Simplified due diligence and low-risk countries

10.1 The Article 13 regime

Operators sourcing entirely in low-risk countries or parts of countries do not have to comply with Articles 10 and 11 (risk assessment and mitigation), provided that, having assessed the complexity of the chain and the risk of circumvention or of mixing with products of unknown origin or from standard- or high-risk countries, they satisfy themselves that all products came from low-risk areas. They must keep documentation attesting to that negligible risk of circumvention and mixing (Article 13(1)).

They remain obliged to:

• carry out due diligence under Article 8;
• meet all the information requirements of Article 9 — geolocation included (FAQ 1.28);
• maintain a due diligence system (Article 12).

If information pointing to risk emerges — including a substantiated concern — the operator returns to full compliance with Articles 10 and 11 and immediately informs the competent authority (Article 13(2)). Products from standard- or high-risk countries processed in a low-risk country in order to "launder" their origin are treated as circumvention and require immediate measures by the authorities (Article 13(3)).

A ban on using simplified due diligence is one of the penalties available for serious or repeated infringements (Article 25(2)(f)).

10.2 What this means for buyers from Brazil