EUDR Article 13 simplified due diligence: what to skip

Article 13 simplified due diligence removes exactly two steps for products sourced entirely from a low-risk country: the risk assessment in Article 10 and the risk mitigation measures in Article 11. Everything else — collecting the Article 9 information, confirming the product is deforestation-free, and filing a due diligence statement — still applies, whatever tier the country sits in.

What Article 13 actually removes

Article 13 is a derogation from two specific articles, not a general exemption. Where every relevant commodity in a consignment was produced in a country, or part of a country, that Commission Implementing Regulation (EU) 2025/1093 classifies as low risk, the operator is not required to carry out:

• The risk assessment under Article 10(2) — the documented analysis weighing deforestation and degradation rates, prevalence of forest in the country or region, production and trade trends, indigenous peoples' and local communities' rights, corruption and governance indicators, supply chain complexity, and circumvention risk such as transhipment through a third country.
• The risk mitigation measures under Article 11 — the additional information, independent surveys, audits or other procedures an operator would otherwise have to put in place wherever the Article 10 assessment finds anything above negligible risk.

That is the whole derogation. It removes the analysis and the response to that analysis. It does not touch the information-gathering step that comes before it, or anything that comes after.

The saving is real where it applies. A documented risk assessment under Article 10 — weighing deforestation rates, governance indicators and supply chain complexity against a specific shipment — is the single most time-consuming part of due diligence for most operators, well ahead of collecting geolocation or filing the statement itself. Skipping it for a genuinely low-risk, segregated supply chain is a meaningful reduction in compliance work. It is just a narrower reduction than the word "simplified" suggests to anyone who has not read Article 13 itself.

What stays, whatever the country's tier

Four obligations apply to every relevant product regardless of risk tier, including products from low-risk countries and from EU member states themselves:

• Article 9 information collection. Product description and quantity, the country (and, where applicable, the specific plot) of production, supplier details, and geolocation of every production plot — points for areas up to 4 hectares, polygons above that.
• Confirmation the product is deforestation-free. The commodity must have been produced on land that has not been subject to deforestation or forest degradation after 31 December 2020.
• Confirmation of legal production. The product must have been produced in accordance with the relevant legislation of the country of production — land use, environmental, labour and tax law, among others.
• A due diligence statement, filed through the EU Information System (TRACES) before the product is placed on the market or exported. Low risk changes nothing about this requirement; it changes how much analysis sits behind the statement you file.

Record-keeping follows the same rule. Whatever a low-risk operator still holds — geolocation data, supplier contracts, the due diligence statement itself — has to be kept for at least five years, the same as under full due diligence. Simplified due diligence does not simplify what you retain, only what you had to produce in the first place.

The checklist, side by side

Step	Full due diligence (standard/high risk)	Simplified due diligence (Article 13)
Collect Article 9 information	Required	Required
Geolocation of every plot	Required	Required
Confirm deforestation-free after 2020-12-31	Required	Required
Confirm legal production	Required	Required
Risk assessment (Article 10)	Required	Not required
Risk mitigation measures (Article 11)	Required if risk found	Not required
File due diligence statement in TRACES	Required	Required
Keep records for 5 years	Required	Required
Act on reason to believe non-compliance	Required	Required

The rows that disappear are the two in the middle. Everything above and below them is identical work.

The "reason to believe" trap

Simplified due diligence is conditional, not automatic. An operator loses the right to rely on Article 13 for a specific consignment the moment it has reason to believe — or receives credible information, including a substantiated concern submitted by a third party — that the product may not comply, whatever the country's benchmarked tier. At that point the operator has to carry out full due diligence on that consignment, including the risk assessment and any mitigation it points to, before placing the product on the market.

This matters because low-risk status is a country-level default, not a guarantee about any individual supplier. A low-risk country with one supplier under credible scrutiny for illegal logging does not let that supplier's buyer rely on Article 13 for that specific relationship, even though every other shipment from the same country still qualifies.

Mixed-origin consignments: one plot ruins the simplification

Simplified due diligence applies only to the portion of a consignment that is shown to come entirely from a low-risk origin. It is not a blended average. If a shipment combines a relevant commodity from a low-risk country with the same commodity from a standard- or high-risk country — a common pattern in commodities bought from traders who blend lots from multiple origins, such as coffee or cocoa — the whole consignment falls into full due diligence. One standard-risk plot in the mix is enough; there is no partial credit for the low-risk share.

In practice this means simplified due diligence is only genuinely available to operators who can show segregated, traceable sourcing from low-risk origins alone. An operator who cannot evidence that every plot behind a shipment sits in a low-risk country should assume full due diligence applies and cost the extra risk assessment work in, rather than claim the simplification and risk a competent authority finding the claim unsupported at inspection.

Who actually gets it — and who gets something narrower instead

Article 13 is open to any operator or trader, of any size, sourcing from a low-risk country. It has nothing to do with headcount or turnover. A large multinational buying exclusively from low-risk origins gets exactly the same reduction in work as a five-person importer doing the same.

That is a different, wider rule than the one-time simplified declaration created by Article 4a for micro and small primary producers, which depends on size and role as well as country. EUDR micro and small operator simplifications sets out how the two interact and why qualifying for one does not mean you qualify for the other. EUDR country benchmarking explained has the current list of which countries sit in which tier, and how that list can change.

Do not confuse simplified due diligence with the lower inspection rate low-risk sourcing also carries. Article 16 sets minimum annual check rates of 1% of operators for low-risk-country products, against 3% for standard risk and 9% of operators plus 9% of volume for high risk. That lower check rate is a separate consequence of the same benchmarking list — it affects how often an authority is likely to look at your filings, not what you had to do to produce them. An operator relying on Article 13 should assume any given shipment could still be the one checked, and keep its eligibility evidence ready regardless of how unlikely a check statistically is.

Proving eligibility, not just claiming it

Skipping the risk assessment does not mean skipping the evidence that you were entitled to skip it. A competent authority checking a due diligence statement filed under Article 13 will expect to see, on request:

• Documentation tying the specific plots behind the consignment to the country's current low-risk classification at the time the product was placed on the market — not at the time a contract was signed, since the applicable tier is the one in force on the placing date.
• Evidence the consignment was not mixed with output from a different origin — segregation records, batch tracing, or supplier attestations covering the specific shipment.
• A record of how the operator established it had no reason to believe the product might not comply, even though no formal risk assessment was carried out.

The five-year record-keeping rule applies to this material exactly as it does to a full risk assessment file.

When the country's tier changes under you

The low-risk list is reviewed periodically and can move a country into the standard or high tier with limited notice once a revision is formally adopted. Eligibility for Article 13 is assessed against the classification in force when the product is placed on the market, not the classification that applied when the sourcing relationship was set up. A consignment placed on the market the day after a reclassification takes effect needs full due diligence, even if the same supplier relationship qualified for simplified treatment the week before. Operators sourcing a material share of volume from a single country should check the current classification before each filing cycle, not rely on a status recorded once at onboarding.

Checking what applies to you

Whether Article 13 is available to a specific product depends on where every plot behind it sits today, not on a general impression that "our supplier's country is fine." Run the free checker to get your deadline, your filing obligations, and whether your sourcing currently qualifies for simplified due diligence, based on your actual business rather than a rule of thumb.

Related reading: the Article 9 information checklist covers exactly what to collect regardless of tier, and EUDR risk assessment and mitigation covers what the two steps Article 13 removes actually involve, for anyone who doesn't qualify.