Batches, deliveries and the practical implementation of DDS in the EUDR

Executive Summary

From December 30, 2026, companies that place EUDR-relevant products on the EU market or export them must have a DDS in the EU information system. The DDS relates to a defined quantity of goods and can cover several partial deliveries over up to twelve months, but must be available before the first delivery.

Traceability must not be interrupted in collective warehouses and mixtures, all origins must remain clearly assignable, mass balance logics are inadmissible. Clear batch allocation, consistent use of reference numbers and the training of all departments involved are the key success factors.

What is the Due Diligence Statement (DDS) and why is it important?

Overview of the DDS obligations of the EUDR

The DDS is the central instrument of the EUDR(EU Regulation 2023/1115). Depending on the size of the company, the obligations will apply from the end of 2026 or mid-2027 to all companies that supply or export deforestation-relevant raw materials such as wood, cocoa, coffee, rubber, palm oil, beef or soy to the EU market for the first time. Find out all about the Deforestation Regulation, obligations and deadlines here.

The prerequisite is a robust due diligence system that identifies, assesses and documents risks along the supply chain. The core is complete traceability down to the production parcel: companies must record geolocation data, quantities, delivery routes and actors involved. The goods must be deforestation-free, with a deadline of December 31, 2020, and comply with the legal requirements of the country of production.

The final step is the electronic submission of the DDS: formal confirmation that information is available, a risk analysis has been carried out and, if necessary, risk reduction measures have been implemented. Without a valid DDS, a product may neither be sold in the EU nor exported.

DDS and the reference to batch and delivery - how is this regulated?

Clearly distinguish batch and delivery

For a successful implementation of the EUDR, it is crucial to use key terms consistently and to distinguish between legal logic and operational practice. "Batch" and "delivery" are both important, but do not mean the same thing.

In practice, "batch" usually refers to an internally defined, clearly definable quantity of goods, a batch or lot logic with which companies bundle products under comparable manufacturing, processing or procurement conditions. Batch is primarily an operational control term. It helps to structure the flow of goods in such a way that the origin, production area/geolocation, actors involved, quantities, processing steps and proofs can be reliably assigned.

This is to be distinguished from "delivery": it describes the actual transportation or physical handover of goods to the next actor in the supply chain. The decisive factor is that a batch can extend over several deliveries and, conversely, a single delivery can contain several batches. This flexibility is normal and is common practice in many industries.

Basic rule of the regulation: DDS refers to a defined quantity of goods

The logic of the EUDR-DDS is not linked to individual delivery bills, but to a clearly defined quantity of relevant products. For this defined quantity, market participants must collect all necessary information and evidence, carry out a risk analysis and, if necessary, implement risk mitigation measures. A DDS can cover several partial deliveries, but must be submitted before the first delivery. Once the quantity specified in the DDS has been fully placed on the market or exported, a new DDS is required for additional quantities.

Important update: Increased inspection risk for DDS for multiple partial deliveries

A DDS may not cover consignments or batches for a period of more than one year from submission. This flexibility increases the complexity and thus the non-compliance risk for the market participant, which can lead to more intensive inspections by the authorities. In the event of non-compliance, interim measures or sanctions may apply to all products covered by this DDS, even if they are included in separate partial shipments.

Recommendation: Weigh up the range of a single DDS carefully and ensure complete traceability for each partial quantity.

Use reference number and verification number correctly

The consistent use of reference numbers from the EU information system is essential for a stringent DDS system. They make it possible to reference DDSs consistently along the supply chain and to link them cleanly internally with batch/lot IDs and delivery or consignment numbers.

A distinction must be made here: Passing on the reference number to the first downstream actor is mandatory, while the verification number is merely an additional level of security and does not have to be passed on proactively, but it can be requested if there are justified concerns.

In practice, these links should be consistently included in the ERP and in the documentation (delivery bills, invoices, incoming/outgoing goods) in order to avoid media disruptions and allocation errors. Standardized product and packaging labeling (e.g. barcode/QR/RFID) is not mandatory, but can simplify data collection, reduce errors and significantly speed up inspections and audits.

How do you deal with collective batches and stock items?

Problem: Lack of separation or mixing in the warehouse

In practice, companies often face organizational and technical challenges when it comes to warehousing, especially when goods are kept as collective stocks or in bulk in silos, tanks or storage boxes. Typical examples are import and storage processes for grain or oilseeds, where harvests from different regions are brought together. Without a clear separation logic, there is a risk that origin information, quantity references and proofs can no longer be clearly assigned.

The EUDR sets high standards for traceability and traceability. The decisive factor is not that physical mixing is excluded in every case, but that mixing does not result in the relevant quantities losing their clear assignment to origin and geolocation.

Mixed batches: What must be documented?

If several batches are physically merged into a collective or mixed batch, the new batch must be documented in such a way that it can be plausibly proven which origins and DDS references it contains even after mixing.

This obligation applies regardless of whether the initial batches come from the same or different suppliers. The central test question is: Can we show which DDS references form the basis of which quantity share in the new batch at any time after blending? According to FAQ 1.4, mass balance logic alone, which only maintains balances of incoming and outgoing quantities without assigning specific origins, is expressly not permitted. Conforming goods may not be mathematically "mixed" with goods of unknown origin.

Do separate DDS documents have to be created for each batch?

The EUDR does not require a blanket due diligence declaration "for the entire warehouse", but a DDS for clearly defined relevant goods before they are placed on the market, made available or exported in the EU. A key technical challenge here is the file size limit of 25 MB per DDS. This limit can quickly be reached or exceeded for collective batches that bundle the origins of hundreds or thousands of production lots, such as coffee blends or bulk cocoa.

Practical example: Loose stored material with individual delivery A retailer stores rubber in several silos, some from different origins and each with assigned certificates. The material is delivered to the processing industry in partial quantities or as mixtures, depending on customer requirements. A DDS must be created for each quantity delivered, mapping all origins in GeoJSON format. The following strategies help to ensure that the 25 MB limit is not exceeded:

• For plots of less than 4 hectares or for cattle farms, the specification of a single longitude and latitude point is sufficient, an efficient method to reduce the amount of data.
• The resolution can be optimized for larger plots that require polygons: Instead of a high number of vertices, the essential vertices are sufficient to describe the perimeter. Software tools can help with the compression of GeoJSON files.

In practice, this means that the DDS must always refer to a clearly defined consignment or lot. If a single product is brought together from different origins (e.g. a coffee blend from several regions), a new relevant item is created for which a corresponding DDS must be submitted, including the geolocation data of all underlying production areas. For a new DDS, information from previously submitted DDSs can be referenced upstream so that data does not have to be entered twice.

Special cases and common pitfalls

Different suppliers for the same products

A particularly challenging situation arises when a company purchases the same types of goods from different suppliers, such as soybeans from several sources. In these cases, the documentation and control effort increases significantly because the origin, production areas, quantities and evidence must be reliably assigned to each source.

The EUDR does not necessarily require "one DDS per supplier" or "one DDS per delivery", but that all relevant products and quantities that are placed on the market or exported are fully covered by a DDS and that the due diligence for these quantities has been demonstrably carried out. If mixing takes place in the warehouse, it must still be possible to trace which origins and quantities are contained in the definable quantity of goods.

Repackaging or order picking in the warehouse

In logistics practice, goods are often repacked or picked for individual customers. This raises the question of how the DDS documentation must be kept if the flow of goods no longer corresponds to the original layout of the stock. It is crucial that the chain of evidence and traceability is maintained even after repackaging, partial removal or reassembly: The definable quantities must still be able to be clearly traced back to the underlying origins and the corresponding DDS references.

Many companies solve this using clear ERP/WMS rules and digital links by using the reference numbers from the EU information system as "anchors" in their inventory and transaction data. Serialized identification (QR code, barcode, RFID) is not mandatory, but can help to avoid media disruptions and speed up checks.

Practical implementation: three levels and technical requirements

A practicable EUDR system should distinguish between three levels:

• DDS level: The due diligence declaration, reference number, verification number, origin data, risk assessment and validity logic are managed here.
• Batch level: This documents which specific quantity of goods has which origin, which properties and which DDS reference.
• Delivery level: This records which quantity from which batch was delivered to which recipient.

This separation is the structural basis for traceability. Without it, batches and deliveries run into each other in practice and the DDS assignment becomes blurred.

What an ERP or traceability system should do

To ensure that the linking of batches, deliveries and DDS references functions reliably, the ERP or traceability system should cover the following functions:

• Creation and management of DDS references including verification numbers and validity period
• Unique assignment of each batch to one or more DDS references
• Ongoing booking of quantity consumption per DDS (received, used, delivered, exported, remaining quantity)
• Mapping of partial deliveries and mixed batches with receipt of all original purchases
• Audit trail for repackaging and order picking
• Blocking logic that blocks goods receipts, deliveries or exports or issues a warning if no valid DDS is stored, the DDS has expired or the originally covered quantity has already been exhausted
• Integration of sensor and measurement data (weighing, fill level, scan data) for automatic stock changes
• Audit-proof archiving of all processes including change history for at least five years

A practical note on the correction window: submitted due diligence declarations or simplified declarations (SD) can be changed or withdrawn within 72 hours after the reference number has been assigned in the information system, as long as the reference number has not yet been used in a customs declaration, the product has not yet been made available or exported and there is no intention on the part of the authority to carry out an audit.

How DDS references are passed on in practice

The legal obligation to pass on the DDS reference number to the first downstream actor leaves open how this should be done technically. In practice, several transmission channels have been established:

• Delivery bills with DDS reference number per item or per batch
• Invoices with reference to the corresponding DDS reference
• Separate EUDR accompanying documents as PDF or structured data sheet
• EDI interfaces for automated data exchange between ERP systems
• Customer portals where customers can call up their DDS references
• Structured data records directly from the ERP system (e.g. via API)

The decisive factor is not the transmission path, but that the customer can clearly identify which goods, which quantity and which delivery the respective DDS reference relates to. A reference number without an allocation to batch and quantity share is practically worthless for the recipient and leads to compliance gaps in their own documentation.

Recommendations for action in practice

Establishment of a structured recording of batch and delivery data

The most important basis is the establishment of a structured system for recording all data relevant to batches and deliveries. Companies should analyze existing processes at an early stage, identify bottlenecks in the data flow and close gaps in warehouse or production logistics. Third-party systems from external logistics partners or suppliers should be integrated into the company's own database at an early stage in order to avoid media disruptions in batch tracking.

Mandatory GeoJSON format and file size limit

All geolocation data must be recorded in GeoJSON format (WGS-84/EPSG-4326) and uploaded to the EU information system. A single DDS may not exceed 25 MB. The IT systems must process this format and offer optimization functions, individual points for areas under 4 hectares or cattle farming, reduction of the polygon resolution to significant corner points, automatic validation of the coordinates to six decimal places.

Training and involvement of relevant departments

The due diligence obligations have a deep impact on several areas of the company - from procurement, production and warehousing to sales and the legal department. Early and continuous training of all employees who come into contact with the processes is crucial. Only those who understand the logical link between batch, delivery and due diligence declaration can avoid process errors, unauthorized mix-ups or gaps in the documentation. Practical training courses based on typical company processes, regular internal audits and a central contact person to answer questions are helpful.

Conclusion

The DDS refers to a defined quantity of goods, usually a batch in operational practice, and the physical delivery is only a subsequent event. The clean separation of DDS, batch and delivery levels is therefore the backbone of EUDR compliance. If you keep clean records of quantities, document mixing processes, pass on reference numbers in a structured manner and use an ERP system with blocking logic, you avoid the typical sources of error: duplicate quantities, uncovered deliveries and lost origin references after mixing processes. With its strict requirements, the EUDR involves effort. The benefits - legal certainty, greater customer confidence and sustainable positioning - pay off in the end.

If you would like to delve deeper into the technical implementation of batch tracing, you will find the most important components in the previous section. It is also worth taking a look at the EU Commission's official guidelines.