The most common mistake with the EU information system for the Deforestation Regulation
The most common mistake is not in drawing up the due diligence statement itself, but in what you do with the EU information system afterwards. Companies fill in the statement carefully, submit it, and then forget that the system works both ways: a number comes out that you must pass on, and a responsibility comes with it that remains with your legal entity, even if someone else has logged in for you.
The key point is this: the EU information system is not a mailbox where you send something once and then forget about it. It is the place where your statement receives a reference number and a verification number, where recipients in the supply chain must be able to fall back on, and where it is precisely recorded under which account and which legal entity was submitted. Mistakes usually arise because that last part is overlooked.
Error 1: failing to pass the number to the next actor in the supply chain
A statement that has been submitted generates a reference number and a verification number. Those numbers are not for internal use: they are intended to be passed on to the party that further processes or resells your product. Anyone who forgets this, or who thinks that a copy of the statement itself is sufficient, leaves the next actor without the information needed to refer back to your submission. You often only notice this when a buyer asks for it themselves, or when an inspection specifically checks for it.
Error 2: submitting from a shared or incorrect account
The information system links a submission to an account, and that account belongs to one legal entity. In practice, someone sometimes logs in to an account of a parent company when the shipment actually belongs to a subsidiary, or an external bureau uses its own account without it being clear on whose behalf exactly it was submitted. That is not a matter of ticking the wrong box: the statement then comes to be registered under the name of a different market participant than the one who is actually responsible for the product. When in doubt about who has which role, it helps to clarify that first; see in a few questions which role and obligation apply to you is a logical starting point before you create an account.
Error 3: granting a mandate without maintaining oversight
The Regulation provides for the possibility of having a third party submit on your behalf. That is practical, but it shifts the action, not the responsibility: the legal risk assessment and the accuracy of the data remain with the market participant, even if someone else presses the button. The mistake often made here is to hand over a key or authorization and then no longer check what exactly is being submitted on your behalf, with what underlying data and under what date. That is not a problem as long as the underlying data is correct, but becomes difficult to explain the moment a competent authority asks questions about a submission that you yourself no longer have a clear grasp of.
Error 4: thinking that one statement applies to the entire supply chain
A due diligence statement belongs to a specific shipment of goods, not to a supplier or supply chain in general. Anyone who has submitted a statement once for a delivery and assumes that it also applies to subsequent deliveries from the same supplier is missing a step. Every shipment that falls under the Regulation basically requires its own statement, even if the origin and supplier are unchanged. This is precisely why having a file per supply chain, with the underlying suppliers and plots in order, makes it easier to quickly generate a new statement each time instead of having to search for it from scratch each time.
How to prevent this
The common thread in these errors is that the information system is viewed in isolation from the underlying documentation. If you have your documentation in order, structured by product stream and linked to the correct legal entity, you will encounter these problems far less often: it will be clear who submits, under which account, for which shipment of goods, and who should receive the resulting number. An overview of how these elements connect can be found in the knowledge base with explanations per topic, and anyone who wants to understand how submission fits precisely into the rest of the process should read that again on the page that shows step by step where the information comes from.
For the precise operation of the information system, the exact fields, and the status of a submission, the official text and the competent authority remain the authoritative source; if you are uncertain about your specific situation, a legal advisor or the supervisory authority is the right contact. Frequently asked questions about submission and accounts are collected on the FAQ page.
Would you like to first understand exactly where you stand before you create an account and start submitting? Take the free role check, or read through the topics that apply to your commodity and your role.