Can I submit the EUDR declaration myself?
Yes, you can submit the due diligence statement yourself in the EU information system. The regulation does not require this to be done through an intermediary; the market operator or trader submitting the statement remains responsible for it themselves. What makes submission difficult in practice is not the entry screen itself, but everything that must be in order beforehand: the correct role determination, geolocation data per plot, the risk classification of the country of origin, and a file that will hold up under inspection.
Whether self-submission is feasible for you depends less on technical skill and more on how many product streams you have, how fragmented your suppliers are, and how much time you can spare to build and maintain that file. For a single product stream with a stable, cooperative supplier, self-submission is manageable for many small and medium-sized enterprises. With multiple commodities, changing suppliers, or countries with higher risk classification, the time investment quickly increases.
What must be in place before you submit anything
Submission itself is the final step, not the first. Before that, you must know what role you perform in the chain and what obligation comes with it, as that determines whether you need a full due diligence statement or a simplified version. You must also be able to identify the plots of origin per product stream with geolocation data, demonstrate the associated documents, and know which risk class the country of origin falls into. If you don't yet have this overview, it's advisable to first determine your role and obligation in five questions first before submission itself becomes relevant.
A file that has gaps on these points will not produce an error message when submitted — the system will accept a statement you submit. The problem only arises if a competent authority asks for substantiation and that substantiation is incomplete or not traceable. Self-submission thus means above all: being responsible yourself for the quality of what comes before it.
Where self-submission reaches its limits
There are a few points where companies run into difficulties in practice. The first is time: collecting geolocation data from multiple suppliers in multiple countries is a recurring, administrative process, not a one-off action. The second is validation: a plot boundary that doesn't match the country of origin, or coordinates that don't align with the rest of the file, are difficult to spot with the naked eye. The third is the retention requirement: documents must remain accessible for five years, even if a supplier changes or an employee leaves.
None of these points makes self-submission impossible. But they do determine whether it's a matter of an afternoon for your company or an ongoing task that someone must manage continuously. Companies submitting declarations for multiple commodities at the same time therefore more often opt for some form of support in structuring and validating the file, while the final submission and responsibility for it remain with them.
The two forms of assistance, and the difference between them
There is a difference between guidance and outsourcing, and for most small and medium-sized enterprises, this difference is the most important one to understand clearly. With guidance, a party structures and validates your file and generates the statement from it; you submit it yourself to the EU information system using your own login credentials. With outsourcing, you hand over those login credentials and the other party submits on your behalf. In both cases, the legal risk assessment remains with you as the market operator or trader; a service provider structures and generates, but does not declare on your behalf that a product is deforestation-free.
On the page on how submission and the file are prepared explains precisely which steps you take yourself and which steps are taken over if you choose to do so. Anyone wanting to know what guidance or full outsourcing costs in relation to the number of product streams will find that information in the overview of fees per situation.
Do it yourself, with the right support
For a single product stream with a manageable supplier base, self-submission is realistic for many SMEs, provided the file is in order beforehand. With multiple commodities, countries of origin with higher risk classifications or frequently changing suppliers, the time required to build and maintain that file often outweighs the submission itself. In the knowledge base with detailed steps per product stream you will find per commodity and role what is concretely needed to arrive at a submittable declaration.
Would you first like to know exactly where you stand before deciding whether to do it yourself or get guidance? Take the free role check and read the associated topics in the knowledge base; that will give you a concrete starting point within minutes.