What actually goes into a DDS, who has to file one, and where exporters get tripped up before a shipment ever reaches an EU port.
Under Regulation (EU) 2025/2650, large and medium-sized operators placing in-scope commodities (cocoa, coffee, timber, rubber, palm oil, soy, cattle) on the EU market must submit a Due Diligence Statement (DDS) through the EU’s information system before those goods can be placed on the market or exported. Micro and small operators get until 30 June 2027, but they still need to prepare for it most are selling into supply chains where a large downstream buyer is asking for the data now, well ahead of their own legal deadline.
Who actually files.
The obligation sits with the EU-based operator placing the goods on the market typically your buyer or their importer of record, not the Cameroonian exporter. But the DDS can only be as good as the information the exporter supplies upstream, and buyers are increasingly refusing to contract with suppliers who can’t provide it in the format their compliance system expects. In practice, the exporter does the data collection; the buyer files the statement.
What a DDS actually contains.
Four categories of information, all of which need to trace back to source:
- Product description commodity, HS code, quantity, and (for mixed-origin shipments) the breakdown by plot of origin.
- Country of production.
- Geolocation coordinates of every plot where the commodity was produced a single point for plots under 4 hectares, a polygon for larger ones.
- A risk assessment and, where relevant, risk mitigation measures evidence that the product is deforestation-free (post-31 December 2020 cut-off) and produced in compliance with the laws of the country of production.
Where exporters get tripped up.
- Aggregated or estimated coordinates. A single GPS point for a cooperative’s collection centre, not the individual farm plots, fails verification. Every plot needs its own coordinate.
- Missing chain-of-custody linkage. If cocoa from ten different plots is bulked at a buying station, the DDS needs a system that keeps the plot-level data attached to the batch, not lost at the point of mixing.
- No plan for the low-risk/standard-risk distinction. Cameroon currently sits in the EU’s standard-risk category, meaning buyers face a 3% compliance-check rate rather than the 1% reserved for low-risk countries. That doesn’t change what data you collect, but it changes how much scrutiny your file needs to survive.
- Treating this as a one-off exercise. The DDS is submitted per shipment (or under a simplified declaration referencing a prior DDS for repeat consignments from the same source). A traceability system that can only produce one clean report, not a repeatable one, will fail on the second shipment.
What to have ready before your buyer asks.
A digitised plot register with GPS coordinates for every registered farmer, a documented chain-of-custody process from farm to first buying point, and a named person in your organisation who owns this file. Buyers are consolidating their supplier base around exporters who can produce this without a scramble we cover that shift in a separate brief on the EU cocoa buying landscape.
