kolum
The Imports upload template changed on September 4, 2026. Older versions of the template are no longer accepted, please download the new one:Download the new Imports template
EUDR · EU Companies · Risk Assessment

The 14 risk criteria

Overview

kolum assesses risk against 14 criteria, organised into five groups. They correspond exactly to the risk-assessment criteria the EUDR itself sets out in Article 10(2), points (a) to (n). Each criterion is given an initial rating (low, medium, or high) from the supplier's data and external data sources, and can be reduced to low with mitigation measures or supporting evidence. The EUDR basis column below gives the Article 10(2) letter for each criterion, plus any article it cross-refers to.

ℹ️ All 14 criteria implement Article 10(2) of the regulation. For the legal text, see the consolidated EUDR.

Geographic and Country Risk

CriterionEUDR basisWhat it assessesInitial rating from
Country RiskArt. 10(2)(a); Art. 29The risk assigned to the country or region of production under the EU benchmarking system.The Commission's Article 29 country benchmarking, plus any safeguard measures, sanctions, or enhanced-scrutiny flags.
Forest PresenceArt. 10(2)(b)Whether forests exist in the country or region of production.Global Forest Watch tree-cover data around the declared plots.
Deforestation RiskArt. 10(2)(f)The prevalence of deforestation or forest degradation in the production area, against the 31 December 2020 cut-off.Global Forest Watch and RADD tree-cover-loss alerts, checked against the cut-off date.
Governance IssuesArt. 10(2)(h)Corruption, document or data falsification, lack of law enforcement, human-rights violations, armed conflict, and sanctions.Transparency International Corruption Perceptions Index and international watchlists.

Indigenous People

CriterionEUDR basisWhat it assessesInitial rating from
Indigenous PresenceArt. 10(2)(c)The presence of indigenous peoples in the country or region of production.Overlap of the declared plots with the LandMark global indigenous and community lands database.
Free, Prior & Informed ConsentArt. 10(2)(d)Consultation and cooperation in good faith with indigenous peoples (FPIC).Whether consultation minutes, consent records, or equivalent evidence are on file.
Land Tenure & RightsArt. 10(2)(e)Duly reasoned claims by indigenous peoples regarding use or ownership of the production area.Coverage of the production area by formal land titles and cadastral records.

Documentation and Supply Chain

CriterionEUDR basisWhat it assessesInitial rating from
Data ReliabilityArt. 10(2)(g); Art. 9The source, reliability, and validity of the information and its links to supporting documentation.Quality and completeness of the supplier's submitted documentation.
Traceability RiskArt. 10(2)(i)The complexity of the supply chain and stage of processing, and difficulty connecting products to the plot of land.Supply-chain complexity and processing stages declared.
Circumvention RiskArt. 10(2)(j)The risk of circumventing the regulation or mixing with products of unknown or non-compliant origin.Supplier declarations on shared storage or equipment and origin diversification.

Compliance and Enforcement

CriterionEUDR basisWhat it assessesInitial rating from
Compliance HistoryArt. 10(2)(l); Art. 31Substantiated concerns submitted under Article 31 and the history of non-compliance along the supply chain.Record of prior violations or substantiated concerns about the supplier.
Risk IndicatorsArt. 10(2)(m)Any other information that would point to a risk that the products are non-compliant.Assorted risk signals on file.

Additional Information

CriterionEUDR basisWhat it assessesInitial rating from
Expert FindingsArt. 10(2)(k)Conclusions of the meetings of the Commission expert groups supporting implementation.Findings from the Commission expert group register.
Certification DataArt. 10(2)(n); Art. 30(5) Dir. (EU) 2018/2001Complementary compliance information from certification or third-party-verified schemes.Presence and validity of recognised third-party certification meeting the Article 9 requirements.

Cross-referenced articles

ArticleWhat it covers
Article 8The due diligence obligation (information, risk assessment, risk mitigation).
Article 9The information requirements, including plot geolocation.
Article 10The risk assessment and its criteria (paragraph 2 lists the 14 above).
Article 29The country benchmarking that classifies countries as low, standard, or high risk.
Article 30(5), Directive (EU) 2018/2001Recognised certification and voluntary schemes referenced by criterion (n).
Article 31Substantiated concerns raised about operators or traders.

How this is used

During Step 2, every criterion above low must be brought to low before a Due Diligence Statement can be submitted. Reduce a criterion either by adding a mitigation measure or by supplying supporting evidence from the supplier. See Step 2 — Conduct the assessment analysis for the workflow, and Risk Mitigation Measures for how measures are applied.

ℹ️ Regulatory context. These criteria are the EUDR's own risk factors under Article 10(2), assessed against the country benchmarking (Article 29) and the information collected under Article 9. See the consolidated EUDR text.