EU Deforestation Regulation simplified due diligence FAQ

Simplified due diligence changes only part of the EUDR due diligence system. Where relevant products are produced in a country or part classified as low risk under the Article 29 benchmarking system, operators are not required to carry out Article 10 risk assessment or Article 11 risk mitigation for that low-risk production, provided the Article 13 conditions are met.

The operator still needs to know the product, commodity, production origin, supplier chain, and EUDR role well enough to justify the simplified treatment. A low-risk benchmark is not a blanket exemption from Article 3, Article 4, Article 8, Article 9, or due diligence statement responsibility.

Article 13 simplified due diligence does not supersede Article 9. Operators still collect and keep the information and evidence needed to show the relevant product is deforestation-free, produced in accordance with the relevant legislation of the country of production, and traceable to the production origin required by the Regulation.

For downstream operators and traders, the record set also needs to preserve the Article 5 supply-chain information they must possess and keep, including supplier details and the due diligence statement reference number or simplified declaration identifier where the supplier is an operator.

Simplified due diligence is unavailable when the product is not produced in a country or part classified as low risk, when the operator cannot ascertain that production occurred in the low-risk area, or when the supply chain creates more than negligible risk of circumvention or mixing with products of unknown, standard-risk, or high-risk origin.

In those cases, the operator should treat the product under the ordinary due diligence route: collect Article 9 information, perform Article 10 risk assessment, and apply Article 11 risk mitigation before placing the product on the EU market or exporting it.

Because simplified due diligence depends on the Article 29 benchmark and on the facts of the supply chain, teams should review the simplification before each sourcing route, supplier change, origin change, or benchmark-status change. The record should show the current country-risk basis and the product-specific facts that support it.

Keep evidence in a form that can be produced to competent authorities on request. For operators, that means Article 9 information, the due diligence statement record, and the Article 13 documentation showing negligible circumvention or mixing risk. For downstream operators and traders, keep the Article 5 supply-chain information for the required retention period.