What is the EUDR risk assessment and why does it matter?

The European Union Deforestation Regulation (EUDR) presents one of the most data-intensive compliance exercises companies have ever undertaken. This regulation requires traders and operators to prove that products on the EU market are deforestation-free and legally produced. 

A risk assessment sits at the core of the EUDR due diligence framework and determines the risk of a shipment. Companies need a clear view of where each product originates, linking each shipment to a specific plot of land and documented business practices. They need to demonstrate that production did not result in deforestation or violation of local and international laws after the 31 December 2020 cutoff date. The risk assessment is done on top of this data collection to ensure the risks are negligible. 

Many companies initially underestimate the level of detail required. They expect a simple document exchange, but the regulation requires detailed geolocation, reliable supplier data and a systematic risk assessment process that withstands regulatory standards. Data collection often has gaps, unclear land ownership and inconsistent supply chain documentation, which slow down compliance and increase risk exposure. 

Political uncertainty has created questions about the enforcement timeline, but the core obligation remains unchanged. If your company imports products into the EU, or if you are placing a new product in the EU market, you will need to collect granular data, validate it, and follow a structured method to determine risk. Even if enforcement shifts, expectations for transparency remain. Companies benefit from acting early so the process feels manageable rather than rushed.

Latest EUDR adjustments explained

The EU has introduced several updates in the past weeks, these directly influence how companies should structure and document their risk assessments. These updates focus on improving data completeness and tightening requirements for demonstrating negligible risk. This guide reflects the most recent updates, giving you an overview of the newest regulatory changes. 

Who benefits from this guide?

This guide is written for operators and importers who need clarity on how to identify their EUDR risks, define their data requirements, design a screening logic and determine the final risk per shipment.  Whether you are setting up your due diligence process, or stress-testing your risk assessment approach, this guide is built to support you, with the most up-to-date information. 

What are EUDR requirements for risk assessment and mitigation?

The EUDR sets clear expectations for how companies can assess and manage risks before placing products on the EU market. Article 9 defines what information operators should gather before assessing their risk. Article 10 is the analytical stage: operators must evaluate the data from Art.9 and determine whether there are any non-negligible risks. Risks are addressed and mitigated. If they cannot be mitigated,  the products cannot be sold on the EU market. 

Article 10 also states that countries ranked as “low risk” are exempt from the risk assessment. However, the initially proposed country risk tiers were rejected in July 2025. Now companies determine for themselves whether a full-scope risk assessment is required. Without benchmarking, country-risk assessments are more important. The country tiers are expected to return, but the timeline for implementation is still unknown.

In Article 10, the EU provides a non-exhaustive list of risks that must be considered. Coolset has sorted these into the following categories: 

1. Country-level risks: Forest presence trends, deforestation and degradation trends, environmental protection, corruption, land use
2. Supply chain-level risks: Number of intermediaries, processing complexity, risk of mixing, non compliant partners
3. Plot/supplier-level risks: Legal permits and titles, indigenous rights, endangered species, labor and human rights violations, deforestation history, poor harvest management
4. Documentation and conduct risks: Missing or unverifiable documents, supplier behavior, transparency issues, past EUDR misconduct

As soon as an assessment shows any indication of non-negligible risk, companies must spring into action. Sustainability teams must collect additional information and perform further verification as per Article 11, until they can confidently conclude that the risks are negligible or have been mitigated. If risks cannot be eliminated, the products unfortunately cannot be placed on the EU market. 

Step-by-step: How to conduct an EUDR risk assessment in 2026

The EUDR requires operators to follow a structured process to prove that risks linked to a product are negligible. This risk assessment process is aligned with Articles 9 and 10, which outline how authorities expect companies to perform thorough due diligence and prepare for EUDR. This step by step guide breaks down the steps for creating a robust risk assessment. 

Step 1: Identify the risks related to your case

EUDR does not provide us with an exhaustive checklist of risks. Instead, it sets a general direction. Your company is expected to identify and reduce your risks to a negligible level based on the specific products and supply chains involved. A good starting point is to understand what could realistically go wrong. 

Step 2: Understand the data requirements 

Once you know which risks apply to your case, you can work backwards: what data does your company need to assess each of these risks? To assess deforestation risks, common data requirements include plot polygons, production/harvest dates and historical land use. In relation to indigenous communities and local population, valuable insights can be whether there are indigenous populations nearby and if the producer collaborates appropriately with the indigenous community. Typical legal information are permits related to land ownership, evidence of compliance with environmental regulation and tax and customs forms.

For each risk, it helps to define a clear set of data points which you will use to evaluate them. When a shipment comes in, you will know exactly which information is missing and where your assessment might be weakest. 

‍Step 3: Create a risk assessment process and scoring logic 

With both risks and data requirements defined, you benefit from having a structured way to bring it all together. What criteria define low, medium and high risks? Assign scores and labels to each criterion so you can compare consistently.

Once you have scored all your criteria, it’s time to evaluate whether all risks have been reduced to a negligible level. The result cannot be an average which is “okay”, there has to be full certainty that no part of your supply chain carries any non-negligible risks. Beyond a risk logic, it is also important to define clear blocking conditions such as high deforestation risk, or allegations of human rights abuse. For medium or unclear risks, you can define extra steps to evaluate the risks involved. 

Step 4: Determine the final risk per shipment

Then it’s time to translate all the checks into a clear decision per shipment: is the risk really negligible or not? This means verifying the quality of the data and ensuring that there are no material issues left unsolved. It should be obvious when a shipment qualifies as negligible risk and when it doesn't without subjective judgement or complicated averages. 

‍Step 5: Create a repeatable and traceable process

The final step is to make sure that the risk assessments are done consistently across all shipments. Past risk assessments should also be kept on record for reference. Consider this step the bookkeeping of the EUDR risk assessments. 

What does an EUDR risk assessment look like? 

A compliant risk assessment breaks the risks down into various layers. With each layer you can focus on a different part of the product’s journey. Together, they offer a realistic view of whether a product might be linked to deforestation, illegal activities or human rights risks. 

‍Country-level risks

Country risks set the backdrop for the rest to follow. Even if one farm looks compliant, weak governance or high perceived corruption in the country of origin can rapidly increase uncertainty. Some practical examples are high deforestation rates with limited regulation and poor enforcement of human rights laws (indigenous and labor). 

Supply chain risks 

This layer examines how the product travels from the origin to the EU market. If supply chains are very complex with various intermediaries, companies may need to conduct deeper checks. Processing in a different country, or a product travelling through multiple traders prior to export are examples of risks in the supply chain. 

Plot/supplier risks 

This is the most granular part of the assessment. Companies have to consider the land use history of the plot, the legality of employment and land ownership, indigenous communities, endangered species, harvest management and more! A key no go is any sign of deforestation since 2020. Other examples which require further investigation include overlaps with indigenous territories, labor violations, unverified land titles and poor harvesting practices. 

Documentation and conduct risks

Even if all the technical data appears strong, supplier behavior significantly influences reliability. Expired certificates or unverifiable documents are signs that evidence from the supplier may not be good enough. Some key things to look out for include:

• Missing land titles or permits: suppliers claim documents were lost
• Opaque behavior: supplier avoids answering certain questions or uploads poor quality documents
• Previous concerns or investigations into EUDR-non-compliance
• Unverifiable certifications: unsuitable documents which are either expired or not adequate
• Inconsistent statements: supplier reports not mixing, yet their facility is known to process multiple commodities

What data to collect, verify and flag

The backbone of a compliant EUDR assessment is adequately conclusive and verifiable information for each batch that reaches the market. This doesn’t only mean collecting data but also ensuring its completeness and consistency. 

Data requirements

• Legal ownership requirements
• Geolocation coordinates
• Harvesting date and production stage
• Declarations from suppliers 
• Evidence of satellite monitoring or verification 

The data collection process depends on the coordination of multiple actors. Some key red flags that sustainability teams should watch out for are intermediaries who cannot fully trace their volumes, overlapping plots, missing data and inconsistencies between declarations. 

Companies can refer to FAO deforestation reports and the TRACES EUDR guidance for more information about traceability and plot verification. 

What mitigation measures to adopt when risk is non negligible

If risk assessments reveal anything above negligible risks, companies have to apply mitigation measures. Although EUDR doesn’t prescribe any specific steps, it does state that mitigation measures must “effectively eliminate” the identified risks. 

Some common mitigation measures include: 

• Requesting additional documentation from suppliers 
• Cross-checking geolocation with higher-resolution imagery 
• Conducting on-site audits where remote evidence is insufficient 
• Switching suppliers or regions when land-use evidence can’t be verified 
• Using remote sensing to confirm historical land cover 

Mitigation is only complete when all identified risks have been mitigated to a negligible level. If any doubts remain about the origin, legality, production or potential deforestation, the shipment cannot be placed on the EU market.

Businesses are encouraged to maintain detailed records of mitigation, including dates, communications, evidence gathered and risk conclusions. Just like maintaining sound financial records, clear documentation helps demonstrate that companies are complying during inspections. Structured checklists can help organize this process, to make sure no elements are forgotten.

How software helps automate EUDR risk checks

In-scope companies can use software to assess and mitigate EUDR risks efficiently as part of the overall due diligence process. Software validates geolocation and supplier data, highlights gaps and gives clear visibility to spots where issues hide. This makes it easier for operators and importers to understand which plots and suppliers require most attention.

Coolset provides all these capabilities plus the functionality needed for reliable, audit-ready risk mitigation. Geospatial monitoring surfaces potential deforestation around reported plots, structured supplier workflows help close data graphs quickly and automated consistency checks ensure submissions meet the latest EUDR expectations. Once risks are resolved, Coolset generates a due diligence statement for each shipment, keeping a fully traceable record for future checks. 

If you want to see how this works in practice, reach out to us! 

FAQ

How do I know if my geolocation data is good enough?

Good geolocation data should clearly identify plot boundaries, match satellite imagery with the pot and make direct links to the product batch. Some major red flags are incomplete coordinates, inconsistent plot sizes or boundaries and mismatched dates. Validation tools and software are helpful to ensure accuracy. 

What if my supplier refuses to provide full traceability? 

EUDR requires plot-level traceability. If suppliers withhold data, or cannot provide the data required, operators should escalate the case. Escalation means requesting missing files and applying mitigation measures. If suppliers can’t comply, operators may need to consider switching suppliers.

Is country risk still relevant after the recent EU vote? 

Yes! Without official risk tiers, operators need to determine the country's risk themselves. Governance, enforcement, deforestation trends and land-use laws all influence country risk scoring. Strong country assessments are the foundation for EUDR, as they determine how deep the due diligence process needs to go. 

How do I link my risk assessment to the EUDR due diligence statement?

If the assessment shows negligible risk, operators submit a due diligence statement in TRACES. The statement must reference the documented assessment, including data sources, geolocation data and evidence of mitigation actions. 

What tools do I need to track mitigation measures for EUDR?

Tools that centralize data, flag inconsistencies and store mitigation records help maintain an audit-ready trail. Software platforms track documentation, validate geolocation, highlight suppliers gaps and generate structured reporting for authorities.