam is currently classified as a low-risk country under the EU benchmarking system. Qualifying Vietnamese coffee imports may therefore benefit from simplified due diligence where all conditions are satisfied.

The importer must still maintain:

Plot identification
Geolocation
Production-period information
Evidence of legal production
Evidence of deforestation-free status
Lot-to-shipment traceability
Accurate DDS and customs information

Low risk simplifies part of the procedure; it does not eliminate the evidence supporting the declaration.

The EUDR Information System

The DDS is submitted electronically through the EUDR Information System. The operator must be properly registered and, for imports, its EORI information must be included in the relevant profile.

The system is used to:

Register operators and authorised representatives
Create and submit Due Diligence Statements
Record the products and quantities covered
Upload or enter geolocation information
Generate a reference number
Retrieve existing statements
Connect references with downstream or customs processes

Companies with high statement volumes may use available technical integration options, but automated submission does not remove the need for data validation and compliance approval.

Reference number and verification information

After submission, the Information System provides a reference number associated with the DDS. Relevant system processes may also use verification information for controlled access or reference validation.

The reference should be connected with:

The correct operator
The correct HS code
The declared quantity
The relevant coffee lot
The contributing plots
The commercial invoice
The packing list
The customs declaration

A valid reference number does not make unrelated coffee compliant. Using the reference of another supplier, product or shipment may represent incorrect reporting or circumvention.

DDS reference in the customs declaration

The person lodging the customs declaration must include the DDS reference number or applicable declaration identifier for the imported product. The importer should therefore transmit the correct reference information to its customs representative before filing.

The customs and compliance teams should compare:

Importer identity and EORI
Product code
Product description
Country of production
Net quantity
Invoice and packing-list references
DDS reference number
Container and lot information

Differences should be resolved before submission rather than after the shipment is held for clarification.

Can one DDS cover multiple shipments?

A DDS may be referenced in more than one customs declaration where it validly covers the relevant products, quantities, production plots and due diligence assessment. The same reference should not be reused beyond the product and quantity actually covered.

Similarly, one customs declaration may include multiple DDS references where the imported consignment contains coffee covered by several valid statements.

The company should maintain a control ledger showing:

Total quantity covered by each DDS
Quantity allocated to each customs declaration
Remaining unallocated quantity
Lots and plots associated with each allocation
Date and status of each import entry

This prevents duplicate allocation and use of a statement for quantities exceeding its actual coverage.

Can a DDS be amended or cancelled?

The operator should verify all data before submission. The ability to amend or cancel a statement may be restricted once its reference has been used in a customs declaration, another statement or a completed market transaction.

Before submission, companies should therefore confirm:

Final product code
Final lot composition
Final production plots
Final quantity
Correct operator and EORI
Correct country of production
Completion of risk approval

If the commercial lot changes after submission, the compliance team should determine whether the existing DDS remains valid or whether a replacement statement is necessary.

Changes after the statement is submitted

A shipment may change because of quantity adjustments, container replacement, damaged bags, customs reclassification, removal of a lot or substitution of product. Every change should be evaluated against the DDS.

A new or revised compliance action may be needed when:

The HS code changes.
The quantity exceeds the amount covered.
The country of production changes.
New farms or plots are added.
The export lot is replaced.
Unknown coffee enters the shipment.
New information changes the risk conclusion.

Administrative convenience should never be used to keep a statement attached to coffee it no longer accurately describes.

Authorised representatives

An operator may appoint an authorised representative to perform specified actions where permitted. The appointment should be documented, and the roles of the operator and representative should be clear.

The operator should define:

Scope of authority
Access to the Information System
Who validates origin data
Who approves the risk conclusion
Who submits the DDS
Who communicates with customs
Who maintains supporting records

Use of a representative does not remove the operator’s responsibility for the compliance of the imported coffee.

Supporting documents are not uploaded only for formality

The core evidence may be stored in the operator’s due diligence system rather than reproduced in full inside every statement. It must nevertheless be organised, accessible and connected to the DDS reference.

A practical file structure may contain:

Operator approval record
Supplier contract and questionnaire
Product and HS-code assessment
Farmer and plot dataset
Geolocation files
Deforestation assessment
Legal-production review
Risk assessment
Risk-mitigation evidence
Lot and quantity reconciliation
Shipping and customs documents
Copy of the submitted DDS and reference

These controls can be integrated with documented coffee quality, traceability and compliance procedures.

Lot traceability supporting the DDS

The statement must relate to identifiable physical coffee. The importer should be able to trace the covered lot backwards to all production plots and forwards to the customs entry and subsequent customers.

A typical chain is:

Production plot
Farmer delivery
Collector or cooperative lot
Processing batch
Dry-mill lot
Warehouse lot
Export lot
Container
Import customs entry
Importer warehouse lot
Roasting or resale batch

If several lots are combined, all inputs must remain identifiable. If one lot is divided, every child lot must retain its connection with the parent record.

Quantity reconciliation supporting the DDS

Quantity controls demonstrate that the declared coffee could realistically have originated from the identified farms and passed through the recorded supply chain.

The operator may compare:

Mapped coffee area
Expected farm yield
Recorded harvest
Delivered cherry or parchment
Green-coffee conversion
Processing losses
Warehouse stock
Export quantity
Imported net mass

Unexplained excess volume is a warning that undocumented coffee may have entered the lot. The issue should be resolved before the DDS is approved.

Consistency between the DDS and commercial documents

The following documents should describe the same transaction:

Purchase contract
Commercial invoice
Packing list
Bill of lading
Certificate of origin where used
Quality certificate
Phytosanitary or other required certificates
DDS
Customs declaration

Not every document contains identical fields, but shared information such as parties, product, origin, quantity and lot should not conflict.

Common DDS mistakes in coffee imports

Submitting the statement before completing risk assessment
Using the exporter instead of the EU operator in the operator field
Entering an incorrect EORI number
Selecting the wrong HS code
Using a product description that is too general
Declaring gross weight instead of the required net quantity
Listing the shipping country instead of the production country
Providing only cooperative or warehouse coordinates
Omitting contributing farms from an aggregated lot
Using copied or invalid coordinates
Failing to reconcile quantities
Using a DDS reference for unrelated coffee
Submitting the DDS after the customs declaration
Assuming certification automatically proves compliance
Assuming low-risk classification removes plot-level information requirements

Warning signs for importers

An importer should pause the DDS process when:

The exporter cannot identify all contributing farms.
The same coordinate appears for many unrelated producers.
The mapped area cannot support the supplied volume.
The stated harvest dates conflict with the regional season.
Land documents do not identify the producer or legal user.
The lot was mixed before farms were verified.
Traceability ends at the cooperative.
The shipment quantity differs materially from the approved lot.
The supplier claims that a sustainability certificate is sufficient by itself.
The compliance team cannot reproduce the basis for the negligible-risk conclusion.

Record-retention obligations

The operator must retain records of Due Diligence Statements and the supporting due diligence information for at least five years. Records should remain accessible even when employees, brokers, suppliers or software systems change.

Retention should cover:

Submitted DDS records
Reference numbers
Geolocation files
Supplier and farm registers
Risk assessments
Risk-mitigation actions
Legal-production evidence
Deforestation-screening evidence
Lot records
Quantity controls
Customs and shipping documentation
Communications concerning corrections or new risk information

New information discovered after import

If the operator obtains new information indicating that imported coffee may not comply, it must act immediately. The response may include informing competent authorities and relevant downstream businesses, stopping distribution, isolating stock, conducting additional investigation and taking corrective action.

Examples of new information include:

A substantiated deforestation concern
Evidence of false coordinates
Discovery of illegal land use
Undeclared mixing
A falsified supplier document
A quantity discrepancy revealing an unknown source

The original DDS should not be treated as a permanent shield against later evidence.

Passing the reference downstream

The responsible operator must communicate the relevant DDS reference information to the downstream operators and traders receiving the coffee. Each downstream business should maintain a clear link between the coffee purchased and the reference received.

Downstream records may include:

Supplier identity
Purchase invoice
Input-lot code
DDS reference number
Quantity received
Processing or resale record
Output-lot code
Customer supplied

The reference must not be attached to products or quantities outside the scope of the original statement.

Internal approval before submission

A company should establish a documented approval process rather than allowing any user with system access to submit a DDS.

The approval may include:

Product-classification review
Supplier approval
Geolocation validation
Legal-production review
Deforestation-screening approval
Risk-assessment approval
Quantity and lot reconciliation
Customs-data comparison
Final management authorisation

The person submitting the statement should understand the meaning of the declaration and not treat it as a routine shipping form.

Import-document checklist

EU operator legal name confirmed
EORI number confirmed
HS code confirmed
Product description confirmed
Country of production confirmed
Net quantity confirmed
All production plots identified
Geolocation validated
Production period recorded
Deforestation-free evidence reviewed
Legal-production evidence reviewed
Risk assessment completed where required
Risk mitigation completed where necessary
Lot composition confirmed
Quantities reconciled
DDS submitted
Reference number obtained
Reference sent to customs declarant
Customs declaration matched with the DDS
Records retained for at least five years

Recommended workflow for coffee importers

Confirm the product’s EUDR scope and customs classification.
Identify the responsible EU operator.
Confirm the applicable EUDR application date.
Contractually require the exporter to provide plot-level data.
Register and validate suppliers, farms and plots.
Collect geolocation and production periods.
Assess deforestation-free status.
Review legal-production evidence.
Establish lot traceability from plots to export shipment.
Reconcile production and shipment quantities.
Complete risk assessment where applicable.
Mitigate every non-negligible risk.
Confirm the final commercial and customs data.
Submit the DDS through the Information System.
Obtain and record the reference number.
Transmit the correct reference to the customs declarant.
Verify customs clearance against the declared product and quantity.
Pass required reference information downstream.
Monitor for new compliance information.
Retain the complete file for at least five years.

Commercial value of DDS-ready supply chains

A well-prepared DDS process can reduce customs delays, document disputes and buyer uncertainty. Exporters that deliver validated plot data and stable lot records may be preferred by European importers even when their coffee is not the lowest-priced offer.

DDS-ready supply programmes may include:

Traceable commercial Robusta
Farm-level Arabica
Fine Robusta microlots
Physically segregated regional lots
Certified coffee with supporting EUDR evidence
Private-label roasted coffee
Documented espresso blends
Traceable processed-coffee supply chains

Suppliers preparing coffee for European customers can review structured coffee export, traceability and documentation services.

Final assessment

The EUDR Due Diligence Statement for coffee imports is the operator’s formal declaration that the imported product has passed the required due diligence process and presents no risk or only a negligible risk of non-compliance. It must accurately identify the operator, product, quantity, production country and all contributing production plots, and its reference must be available for the customs declaration.

The DDS is only as reliable as the records behind it. Incomplete geolocation, unidentified farms, inconsistent quantities, unsupported legal claims or unknown mixing cannot be corrected merely by submitting an electronic form.

Importers should complete due diligence before customs filing, validate the final shipment against the statement and preserve the supporting evidence for regulatory checks. Businesses seeking Vietnamese green, roasted or processed coffee with defined EUDR documentation can submit a customised wholesale coffee inquiry specifying the product, origin, quantity, destination, processing method, packaging and due diligence data required.

EUDR Due Diligence Statement for Coffee Imports