How
to Generate a TRACES-Ready DDS for Colombian Coffee (Step-by-Step)
The Due Diligence Statement is the document that makes or breaks EU
market access under EUDR. Getting it right requires assembling verified
data from multiple sources, validating it against regulatory
specifications, and submitting it through the EU’s TRACES system before
the commodity crosses the border. This guide covers what the DDS must
contain, how to submit it, and how Origo reduces the process from weeks
to hours.
For the full regulatory context, see our EUDR
compliance guide for EU coffee importers.
What
information does a valid DDS require under EU 2023/1731?
A valid DDS under EU Commission Implementing Regulation 2023/1731
must contain a defined set of data fields. Missing or incomplete fields
will cause the submission to be rejected by the TRACES system or flagged
for review by the competent authority. The mandatory elements are:
Product description. The commodity type (coffee),
HS/CN code, product form (green bean, roasted, soluble), and quantity.
The description must be specific enough to link the DDS to a single
shipment or batch.
Country of production. Colombia, identified by ISO
country code. If the supply chain involves blending from multiple
origins, each origin requires its own DDS or a combined DDS that
separates the data by country.
Geolocation of production parcels. GPS polygon
coordinates (all boundary vertices) for each parcel where the coffee was
produced. For parcels under 4 hectares, a single GPS coordinate point is
acceptable under the simplified procedure, though polygon data is
strongly recommended. The coordinates must use WGS84 reference system
(standard GPS format). For more on the polygon vs. point distinction,
see our geolocation
verification guide.
Deforestation verification. A declaration that the
operator has verified, using satellite monitoring data and the country
of origin’s national forest monitoring system, that no deforestation or
forest degradation occurred on the production parcels after 31 December
2020. The verification must reference the specific data sources
used.
Legal compliance verification. Confirmation that
production complied with the producer country’s relevant laws, including
land use regulations, environmental protections, labour laws, tax
obligations, and, where applicable, Indigenous peoples’ rights (FPIC
under ILO Convention 169). For Colombian supply chains, this includes
verification against IDEAM land use classifications and land title
records.
Operator declaration. The name, address, and EORI
number of the EU operator or trader submitting the DDS, along with a
signed declaration that the due diligence has been exercised and the
risk assessment concluded that the risk of non-compliance is
negligible.
Date and signature. The DDS must be dated and signed
by an authorized representative of the submitting operator. Electronic
signatures are accepted through the TRACES portal.
The
manual TRACES submission path: PDF export and portal upload
The EU’s TRACES NT (New Technology) system, accessible at
ec.europa.eu/traces, is the designated portal for DDS submission. The
manual submission process works as follows.
Step 1: Register on TRACES NT. The EU operator must
have an active TRACES NT account. Registration requires an EORI number
and verification by the relevant national competent authority. Allow 2-4
weeks for account activation if you have not previously used the
system.
Step 2: Prepare the DDS document. Assemble all
required data fields into the format specified by Implementing
Regulation 2023/1731. This includes formatting geolocation data
correctly (WGS84 coordinates), attaching supporting evidence for the
risk assessment, and completing the operator declaration.
Step 3: Enter data into the TRACES portal. The
portal provides a structured form for DDS data entry. Each field
corresponds to a requirement in the implementing regulation. Geolocation
data can be entered manually or uploaded as a file (GeoJSON or shapefile
format).
Step 4: Attach supporting documents. Upload the risk
assessment documentation, deforestation verification evidence, legal
compliance records, and any other supporting materials. The portal
accepts PDF, GeoJSON, and standard document formats.
Step 5: Submit and receive reference number. Upon
submission, TRACES generates a unique DDS reference number. This number
must accompany the physical commodity shipment. Customs authorities at
EU entry points will verify that a valid DDS reference number exists for
each consignment of covered commodities.
Step 6: Present DDS before dispatch. The DDS must be
completed and submitted before the commodity is dispatched from the
country of production or, at the latest, before it is placed on the EU
market. Retroactive submission is not permitted.
The manual path is functional but labour-intensive. For a single
shipment from a single cooperative with well-organized data, an
experienced compliance team can prepare and submit a DDS in
approximately 6-8 weeks from initial data collection to submission. For
importers handling multiple origins, dozens of cooperatives, and
thousands of farm parcels, the manual path does not scale. Industry
estimates put the cost of manual DDS preparation at EUR 20,000 to EUR
50,000 per origin when using external consultants.
The
automated path: API submission (when EU TRACES API becomes public)
The EU Commission has indicated that a TRACES API for programmatic
DDS submission will be made available. As of May 2026, the API
specification has not been publicly released, and direct
machine-to-machine submission is not yet possible.
When the API becomes operational, compliant platforms like Origo will
support direct submission, eliminating the manual portal upload step.
The data preparation, verification, and validation steps remain
identical; only the final submission mechanism changes from manual
upload to API call.
Origo is designed for API integration from day one. The platform
already produces DDS data in a structured, machine-readable format. When
the TRACES API launches, the switch from document export to direct
submission will be a configuration change, not a rebuild. Importers
using Origo will be among the first to benefit from automated
submission.
Until then, the workflow is: Origo generates the compliant DDS
document, the EU importer reviews and signs it, and the importer uploads
it manually to TRACES NT.
How Origo
generates the DDS document in 24 hours
Origo’s DDS generation process compresses what would otherwise take
weeks of manual work into a structured, automated pipeline. The data
flow proceeds through five stages.
Stage 1: Supply chain data ingestion. The Colombian
cooperative or exporter uploads farm-level data to Origo: GPS polygons,
farmer identity, lot numbers, cooperative membership records, and land
tenure documentation. Data can be uploaded via CSV, GeoJSON, API, or
Origo’s field data collection app.
Stage 2: IDEAM and JRC verification. Origo
cross-references each parcel’s GPS polygon against IDEAM’s national
forest monitoring data and the EU JRC’s Global Forest Watch dataset. The
system checks for any detected deforestation or forest degradation
events after 31 December 2020.
Stage 3: SHACL validation. Origo’s rule engine
applies a set of validation shapes to the data. These shapes check data
completeness (all required fields present), data consistency (polygon
coordinates within Colombia’s boundaries, HS codes matching product
type), and regulatory compliance (deforestation cutoff date, legal
compliance fields). Validation results are returned as pass, warning, or
violation for each parcel.
Stage 4: Agroforestry check. For parcels where IDEAM
classifies land use as an agroforestry category (cafe de sombra,
sistemas agroforestales, etc.), the agroforestry
validation process applies. Warnings are escalated for manual canopy
verification rather than treated as hard failures.
Stage 5: DDS document generation. Once all parcels
pass validation (or have warnings resolved), Origo assembles the DDS
document in the format required by Implementing Regulation 2023/1731.
The document includes all mandatory fields, supporting evidence
references, and the operator declaration template for the importer to
sign.
Timeline: Initial setup (cooperative onboarding,
first data ingestion, field data collection coordination) takes 1-2
weeks. After setup, each subsequent DDS is generated in under 24 hours
from data submission to document delivery. For cooperatives with ongoing
supply relationships, the process becomes faster as historical data
accumulates and only new lots require fresh verification.
The
5-year archive requirement: what to store and how Origo handles it
Article 10 of the EUDR requires operators to retain all due diligence
documentation for a minimum of five years from the date of the DDS
submission. This is not optional, and the competent authority can
request access to archived records at any point during the retention
period.
The records that must be archived include:
- GPS polygon data for every production parcel
referenced in the DDS - IDEAM and JRC verification reports documenting the
deforestation risk assessment - FPIC records for any parcels on Indigenous
territories - Land title documentation or evidence of legal land
use - Supplier contracts and chain-of-custody records
linking farm parcels to export shipments - The DDS itself, including the signed operator
declaration and the TRACES reference number - Risk assessment methodology documentation,
describing how the operator evaluated and mitigated deforestation
risk
The penalty for inadequate record-keeping is the same as for
non-compliance: fines up to 4% of EU turnover, confiscation, and
potential market exclusion.
Origo automatically archives all DDS-related data for five years from
submission date. The archive is structured, searchable, and exportable.
If a competent authority requests documentation for a specific DDS, the
importer can retrieve the complete file, including all underlying parcel
data and verification evidence, from Origo’s archive within minutes. No
filing cabinets, no scattered spreadsheets, no reliance on a
consultant’s project folder that may or may not still exist in 2031.
Manual vs. Origo: a direct
comparison
| Factor | Manual / Consultant | Origo |
|---|---|---|
| Time to first DDS | 6-8 weeks | 1-2 weeks (setup) + 24 hours |
| Cost per DDS | EUR 20,000-50,000 (consultant) | EUR 75-150 per DDS |
| Agroforestry handling | No Colombia-specific validation | IDEAM-calibrated SHACL validation |
| 5-year archive | Operator’s responsibility | Automated, included |
| Scalability | Linear cost increase per origin | Marginal cost per additional DDS |
| TRACES API readiness | Manual upload only | API-ready when TRACES opens |
The difference is not just cost. It is whether your compliance
process can operate at the speed and scale that ongoing trade requires.
A consultant engagement produces one DDS for one shipment. Origo
produces a continuous compliance capability.
Start your DDS preparation now on the Origo platform.
