Do Retailers Need Their Own EUDR Compliance Solutions

Can Retailers Rely Solely on DDS References from Upstream Suppliers? Not entirely. While upstream DDS references are important, retailers still hold responsibility under EUDR depending on how they’re classified in the supply chain particularly if they are the first to place the product on the EU market or sell under their own-label/private brand. 

Retailers are no longer shielded from the supply chain. Under EUDR, liability for due diligence no longer stops at the importer or producer—it extends up the value chain. If a product on your shelves cannot be proven to be deforestation-free and compliant with EUDR standards, you can be held accountable. This regulation demands that every actor placing products on the EU market must demonstrate traceability to the plot of land and a risk assessment for deforestation. 

In essence, if you’re selling a chocolate bar, a wooden chair, or packaged meat, your brand is now part of the deforestation conversation. And so are your compliance responsibilities. 

Many retailers assume that relying on suppliers’ due diligence systems (DDS) or traceability tools absolves them of responsibility. But this is a dangerous oversimplification. Suppliers can support your process, but they cannot submit for you. You can’t simply “pass the paperwork” upstream anymore—regulators want proof at every level, and ignorance is not a defense. 

Key Takeaways 

Under the EU Deforestation Regulation (EUDR), Due Diligence Statements (DDS) must be submitted by operators placing products on the EU market. While retailers may rely on upstream DDS provided by importers or manufacturers, blind trust in these files is risky—especially when the retailer is also the brand owner or importer. 

Retailers are expected to verify supplier claims, monitor risks, and, in some cases, maintain their own compliance systems. This includes data on geolocation, deforestation status, and legality of production. 

An ideal retail compliance stack includes digital traceability tools, risk-scoring dashboards, document management, and auto-generated DDS reports. TraceX enables retailers to audit supplier DDS, track gaps in real time, and maintain continuous compliance across complex, multi-tiered sourcing networks. 

What does the Regulation Say about DDS? 

Under the EU Deforestation Regulation (EUDR), every operator placing a product on the EU market must submit a Due Diligence Statement (DDS). This isn’t optional. And it’s not something you can fully outsource. EUDR requires that each operator placing a product on the EU market must submit or reference a Due Diligence Statement (DDS) that proves deforestation-free and legal origin. 

What Goes Into a DDS? 

It’s not just a box-checking document. A DDS is a regulatory-grade submission that proves your product is: 

• Deforestation-free (using precise geo-coordinates, often at plot level) 

• Legally produced in its country of origin 

• Low-risk—with a clear, documented risk assessment to back that up 

This isn’t vague sustainability reporting. It’s evidence-based compliance, backed by data that can hold up to audits, inspections, and enforcement action. It’s what regulators will look at when evaluating whether your product should even be on the shelf. 

Who Counts as an “Operator” Under EUDR? 

If you are the one placing a product on the EU market—either through direct sale, distribution, or import—you are the operator. 

And that means you are responsible for submitting a DDS, even if your supplier provided a risk analysis or traceability tool. Suppliers can support you—but they can’t submit your DDS for you. The regulatory burden is now shared and personal.

The retailers and brands who treat DDS as a strategic tool rather than a compliance burden will earn faster market access, deeper customer trust, and a powerful ESG narrative that holds up in every boardroom. 

Explore our expert blogs that break down everything you need to know about due diligence and regulatory responsibilities: 

• EUDR Due Diligence Explained: What You Need to Collect and Prove 

• The Complete Guide to EUDR Compliance for Operators and Traders 

When can Upstream DDS  Be Used by Retailers 

Retailers can use an upstream DDS only for unaltered, branded goods with a valid, batch-specific DDS submitted in EU-TRACES. 
They must retain full traceability and verification access—otherwise, they must submit their own DDS. 

You Can Use an Upstream DDS—But Only If: 

1. The product is a branded good 
   You’re not altering or repacking it. You’re simply reselling it as-is, under the same brand. 

2. A valid DDS already exists in TRACES 
   TRACES is the EU’s centralized due diligence database. If your supplier has already submitted the DDS for that exact product and batch, you can reference it. 

3. The batch, product, and risk profile are identical 
   Same batch number, same packaging, same sourcing origin, same product category. If anything has changed—ingredient source, processing, labeling—you may no longer qualify to use the supplier’s DDS. 

4. You have full visibility and access 
   You can’t just take your supplier’s word for it. You need verifiable documentation, and the ability to trace the product back to the original DDS and prove its integrity. 

Why Blind Trust in Supplier DDS Is Risky 

Let’s say you trust your supplier—they’re reputable, certified, and tell you they’ve “got EUDR covered.” But: 

• Their DDS might only apply to part of the shipment 

• It might be outdated or never uploaded to TRACES 

• Their traceability system may not meet EUDR’s land-plot-level standards 

• You may be selling a repackaged version, which makes you the new operator 

When Retailers Must Have Their Own Compliance Systems 

Retailers must have their own EUDR compliance systems when selling private-label goods, multi-ingredient products, or direct imports from outside the EU. 
They are also responsible when product origin is unclear or when buyers demand traceability proof—making them the legal “operator” under the regulation. 

What Retailers Really Want 

Retailers aren’t trying to become traceability experts. What they do want is: 

• Low risk, legally compliant products 

• Streamlined onboarding for new SKUs 

• Confidence that their buyers, regulators, and customers trust their sourcing 

• A clear process that doesn’t bog down the team 

But today’s reality is that legacy sourcing playbooks no longer fit the EUDR era. And many current vendor workflows don’t provide the defensible, plot-level data regulators (and B2B buyers) now demand. 

You Must Have Your Own Compliance System When… 

1. You sell private-label or own-brand goods 

If your store’s name is on the packaging—or if you’ve commissioned the product—you are legally considered the operator under EUDR. This means you, not the manufacturer, must file the Due Diligence Statement (DDS). 

2. You sell multi-ingredient SKUs 

Think of a chocolate bar with cocoa, soy lecithin, and palm oil. Or a frozen meal with beef, rubber-packaged vegetables, and soy sauce. 
Each ingredient may have different origins, and some may be deforestation-risk commodities under EUDR. 

3. You import directly from outside the EU 

Even if you don’t manufacture the product, if your company imports it into the EU, you’re the first placer on the market. 
That makes you the operator—and you must submit the DDS. 

4. Your products are composite or have unclear origin 

Do your SKUs contain processed ingredients like “vegetable oil,” “natural flavoring,” or “mixed spices”? These kinds of catch-all terms often hide EUDR-risk ingredients like palm, cocoa, or soy. 

Without a solid traceability system, you can’t know whether: 

• The product needs a DDS 

• It passes the deforestation-free requirement 

• You’re opening yourself up to enforcement action 

Retailers relying on vague supplier specs or “certified” claims with no location data will be the first in the compliance hot seat. 

5. Buyers  are asking you for proof 

Retailers aren’t just accountable to regulators—they’re now under pressure from buyers, procurement teams, and investors who want documentation that goes beyond “we trust our suppliers.” 
The ask is becoming: 

• “Show me your geolocation proof” 

• “Do you have a system to manage DDS filings?” 

• “How do you verify legality and deforestation-free status?” 

A clear, retail-owned compliance system helps you respond with confidence instead of scrambling. 

What an Ideal Retail Compliance Stack Looks Like 

An ideal retail compliance stack includes supplier onboarding with geolocation capture, automated DDS generation, and satellite-based risk alerts. 
It enables real-time compliance tracking and ensures audit-ready accuracy across all EUDR-regulated products. 

The 4 Core Pillars of a Retail Compliance Stack 

1. Supplier Onboarding + Geo-Data Capture 

From day one, your system should require: 

• Farm or plot-level geolocation data (not just country of origin) 

• Source documentation on legality and land use 

• Automated flagging of missing or non-compliant fields 

2. DDS Generation or Validation Engine 

Your tech should be able to: 

• Automatically generate DDS per SKU or batch 

• Validate supplier-submitted DDS against your own standards 

• Store all documentation in an auditable, regulator-ready format 

3. Satellite Monitoring + Deforestation Risk Alerts 

Modern compliance isn’t static—it’s proactive. Your system should integrate: 

• Real-time or recent satellite imagery 

• Geo-matching to spot deforestation events linked to your sourcing plots 

• Automated alerts if a source shifts from “low” to “elevated risk” 

4. Dashboard for Tracking, Reporting & Audits 

A single-pane dashboard should show: 

• DDS status per SKU/batch 

• Commodity risk heatmaps 

• Audit trails and documentation for regulators, buyers, and internal teams 

The ideal compliance stack isn’t just about avoiding fines. It’s about: 

• Scaling private label with confidence 

• Securing shelf space in high-regulation markets 

• Turning supply chain integrity into a brand asset 

How TraceX Helps Retailers Stay Ahead of EUDR Compliance 

With the EU Deforestation Regulation (EUDR) raising the bar on supply chain transparency, retailers are under pressure to prove that every product they sell is deforestation-free and legally sourced. That’s where TraceX EUDR Compliance Platform  steps in—turning a complex regulatory burden into a streamlined, digital process. 

End-to-End Traceability 

TraceX captures real-time data from the source—down to the plot of land—giving retailers full visibility into commodity origin. Whether it’s cocoa, palm oil, or timber, TraceX ensures every ingredient is traceable to its source, a core requirement under EUDR. 

Automated Due Diligence Statement (DDS) Generation 

Say goodbye to spreadsheets and fragmented data. TraceX automatically compiles DDS using validated supplier information, risk assessments, and geolocation data—making your submissions fast, accurate, and audit-ready. 

Integrated Risk Monitoring 

With satellite imagery and real-time deforestation alerts built into the platform, retailers get proactive insights into sourcing risks before they become regulatory liabilities. This helps prioritize high-risk products and take corrective action early. 

Compliance Dashboard for Audits 

The TraceX compliance dashboard provides a single view of DDS status, supplier readiness, and risk exposure. It simplifies internal audits and makes it easy to respond to buyer queries or regulator inspections with confidence. 

Scalable for Private-Label and Multi-Ingredient SKUs 

For retailers managing complex product lines or own-brand sourcing, TraceX supports multi-origin tracking and layered risk validation—so even composite SKUs meet the EUDR’s high standards. 

The Bottom Line: Compliance Is Now a Retail Core Function 

Retailers are considered “operators” under EUDR if they place products on the EU market—especially own-label goods, direct imports, or multi-ingredient SKUs. This means they must implement their own compliance systems for due diligence, traceability, and DDS submissions. Supplier documentation alone is not sufficient; retailers are legally accountable and need audit-ready processes to meet EUDR standards. 

Frequently Asked Questions (FAQ’s)

Related Topics to Deepen Your EUDR Strategy 

How to File DDS for EUDR 

EUDR Requirements for Operators & Traders 

EUDR Country Risk Classifications 

EUDR Risk Assessment 

Supplier Assessment for EUDR