If you buy from an EU supplier, you may not need to file a DDS at all

One of the more significant changes in the 2025 revision is also one of the least understood. If your business buys relevant products that another operator has already placed on the EU market, your position is materially different from that of the company that imported them.

You are not expected to file a fresh due diligence statement for those goods. You collect the reference number of the statement submitted upstream, retain it, and keep the supporting documentation. Non-SME downstream operators and traders still register.

Why this catches people out

Most guidance written before December 2025 assumes everyone in the chain files their own statement. Programmes that started from that assumption are aimed at the wrong output: building a way to submit, when the requirement is to collect, check and keep what suppliers give you.

These are not the same job. Submitting ends at the Information System and is under your control. Collecting ends in your own records and depends entirely on a supplier giving you a reference in a usable form, at the right time. The failure modes differ too. An unsubmitted statement is yours to fix. A missing supplier reference means chasing someone who considers the matter closed.

Where you sit in the chain

Whether you place products on the EU market for the first time, or receive goods already placed by someone else. Everything else follows from this.

Your size classification

SME status affects both registration and which application date applies to you.

Whether your suppliers can produce references

A supplier who cannot tell you their reference number today is a supplier you will be chasing in December.

Where references will live

A reference in an email thread is not a retained record. It needs to sit against the purchase order it belongs to.

Many businesses sit in both positions at once, importing directly for some lines and buying domestically for others. That is common, and it means whatever you build has to support both endings rather than assuming one.