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The 3-step due-diligence process

Art. 8(2) of Reg. (EU) 2023/1115 sets out a three-step due-diligence pipeline that every operator must run before placing a covered commodity on the EU market:

Information collection (Art. 9)
Risk assessment (Art. 10)
Risk mitigation (Art. 11), when the assessment finds more than negligible risk.

The DDS that goes to TRACES NT is the documented output of step 1, plus an operator statement that steps 2 and 3 (where applicable) returned a negligible-risk verdict.

Step 1. Information collection (Art. 9)

The operator must gather, document and retain (5 years) every input listed in Art. 9(1) for every consignment:

Art. 9(1) item	What it is	How it lands in our DDS
(a)	Operator information — name, address, EORI.	`1_operator` block.
(b)	HS code, product description (incl. trade name).	`2_product`.
(c)	Quantity (kg net or supplementary unit per Annex I).	`2_product.quantity_kg` + `supplementary_quantity`.
(d)	Country of production + geolocation of every plot + production time-range.	`3_geolocation` array; one entry per plot.
(e)	Information identifying the supplier (and producer where applicable): name, address, email.	Annex 9 row in the printable report.
(f)	Information identifying any operator or trader downstream that received the product.	Connector / shipment-export channel.
(g)	Verifiable information that the goods are deforestation-free.	The signed emem evidence chain in `source_receipts.emem`.
(h)	Verifiable information of compliance with country-of-production law.	The legality module + supplier certifications.

Step 2. Risk assessment (Art. 10)

The operator analyses the Art. 9 inputs against a non-exhaustive list of risk indicators set out in Art. 10(2):

Country / subnational risk classification (Art. 29 + Implementing Reg. 2025/1093).
Forest cover and forest change history of the plot.
Indigenous-peoples land-rights and FPIC concerns (Art. 10(2)(g)).
Substantiated concerns from third parties (Art. 10(2)(j) + Art. 31).
Complexity of the supply chain.
Co-mingling risk (mass-balance / origin commingling).

The output is a verdict: negligible or not negligible (or indeterminate, when evidence is insufficient).

Our engine implements the Art. 10 risk-assessment per /docs/theory/methodology. The verdict + its inputs are written into the receipt under conclusion + source_receipts.

Step 3. Risk mitigation (Art. 11)

Triggered only when Art. 10 returns "not negligible." The operator must apply adequate and proportionate mitigation procedures (Art. 11(1)). Examples:

Request supplementary information from the supplier.
Commission independent third-party verification of the plot.
Audit the supplier's own due-diligence process.
Adjust purchasing decisions.

After mitigation, the operator re-runs Art. 10. If the residual risk is now negligible, the consignment may be placed on the EU market. If not, the operator must refuse the consignment (Art. 4(1)).

Simplified due diligence (Art. 13)

Operators sourcing exclusively from low-risk countries (per the country benchmark. See country benchmarking) may skip Art. 10 and Art. 11.

They still owe:

The Art. 9 information-collection step (always).
The mixing / circumvention test. Confirming that no high-risk material was co-mingled into the consignment.
The DDS itself.

Simplified DD does NOT exempt the operator from the DDS-filing obligation; it only waives the assessment-and-mitigation steps.

When the verdict flips