# EUDR Risk Assessment: Article 10 Criteria, Negligible Risk and Substantiated Concerns

Last updated: 2026-11-03

> How EUDR risk assessment works: the 14 Article 10 criteria, what negligible risk means, low-risk countries, and what happens when someone files a concern.

Date: November 3, 2026

> Part of the [EUDR Guide](https://restorationscope.com/blog/category/eudr), step 4 of 5: review the evidence.

An EUDR risk assessment is the operator's check, before placing or exporting a product, that the risk it comes from land deforested after 31 December 2020, or breaks the producing country's relevant laws, is at most negligible. Article 10 lists 14 criteria; Article 11 covers mitigation while risk remains. Products only from low-risk countries can skip both once the operator has assessed chain complexity and the risk of circumvention or mixing, though not the data collection (Article 13). From 30 December 2026 (30 June 2027 for most micro and small operators), anyone can send authorities substantiated concerns they must assess.

This guide is for EU importers who do the assessment and for the coffee and cocoa exporters and cooperatives who supply the evidence. For the regulation as a whole, see [what is the EUDR](https://restorationscope.com/blog/what-is-eudr); for the full sequence of work, the [EUDR compliance checklist](https://restorationscope.com/blog/eudr-compliance-checklist).

**Checked 2 November 2026:** against [Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918) (consolidated text of 18 September 2026, which includes [2024/3234](https://eur-lex.europa.eu/eli/reg/2024/3234/oj) and [2025/2650](https://eur-lex.europa.eu/eli/reg/2025/2650/oj) and Delegated Regulation [2026/2102](https://eur-lex.europa.eu/eli/reg_del/2026/2102/oj)), the country list in [Implementing Regulation (EU) 2025/1093](https://eur-lex.europa.eu/eli/reg_impl/2025/1093/oj) (unamended), the Commission's [guidance](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52026XC03896) (C/2026/3896, 20 July 2026) and [FAQ](https://environment.ec.europa.eu/publications/faq-eudr-implementation_en) (version 5, April 2026), and its [review of 4 May 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52026DC0191). A plain-language summary, not legal advice.

## Where does risk assessment sit in EUDR due diligence?

It is the middle of three steps the operator repeats before placing or exporting each product (Article 8):

1. **Collect the information (Article 9).** The product, quantity, country, the geolocation of every plot with its date or time range of production, suppliers and customers, and "adequately conclusive and verifiable" evidence that it is deforestation-free and legal. Every operator does this step, including those using simplified due diligence.
2. **Assess the risk (Article 10).** Check that information against the criteria below and decide whether any risk of non-compliance remains. Skipped under simplified due diligence (Article 13).
3. **Mitigate it (Article 11).** If the risk is more than negligible, act until it is negligible. If it can't be brought down, the product isn't placed on the market or exported (Article 4(4)).

The operator then files a due diligence statement declaring that it found no or only a negligible risk (Article 4(2)); micro and small primary operators file a one-time simplified declaration instead (Article 4a). The [statement walkthrough](https://restorationscope.com/blog/eudr-due-diligence-statement-traces) covers that filing screen by screen.

## What does Article 10 ask the operator to weigh?

Fourteen criteria, "in particular", so the list is a floor (Article 10(2)). The Commission's guidance says operators tailor them to their products, write them into their due diligence system, and assess each source or geolocation separately when a product comes from several. Most of the evidence sits with the exporter or cooperative.

**[Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918): what the operator’s risk assessment weighs, in particular**

- **Country risk tier** ([Article 10(2)(a)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(a)-,the%20assignment%20of%20risk%20to%20the%20relevant%20country%20of%20production)): The risk tier of the country of production, or part of it, under Article 29. An exporter or cooperative can show: The tier in Implementing Regulation 2025/1093 for each country the lot comes from.
- **Forests** ([Article 10(2)(b)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(b)-,the%20presence%20of%20forests%20in%20the%20country%20of%20production)): The presence of forests in the country or area of production. An exporter or cooperative can show: Each plot over imagery from the end of 2020 and today, with the reason it passed.
- **Indigenous peoples** ([Article 10(2)(c)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(c)-,the%20presence%20of%20indigenous%20peoples%20in%20the%20country%20of%20production)): The presence of indigenous peoples there. An exporter or cooperative can show: Which plots lie in or next to indigenous territory, and the source used.
- **Consultation** ([Article 10(2)(d)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(d)-,the%20consultation%20and%20cooperation%20in%20good%20faith%20with%20indigenous%20peoples)): Consultation and good-faith cooperation with indigenous peoples there. An exporter or cooperative can show: Records of meetings, consent and agreements where they apply.
- **Claims to the land** ([Article 10(2)(e)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(e)-,the%20existence%20of%20duly%20reasoned%20claims%20by%20indigenous%20peoples)): Duly reasoned claims by indigenous peoples, based on objective and verifiable information, to use or ownership of the land. An exporter or cooperative can show: Known claims over the plots’ area, and what was done about each.
- **Forest loss in the area** ([Article 10(2)(f)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(f)-,prevalence%20of%20deforestation%20or%20forest%20degradation)): How common deforestation and forest degradation are there. An exporter or cooperative can show: Recent forest loss around the plots; plots near it get a closer look.
- **Reliable plot information** ([Article 10(2)(g)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(g)-,the%20source%2C%20reliability%2C%20validity%2C%20and%20links%20to%20other%20available%20documentation)): The source, reliability and validity of the Article 9 information, and its links to other documents. An exporter or cooperative can show: Who mapped each plot, when and how, and land documents that match the member.
- **Country concerns** ([Article 10(2)(h)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(h)-,concerns%20in%20relation%20to%20the%20country%20of%20production%20and%20origin)): Corruption, falsified documents and data, weak law enforcement, human rights violations, armed conflict, and UN Security Council or EU sanctions. An exporter or cooperative can show: Which documents can be checked against an official registry.
- **Supply chain complexity** ([Article 10(2)(i)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(i)-,the%20complexity%20of%20the%20relevant%20supply%20chain)): How complex the supply chain is and how processed the product, above all how hard it is to connect products to their plots. An exporter or cooperative can show: Every hand between plot and lot, and the link from each lot to its plots.
- **Circumvention and mixing** ([Article 10(2)(j)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(j)-,the%20risk%20of%20circumvention%20of%20this%20Regulation%20or%20of%20mixing)): The risk of circumvention, or of mixing with products of unknown origin or from areas where deforestation or forest degradation has occurred or is occurring. An exporter or cooperative can show: How lots are kept apart, and purchases from non-members or intermediaries.
- **Expert group conclusions** ([Article 10(2)(k)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(k)-,conclusions%20of%20the%20meetings%20of%20the%20Commission%20expert%20groups)): Conclusions of the Commission’s expert groups, as published in its expert group register. An exporter or cooperative can show: The operator follows these on the Commission’s expert group register.
- **Concerns and past breaches** ([Article 10(2)(l)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(l)-,substantiated%20concerns%20submitted%20under%20Article%2031)): Substantiated concerns, and past breaches of this regulation by operators or traders along the chain. An exporter or cooperative can show: Any concern received about you or your suppliers, and what you did.
- **Any other sign of risk** ([Article 10(2)(m)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(m)-,any%20information%20that%20would%20point%20to%20a%20risk)): Any information that would point to a risk that the products are non-compliant. An exporter or cooperative can show: For example, a member’s deliveries above what their mapped area can grow.
- **Certification and other schemes** ([Article 10(2)(n)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10:~:text=(n)-,complementary%20information%20on%20compliance%20with%20this%20Regulation)): Complementary information, such as from certification or third-party verified schemes, provided it meets the requirements of Article 9. An exporter or cooperative can show: Certificate scope and validity; supporting only, and only if it meets Article 9.

Wood products covered by a valid FLEGT licence from an operational licensing scheme count as legally produced (Article 10(3)); they still have to be deforestation-free. The operator documents the assessment, reviews it at least once a year and must "be able to demonstrate how the information gathered was checked against the risk assessment criteria" and how it set the level of risk (Article 10(4)).

## What does "negligible risk" mean?

Article 2(26) defines it: after "a full assessment of product-specific and general information" and any mitigation needed, the products show "no cause for concern" of not being deforestation-free or legal. Four points follow from the Commission's guidance and FAQ:

- **There is no threshold.** The regulation sets no score or percentage. The operator judges each case, and the guidance says the level of risk "can only be assessed on a case-by-case basis".
- **One weak criterion is enough.** If, after any mitigation, any criterion still shows a non-negligible risk, the product carries a non-negligible risk and can't be placed or exported (guidance, section 4(b)).
- **Gaps can count as risk.** "Unidentified steps in the supply chain" can lead to the conclusion that the risk is non-negligible (guidance, section 5).
- **It is a result, not a status.** No commodity, and no commodity from a given country, is negligible risk in itself; the only way to reach it is due diligence (FAQ 5.10 and 5.11).

Deforestation is not a matter of degree: if forest on a plot was converted to farming after 31 December 2020, everything grown there is disqualified (Articles 2(13) and 9(1)(d)), and so is any lot it was mixed into that can't be separated again (FAQ 1.5). Shade trees cleared on land that was already an agroforestry coffee or cocoa plantation at the end of 2020 are a different question: agricultural plantations, agroforestry included, aren't forest (Article 2(6)). Coffee grown in small amounts under natural forest is still forest, and so is any forest patch inside a farm (guidance, section 11).

## What counts as risk mitigation under Article 11?

Measures "adequate to achieve no or only a negligible risk", taken before placing or exporting the product (Article 11(1)). They may include:

- Asking for more information, data or documents, such as a land title or a remapped boundary.
- Independent surveys or audits, such as a field visit to a flagged plot.
- Other measures on the Article 9 information, such as leaving out the coffee of a plot that was kept separate.
- Supporting suppliers, "in particular smallholders", through capacity building and investment.

Every operator outside simplified due diligence also needs policies, controls and procedures to manage these risks: risk management, reporting, record-keeping, internal control and compliance management. Operators that aren't SMEs must also appoint a compliance officer at management level and have an independent audit function that checks those policies, controls and procedures (Article 11(2)). Every mitigation decision is documented, reviewed at least yearly and shown to authorities on request (Article 11(3)).

## How does country benchmarking change the work?

Article 29 sorts countries into three tiers by the risk of producing commodities that are not deforestation-free. The Commission's list, [Implementing Regulation (EU) 2025/1093](https://eur-lex.europa.eu/eli/reg_impl/2025/1093/oj) of 22 May 2025, rates whole countries; any country it doesn't list is standard risk.

| Tier | Countries (examples) | Due diligence | Companies checked a year (minimum) |
| --- | --- | --- | --- |
| Low | Vietnam, India, Ghana, Costa Rica, Dominican Republic, Kenya, Rwanda, Papua New Guinea | Simplified due diligence may apply | 1% |
| Standard | Brazil, Colombia, Peru, Honduras, Ethiopia, Uganda, Côte d'Ivoire, Indonesia | Full risk assessment and mitigation | 3% |
| High | Belarus, Myanmar, North Korea, Russia | Full risk assessment and mitigation | 9% |

The low and standard rows are a selection of coffee and cocoa producers from the 2025 list; the high row is all of it. Authorities pick whom to check by risk criteria that always include high-risk origin, and for high-risk countries they also check 9% of the quantity of each product (Article 16). Check rates are per commodity, and count operators plus downstream operators and traders that aren't SMEs who, the year before, placed, supplied or exported products containing that commodity from a country in that tier (Article 16(8) to (11)). Exporters outside the EU aren't counted unless they place goods on the EU market themselves, but a check on their buyer can reach their records and, with their country's agreement, their plots (Article 18(2)(e)). The tiers come mainly from the rate of deforestation and forest degradation, the expansion of farmland for the commodities and production trends, using FAO's Global Forest Resources Assessment (Article 29(3), recitals of 2025/1093). The list can be updated "as often as necessary"; as of 2 November 2026 EUR-Lex shows no amendment.

**Simplified due diligence (Article 13).** An operator skips Articles 10 and 11 only after checking the supply chain's complexity and the risk of circumvention or of mixing with products of unknown, standard-risk or high-risk origin, and establishing that everything was produced in low-risk countries. On request, it shows the authority documents that the risk of circumvention or mixing is negligible. Three things don't change:

- **The data.** Article 9 still applies in full, plot geolocation included (micro and small primary operators may give postal addresses instead, Article 4a(5)); the FAQ says collecting it can meet the deforestation-free evidence requirement for a low-risk lot.
- **A concern switches it off.** Any information pointing to a risk, substantiated concerns included, brings back the full assessment and mitigation, and the operator must tell the authority at once (Article 13(2)).
- **Processing elsewhere isn't a shortcut.** The tier follows where the commodity was grown, not where it was processed. Authorities must act immediately on information pointing to a circumvention risk, which the regulation says includes standard- or high-risk commodities processed in a low-risk country and placed on the market or exported from there (Article 13(3)).

The tiers rate deforestation risk only (Article 29(1)). Legality evidence is still collected for every product whatever the tier (Article 9(1)(h)), and under simplified due diligence any information pointing to illegality brings back the full assessment (Article 13(2)).

## What is a substantiated concern, and who can file one?

A "duly reasoned claim based on objective and verifiable information regarding non-compliance" that could need the authorities to step in (Article 2(31)). Any natural or legal person can send one to a competent authority when they consider an operator, downstream operator or trader isn't complying (Article 31(1)). The FAQ adds that it can also go to the operator, downstream operator or trader, which must then inform the authorities where Articles 4(5), 5(5) or 5(6) apply (question 4.15).

What makes a claim substantiated, per the FAQ:

- **Duly reasoned.** A "transparent, concrete, logical and defensible chain of reasoning" the recipient should be able to reconstruct.
- **Specific.** It identifies "who, how and when". A general pattern of trade doesn't qualify, and a concern sent to a company must link the problem to that company: pointing to illegal harvest in a country it sources from is not enough.
- **Backed by evidence**, as far as possible: photos, reports, witnesses, information from authorities or civil society, certification audits.

The FAQ suggests including as many of these as possible:

- Who it is about: the operator, downstream operator or trader, if known.
- Who is filing it, unless that puts them at risk. EU countries must provide measures to protect the identity of people who send concerns to authorities (Article 31(4)).
- Which obligation is breached: deforestation-free, legality, or no statement or declaration.
- For illegality, which law of the country of production was broken.
- Where and when: the area and time of production.
- What: the shipments, species, quantities.
- The evidence.
- Anything else useful to the investigation.

Article 31 applies from 30 December 2026, and from 30 June 2027 for operators that were already natural persons or micro or small undertakings on 31 December 2024, except for products covered by the EU Timber Regulation (Article 38(2) and (3)).

## What do authorities do with a concern?

1. **Assess it.** "Without undue delay, diligently and impartially", including whether it is well-founded (Article 31(2)).
2. **Check the companies.** Concerns trigger checks on top of the yearly plan (Article 16(12)), usually without warning (Article 16(13)). A check on an operator covers its due diligence system and the records for specific products; on a downstream operator or trader, its Article 5 records (Articles 18 and 19). It can go further, especially where that raises questions: on-the-ground examination, DNA or chemical tests, satellite data such as Copernicus, and field audits in the producing country if it agrees (Article 18).
3. **Stop the goods if needed.** Interim measures include seizing products or suspending their placing, supply or export (Articles 23 and 31(2)).
4. **Answer the person who filed it.** Within 30 days, unless national law says otherwise, the authority tells them what it did and why (Article 31(3)). Article 32 gives them access, through their country's procedures, to have the authority's decision, or its failure to act, reviewed.
5. **Order corrections.** Where it finds non-compliance: fix formal gaps, keep the product off the market, withdraw or recall it, or donate or dispose of it, and fix the due diligence system (Article 24). Penalties are set by each EU country, with minimums in Article 25, such as a maximum fine of at least 4% of EU turnover.

Companies have duties of their own once a concern reaches them. An operator that learns a product it placed is at risk immediately informs the authorities where it placed it and the downstream operators and traders it supplied (Article 4(5)); downstream operators and traders do the same (Article 5(5)). When the concern is substantiated, downstream operators and traders that aren't SMEs must also verify that due diligence was done and found no or only negligible risk before placing, supplying or exporting the product (Article 5(6)). The FAQ counts a company as aware once it hears of the concern by email, in a meeting, from authorities or from the media (question 3.6.2).

## What should an exporter or cooperative be able to show?

Exporters and cooperatives outside the EU have no EUDR duties unless they place goods on the EU market themselves. But when a concern lands on the EU operator that bought from them, that operator has to be able to show how each criterion was checked (Articles 10(4) and 13(2)), and the answers are in the exporter's files. Have these ready per lot, not per season:

- **Plot list:** every plot in the lot, its geolocation, who mapped it, when and how.
- **Land review:** each plot's status against imagery from the end of 2020 and today, with who decided and why. The [EUDR plot viewer](https://restorationscope.com/tools/eudr-plot-imagery-viewer) shows both side by side.
- **Land rights:** the title, lease or other arrangement that gives the member the right to use each plot.
- **Lot links:** which plots each lot came from, with quantities that add up.
- **Suppliers:** names, addresses and emails of everyone who sold into the lot, members or not.
- **Rights records** where indigenous peoples are present: consultation, consent where the country's law requires it, and agreements. See [FPIC and benefit-sharing records](https://restorationscope.com/blog/fpic-benefit-sharing-records).
- **Certificates**, with their scope and validity dates.
- **A concern log:** what was raised, by whom, what you checked, what you changed, and when.

Speed matters. When the authorities' system flags products for immediate action before they are placed, supplied or exported, the suspension ends within three working days, or 72 hours for perishable goods, unless the authority extends it by further three-working-day periods (Article 17(3)). The clock starts when the system flags the risk, so the buyer needs your evidence within days.

## Where does Restoration Scope fit?

Restoration Scope builds digital infrastructure for nature projects: software for carbon and nature restoration projects that connects each team's field data, maps and workflows in one system. For a cooperative or exporter, that means the plot list above in one place: each plot's boundary, mapped on a phone in the field, over imagery from 2020 and today, with the review status your compliance team sets and why, linked to its member and to the lots it went into.

**The same plot in April 2020 and October 2025.**

One coffee plot outlined on satellite imagery from April 2020 and October 2025, split by a swipe divider, so the team can see what changed before setting its review status. Demo cooperative: producers, plot records, risk cases and field visits are made up, and deforestation statuses, check results and cutoff figures are not computed by Restoration Scope. Plot locations, map layers and imagery are real.

![EUDR demo coffee plot La Florida 3 outlined on the satellite map, split by a swipe divider: Esri Wayback imagery from 19 Apr 2020 (WorldView-2) on the left and 12 Oct 2025 (WorldView Legion) on the right](https://restorationscope.com/images/landing/eudr-demo/imagery-swipe-map.png)

**Good fit:** an exporter or cooperative that wants its plot evidence ready for any buyer question, with help setting it up.

**Think twice if:** you want a risk score. We don't score risk or give a compliance verdict; your team, and your buyer, make the call.

**Cost:** a free pilot on a sample of your data, then a platform license plus implementation, quoted after a scoping call.

## Where to start

Pick your largest lot from last season and try to answer the 14 criteria for it from your own files. Where an answer needs a phone call, that is the gap a buyer, or an authority, will find first. For the full list of steps, see the [EUDR compliance checklist](https://restorationscope.com/blog/eudr-compliance-checklist); for what to send with each lot, [EUDR for exporters](https://restorationscope.com/blog/eudr-for-exporters) and [EUDR for cooperatives](https://restorationscope.com/blog/eudr-for-cooperatives).

**Disclosure:** We make Restoration Scope, field and plot software that exporters and cooperatives use to keep plot data for the EUDR. No authority or company named here paid for or reviewed this guide.

**EUDR Guide: Learn everything about the EUDR.** From what the regulation asks to mapping plots, tracing lots and reviewing the evidence, in the order teams need it.

1. **Understand the rule.** Who has to comply, what a due diligence statement holds and when it applies.
   - Guide: [What is the EUDR?](https://restorationscope.com/blog/what-is-eudr)
   - Guide: [EUDR for EU importers](https://restorationscope.com/blog/eudr-for-importers)
   - Guide: [EUDR for smallholder farmers](https://restorationscope.com/blog/eudr-for-smallholders)
   - Guide: [EUDR competent authorities and penalties](https://restorationscope.com/blog/eudr-competent-authorities)
   - Guide: [What changed in the EUDR](https://restorationscope.com/blog/eudr-changes)
   - Free tool: [EUDR scope checker](https://restorationscope.com/tools/eudr-scope-checker)
   - Free tool: [EUDR HS code and country lookup](https://restorationscope.com/tools/eudr-hs-code-lookup)
   - Free tool: [EUDR delay checker](https://restorationscope.com/tools/eudr-delay-checker)
2. **Map every plot.** A point or a boundary for each plot, collected in the field and kept current.
   - Guide: [EUDR for cooperatives](https://restorationscope.com/blog/eudr-for-cooperatives)
   - Guide: [What geolocation the EUDR requires](https://restorationscope.com/blog/eudr-geolocation)
   - Guide: [Tools for EUDR geolocation data](https://restorationscope.com/blog/eudr-geolocation-tools)
   - Free tool: [Field plot template](https://restorationscope.com/tools/eudr-field-template)
   - Free tool: [Plot file checker](https://restorationscope.com/tools/eudr-plot-file-checker)
   - Product: [Mapping plots in Restoration Scope](https://restorationscope.com/eudr#geolocation)
3. **Trace each lot to its plots.** Harvest recorded by plot, grouped into lots, with the geolocation file each lot needs.
   - Guide: [EUDR for exporters](https://restorationscope.com/blog/eudr-for-exporters)
   - Product: [Harvest and lots](https://restorationscope.com/eudr#traceability)
   - Product: [The file for your EU buyer](https://restorationscope.com/eudr#export)
   - Free tool: [Due diligence statement prep sheet](https://restorationscope.com/tools/eudr-due-diligence-statement)
4. **Review the evidence.** Imagery from before the 2020 cutoff, forest maps and the plots whose data needs a fix. Your team makes the call.
   - Guide: [EUDR compliance checklist](https://restorationscope.com/blog/eudr-compliance-checklist)
   - Guide: Risk assessment and concerns (you're reading this)
   - Guide: [Filing the statement in TRACES](https://restorationscope.com/blog/eudr-due-diligence-statement-traces)
   - Guide: [Screening plots with Whisp](https://restorationscope.com/blog/whisp-eudr)
   - Guide: [DCF commitments vs the EUDR](https://restorationscope.com/blog/dcf-vs-eudr)
   - Free tool: [Plot imagery viewer](https://restorationscope.com/tools/eudr-plot-imagery-viewer)
   - Product: [Deforestation evidence](https://restorationscope.com/eudr#evidence)
   - Product: [Data quality](https://restorationscope.com/eudr#data-quality)
5. **See it working.** An example coffee cooperative with its plots, lots and imagery.
   - Product: [Restoration Scope for EUDR](https://restorationscope.com/eudr)
   - Demo: [Book a call to see the demo](https://cal.com/bernat/restoration-scope-initial-call)

[Open the EUDR Guide](https://restorationscope.com/blog/category/eudr)

## Questions about EUDR risk assessment

### What is an EUDR risk assessment?

The second step of due diligence under [Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02023R1115-20260918#art_10). Before placing a product on the EU market or exporting it, the operator checks the information it collected against the criteria in Article 10(2) and decides whether there is a risk the product was grown on land deforested after 31 December 2020 or in breach of the relevant laws of the country of production (Articles 2(13), 2(40) and 3). It may place the product only if the risk is none or negligible, and it must be able to show how it checked each criterion and reached that level (Article 10(4)).

### What does negligible risk mean under the EUDR?

Article 2(26) defines it as the level of risk where, after a full assessment of product-specific and general information and any mitigation needed, the products show no cause for concern of not being deforestation-free or legal. The regulation sets no score or percentage. The Commission's [guidance of 20 July 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52026XC03896) says that if, after assessment and mitigation, any criterion still reveals a non-negligible risk, the product carries a non-negligible risk.

### Do products from low-risk countries need a risk assessment?

Not if everything in them comes from countries rated low risk in [Implementing Regulation (EU) 2025/1093](https://eur-lex.europa.eu/eli/reg_impl/2025/1093/oj) and the operator has assessed the supply chain's complexity and found only a negligible risk of circumvention or of mixing with products of unknown, standard-risk or high-risk origin (Article 13(1)). The operator still collects all the Article 9 information, including plot geolocation (micro and small primary operators may give the plots' postal address instead, Article 4a(5)). If it learns of a risk, including a substantiated concern, it has to do the full risk assessment and mitigation and tell the competent authority at once (Article 13(2)).

### Who can submit a substantiated concern under the EUDR?

Any natural or legal person, such as an NGO, a journalist, a community member or a competitor, to a competent authority when they consider an operator, downstream operator or trader is not complying (Article 31(1)). The Commission's [FAQ](https://environment.ec.europa.eu/publications/faq-eudr-implementation_en) (version 5, April 2026, question 4.15) says it can also go to the operator, downstream operator or trader, which then has to inform the authorities where Articles 4(5), 5(5) or 5(6) apply.

### What happens after a substantiated concern is filed?

The competent authority assesses it without undue delay, diligently and impartially, and can run checks, hear the companies and take interim measures, such as suspending or seizing the products (Articles 31(2) and 23). Within 30 days, unless national law says otherwise, it tells the person who filed it what it did and why (Article 31(3)). EU countries must provide measures to protect the identity of people who send concerns to authorities (Article 31(4)).

### Does certification replace an EUDR risk assessment?

No. Information from certification or third-party verified schemes can feed into the risk assessment if it meets the Article 9 requirements (Article 10(2)(n)), but the Commission's guidance says it cannot replace the operator's due diligence and is not a green lane. A chain of custody that mixes deforestation-free commodities with commodities of unknown origin or that aren't deforestation-free, including mass balance that does so, is not allowed (FAQ 1.4); a product mixing certified and non-certified material still needs due diligence on the whole of it (guidance, section 10).