# What are the three steps of due diligence under the European Union (EU) Deforestation Regulation (EUDR), and which parts does an Indian supplier feed?

Canonical: https://senseible.earth/answers/eu-deforestation-three-due-diligence-steps-what-each-needs

The Commission lists three steps: collect the Article 9 information, assess risk, then mitigate it unless risk is negligible. Our reading: Indian suppliers feed in at Step 1, mainly plot geolocation, quantity and legality evidence. If the operator cannot collect the information, it must not place the product on the market.

## Step 1: collect information

The Commission says operators collect the Article 9 information, such as the commodity or product, the quantity, supplier, country of production and evidence of legal harvest. A key requirement is the geographic coordinates (geolocations) of the plots where the commodity was produced.

If the operator cannot collect the required information, it must not place the product on the EU market or export it.

Our reading: this is the step where a supplier is asked for data.

## Step 2: assess risk

The operator uses the Step 1 information to verify and evaluate the risk of non-compliant products entering the supply chain, using the Article 10 criteria. The Commission lists among them the presence of forests and indigenous peoples, prevalence of deforestation, complexity of the supply chain and strength of law enforcement.

Operators need to show how the information was checked against the criteria and how they decided the risk.

## Step 3: mitigate

Operators take adequate and proportionate measures to mitigate risk, "unless under step 2 they find no or only a negligible risk of non-compliance". The measures must make the risk negligible.

## When steps 2 and 3 fall away

If all relevant products come from low risk countries, the operator may skip steps 2 and 3 under simplified due diligence (Article 13). The page on India as a low risk country gives the conditions.

## No fixed checklist

The Commission says due diligence is "not a 'tick-box' process" and there is no fixed format or set list of questions. Operators must reach no, or negligible, risk before placing products on the market or exporting them. Our reading: two buyers can therefore send you different forms for the same crop.

## What Senseible does here

Senseible reads the HS code on each purchase invoice and keeps every invoice dated, so you can show your buyer what came in, from whom and when. Plot coordinates come from your growers and your buyer files the statement. We do not file statements or certify deforestation-free status.

- [What an Indian supplier gives the EU importer for the statement](https://senseible.earth/answers/eudr-due-diligence-statement-supplier-data)
- [India as a low risk country under EUDR](https://senseible.earth/answers/eudr-country-risk-category-india)
- [Polygon or single point for a plot](https://senseible.earth/answers/eudr-geolocation-polygon-or-point)
- [EUDR readiness: what applies to your goods](https://senseible.earth/eudr)

Sources: [European Commission Green Forum, Understand due diligence under the EU Deforestation Regulation](https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/understand-due-diligence_en), [European Commission Green Forum, EUDR country classification list](https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/eudr-cooperation-and-partnerships/country-classification-list_en)

Last reviewed 2026-11-05. Steps are as described on the Commission due diligence page. The page says to read it with the guidance, the Frequently Asked Questions (FAQs) and the legal text, so check those for your product.