EUDR simplified due diligence Article 13 low-risk countries

EUDR Simplified Due Diligence (Article 13): What You Can Skip - and What You Can't

Last updated · July 30, 2026

If your supply chain runs through the United States, Canada, China, Japan, or any EU Member State, you've probably heard that you qualify for "simplified due diligence" under the EUDR. That sounds like good news - and it is. But it's also one of the most misunderstood phrases in the regulation.

Simplified does not mean optional. It does not mean exempt. And it definitely does not mean you can skip the due diligence statement.

This guide explains precisely what Article 13 simplified due diligence removes from your workload, what it leaves firmly in place, and the one operational trap - mixed origins - that can pull you straight back into full due diligence even when you thought you were in the clear.

The Benchmarking System: Where You Stand

Before Article 13 applies to you at all, you need to know your country's classification. Commission Implementing Regulation (EU) 2025/1093, adopted on 22 May 2025, formally established the three-tier country benchmarking system.

The results:

140 countries are classified as low risk, including all EU Member States, the United States, Canada, China, and Japan. Around 50 countries are standard risk, including Brazil, Indonesia, and Malaysia. Four countries - Russia, Belarus, Myanmar, and North Korea - are designated high risk.

If your commodities are produced exclusively in low-risk countries, Article 13 applies to you. If your supply chain touches any standard- or high-risk country - even partially - you're back to full due diligence for that portion of your sourcing.

You can check any country's current classification on our EUDR country risk list.

The benchmarking list is not permanent. The Commission is required to review classifications periodically, and a country's tier can change. Build your compliance system around the process, not just the current list — so you can adapt quickly if a key sourcing country moves tiers.

The Core Relief: What Article 13 Actually Removes

The EUDR's standard due diligence framework has three sequential steps: information collection (Article 9), risk assessment (Article 10), and risk mitigation (Article 11). Under full due diligence, you must complete all three before placing a product on the EU market.

Article 13 removes the middle two steps - but only the middle two.

Simplified due diligence means you must still collect all information required under Article 9 (geolocation, production dates, legality documentation, etc.), and you are not required to carry out risk assessment (Article 10) or risk mitigation (Article 11) - unless you obtain or become aware of information indicating a risk of non-compliance.

In practical terms, Articles 10 and 11 are where the heaviest analytical work lives: verifying satellite imagery against deforestation databases, cross-referencing legal land-use records, commissioning third-party audits, and documenting risk mitigation measures. The EUDR due diligence framework consists of three core elements: information gathering, risk assessment, and risk mitigation - and the simplified due diligence procedure affects only the second and third components.

That's a meaningful reduction in workload. But the first component - information collection - remains fully intact.

What You Must Still Do: The Non-Negotiable Obligations

This is where many operators get caught out. They hear "simplified" and assume the paperwork burden disappears. It doesn't. Here is what Article 13 leaves completely unchanged:

1. Full Article 9 Information Collection - Including Geolocation

Operators sourcing from low-risk countries of production must still collect all information listed under Article 9(1), including all plot-level geolocations and the date or time of production.

Operators would still need to provide geolocation coordinates for plots of land where commodities were produced. There is no geolocation waiver for low-risk sourcing. Every farm, plantation, or forest plot in your supply chain still needs to be mapped.

The Commission's updated Guidance Document (3rd edition, 4 May 2026) does offer one clarification that eases the legality documentation burden: for supply chains, production areas, and countries of production where an initial examination of available information indicates a negligible risk of non-compliance with Article 3(b) (legality), operators are not required to carry out in-depth data collection. Specifically, they should not be required to systematically collect comprehensive legal documentation for each individual plot of land or obtain specific document types such as individual land titles.

Additionally, for operators benefitting from simplified due diligence under Article 13, the requirement to provide "adequately conclusive and verifiable information" that products are deforestation-free can now be fulfilled simply by collecting geolocation coordinates (or postal addresses for MSPOs), without additional independent verification of the information's substance.

2. The Mixing and Circumvention Assessment - Before You Apply Article 13

This is the step most operators overlook, and it's built directly into the text of Article 13 itself.

Article 13 states that operators shall not be required to fulfill the obligations under Articles 10 and 11 where, after having assessed the complexity of the relevant supply chain and the risk of circumvention of this Regulation or the risk of mixing with products of unknown origin or origin in high-risk or standard-risk countries, they have ascertained that all relevant commodities and relevant products have been produced in countries classified as low risk.

In other words, the mixing and circumvention check is a prerequisite for applying simplified due diligence - not something you can skip because you're in the simplified lane. Operators must also be prepared to make any relevant documentation proving that there is negligible risk of mixing or circumvention of the law available to competent authorities in the event of an audit.

3. A Due Diligence Statement (DDS) - Still Required

This is the single biggest misconception about Article 13. Companies must continue to collect and document the required information and submit a due diligence declaration (DDS). While operators sourcing from low-risk countries still must submit a DDS to EU TRACES as the primary upstream operator, they do not need to conduct deforestation analysis on those polygons nor do they need to conduct a full legality risk assessment unless they obtain or are made aware of information that would point to a risk that the relevant products do not comply with the EUDR.

Simplified due diligence reduces the assessment and mitigation burden. It does not remove the obligation to exercise due diligence and submit a statement before placing products on the EU market.

4. Vigilance on Substantiated Concerns

Operators must respond to substantiated concerns or credible information that points to a risk that the products they are sourcing are not EUDR-compliant. This may also require communicating the relevant information to a competent authority.

A low-risk country classification is a starting point, not a permanent shield. If a credible NGO report, a supplier audit finding, or a competent authority alert raises questions about your specific supply chain, you cannot simply point to the country tier and walk away.

Side-by-Side: What Changes, What Stays

Obligation	Full Due Diligence (Standard/High Risk)	Simplified Due Diligence (Low Risk, Article 13)
Article 9 information collection (incl. geolocation)	✅ Required	✅ Required
Article 12 due diligence system	✅ Required	✅ Required
Mixing & circumvention assessment	✅ Required	✅ Required (prerequisite for Article 13)
Due diligence statement (DDS) submission	✅ Required	✅ Required
Article 10 risk assessment	✅ Required	❌ Not required (unless concerns arise)
Article 11 risk mitigation measures	✅ Required	❌ Not required (unless concerns arise)
Respond to substantiated concerns	✅ Required	✅ Required
Competent authority check rate	3% (standard) / 9% (high)	1%

The Mixing Trap: Why Blended Origins Are Dangerous

The most operationally significant risk in Article 13 is the mixing problem. It catches operators who source primarily from low-risk countries but whose supply chains include even a small volume from standard- or high-risk origins.

Mixed or unclear origins trigger full due diligence for the entire shipment. Not just the portion from the higher-risk country - the whole thing.

To ensure there is negligible risk of mixing, operators must first assess the complexity of the supply chain for their products. This can be achieved by mapping the supply chain upstream from finished goods back to raw material while collecting transportation and payment records - otherwise known as chain of custody documentation - as a means of verifying each step.

This is particularly relevant for processed or derived products - chocolate, rubber compounds, wood panels, blended oils - where raw materials from multiple origins are combined before reaching the EU. Derived products are in scope for EUDR if they share an HS code listed in Annex I of the adopted text. Many derived products may have a high likelihood of being produced using commodities from several countries rather than a single country of origin.

The Commission's guidance also clarified that simplified due diligence applies only where relevant products have been produced exclusively in low-risk countries. A single unverified origin in your supply chain is enough to disqualify the entire shipment from Article 13.

The 'exclusively' requirement is strict. If you cannot confirm that every gram of a commodity in a product was produced in a low-risk country — with documentation to prove it — you cannot apply simplified due diligence. When in doubt, treat the shipment as standard risk and run the full process.

What Triggers a Fall-Back to Full Due Diligence

Even if you've correctly applied Article 13 from the start, certain events require you to revert to full due diligence:

Substantiated concerns or credible information indicating that products in your supply chain may not comply with the EUDR - regardless of the country's risk tier.
Evidence of mixing with products of unknown origin, or origin in standard- or high-risk countries.
A country reclassification - if a key sourcing country moves from low to standard risk in a future benchmarking review, your simplified due diligence entitlement disappears with it.
Circumvention indicators - signs that products are being routed through low-risk countries to obscure their true origin.

Operators must be prepared to conduct full due diligence, even when sourcing from a low-risk country of production. This would be required where mixing or circumvention risks are identified, or where credible information is contrasting with the low-risk status of the country.

A Special Note for Micro and Small Primary Operators

If you are a micro or small primary operator established in a low-risk country, there is an additional simplification available to you. Micro and small primary operators who produce relevant products in low-risk countries are now only required to produce and submit a one-time simplified declaration to the EU's TRACES portal, rather than a full DDS for every shipment.

This is a meaningful administrative relief - but it applies only to primary operators (those who first place the product on the market) established in low-risk countries. It does not apply to EU-based importers sourcing from low-risk countries.

Application Dates

The EUDR applies from 30 December 2026 for large and medium operators, and from 30 June 2027 for micro and small operators and natural persons. These dates apply regardless of whether you are using full or simplified due diligence.

Use the time between now and your deadline to build the systems - geolocation collection, supplier data requests, DDS submission workflows - that Article 13 still requires.

Your Article 13 Simplified Due Diligence Checklist

Use this before placing any product on the EU market under simplified due diligence:

Confirm exclusive low-risk origin

Verify that every commodity in the product was produced in a country classified as low risk under Commission Implementing Regulation (EU) 2025/1093. Check the EUDR country risk list. If any origin is standard or high risk, stop — full due diligence applies.

Collect all Article 9 information

Gather the full set of required information: supplier name and address, country of production, quantity, HS codes, and — critically — plot-level geolocation coordinates (latitude/longitude polygons or points) for every farm or forest area. Production dates or time ranges are also required.

Assess mixing and circumvention risk

Map your supply chain from finished product back to raw material. Collect chain-of-custody documentation (transport records, payment records, processing certificates) to demonstrate that no mixing with standard- or high-risk origins has occurred and that the supply chain has not been structured to circumvent the regulation.

Document your negligible-risk finding

Create a written record — a due diligence report — that captures your mixing and circumvention assessment and your conclusion that negligible risk exists. This documentation must be available to competent authorities on request.

Submit your Due Diligence Statement (DDS)

Submit the DDS via the EU TRACES system before placing the product on the EU market or exporting it. Include the geolocation data for all production plots. Retain the DDS reference number and all supporting documentation for at least five years.

Stay alert to substantiated concerns

Monitor for any credible information — NGO reports, supplier alerts, competent authority notices — that could indicate non-compliance in your supply chain. If such information emerges, revert to full due diligence (Articles 10 and 11) immediately.

Not Sure Which Procedure Applies to You?

The right due diligence path depends on your role in the supply chain, your company size, and where your commodities are produced. Our free Obligations Checker walks you through all three variables and tells you exactly what applies to you - in plain English, in under two minutes.

The Bottom Line

Article 13 simplified due diligence is a genuine and meaningful relief. Skipping the Article 10 risk assessment and Article 11 mitigation measures removes the most analytically intensive parts of the compliance process - the satellite imagery checks, the deforestation database cross-referencing, the formal risk mitigation documentation.

But the foundation remains. Geolocation collection, the mixing and circumvention check, the due diligence statement, and ongoing vigilance are all still required. Low-risk does not mean zero-effort, as sourcing from low-risk countries of production is not a guarantee of legal compliance.

Build your Article 13 process properly - and document it - and you'll have both the compliance relief the regulation offers and the audit trail to prove you earned it.