Due diligence system
Also known as: Article 12
Article 12 duty to establish, maintain and annually review a documented due diligence system — required at every country risk tier, including fully low-risk programmes.
What it means
The due diligence system is the written policies, controls and procedures that produce your plot data, assessments and filings. It is the obligation most low-risk programmes miss when they read “simplified” as “informal”.
In the regulation
Article 12 applies at low, standard and high risk alike. Simplified due diligence (Article 13) switches off Articles 10 and 11 under conditions; it does not switch off Article 12. Operators must still be able to show how the system works and review it at least annually.
How ERWAY treats it
The risk-tier obligation matrix on this site calls Article 12 the row most summaries leave out. Process packs and retained evidence in ERWAY are meant to make that system visible under a check.
Related terms
- Risk & benchmarking
Simplified due diligence
Article 13 path that switches off risk assessment and mitigation when every plot is low-risk and mixing/circumvention risks are negligible — it never switches off geolocation, the DDS, or Article 12.
- Risk & benchmarkingLow risk (country)
Low risk
Country benchmarking tier covering roughly 140 countries: Article 9 geolocation and the DDS still apply; Articles 10 and 11 may be skipped only under Article 13’s conditions; authorities check at least 1% of operators.
- Filing & enforcement
Due Diligence Statement
The filing by which the first-placing operator formally declares that due diligence was carried out and that risk is negligible — required at every country risk tier.
Keep reading
Risk & benchmarkingEUDR country risk classification: which obligations change, tier by tier
A complete tier-by-tier comparison of EUDR obligations: information collection, due diligence systems, risk assessment, mitigation, mixing rules, substantiated concerns and authority check rates.
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Risk & benchmarkingCountry benchmarking: what the risk tiers change, and what they don't
How EUDR country benchmarking works, what Implementing Regulation (EU) 2025/1093 classified, what simplified due diligence actually removes, and why the Parliament's objection changed nothing.
6 min read