EUDR Risk Assessment — Methodology and Criteria

Risk Assessment Under EUDR

Risk assessment is the central step of the due diligence system. Article 10 of Regulation (EU) 2023/1115 defines the criteria that operators must analyze.

Country Benchmarking

The European Commission will classify countries (or regions within them) into three risk categories:

Category	Implications
Low risk	Operators may apply a simplified due diligence procedure. Data collection and assessment obligations are reduced.
Standard risk	The full due diligence procedure applies, following all three steps.
High risk	Additional verification obligations. Competent authorities will carry out more frequent checks (9% of operators).

Until the official benchmarking is published, all countries are considered standard risk.

Risk Assessment Criteria

The assessment must cover the following criteria (Article 10(2)):

1. Risk of deforestation or forest degradation in the production area — based on satellite data, scientific reports, and official statistics on forest cover change.
2. Risk of non-compliance with the country of production's legislation — including land tenure rights, environmental regulations, labor rights, and indigenous peoples' rights.
3. Supply chain complexity — the number of intermediaries, mixing points, changes of ownership. The longer the chain, the more difficult traceability becomes.
4. Risk of fraud or circumvention — supplier track records, non-compliance reports, alerts from monitoring systems.
5. Prevalence of armed conflict or instability in the production area.
6. Existence of international sanctions applicable to the country or region of production.

When Is Risk Negligible?

Risk may be considered negligible when:

• Geolocation data is complete and verifiable.
• Satellite imagery analysis confirms the absence of deforestation on the relevant plots after 31 December 2020.
• Country of production legislation is respected, with documentary evidence.
• The supply chain is transparent and verifiable.
• There are no contrary indications from public sources or third-party reports.

If any of these conditions is not met, the risk cannot be considered negligible and the operator must apply mitigation measures.

Risk Assessment Tools

The following public sources can be used as part of the assessment:

• Global Forest Watch — satellite data on forest cover loss at the global level.
• JRC Tropical Moist Forest — data from the EU Joint Research Centre on tropical moist forests.
• Transparency International CPI — the Corruption Perceptions Index for governance risk assessment.
• FAOSTAT — statistics on the production and trade of agricultural and forestry commodities.
• EU Information System — once operational, it will include reference data for country benchmarking.

Documenting the Assessment

The risk assessment must be documented and retained for a minimum of 5 years. Documentation should include: data sources consulted, methodology applied, conclusions for each criterion analyzed, and the final decision. This documentation may be requested by competent authorities during inspections.

See the compliance checklist for a summary of all documentation requirements.