What are the EUDR’s specific due diligence requirements?
To ensure compliance, companies will have to carry out a multi-step due diligence process: data collection, risk assessment, and risk mitigation.
- EUDR DATA COLLECTION
At the data collection phase, businesses must acquire real-time information about their products. This includes everything from basic product descriptions and quantities to more in-depth details, like the geolocation of the farm or forest from which the product originates. Companies must also acquire conclusive evidence verifying that the product’s production is free from deforestation and adheres to the laws of the country of origin.
- EUDR RISK ASSESSMENT
Once companies have completed the data collection, they must undertake a risk assessment. Risk levels are determined by various factors, such as the presence of forests and deforestation, conflicts over land rights with indigenous communities, mixing and circumvention, supply chain complexity, and even socio-political aspects, including corruption and lack of transparency. This comprehensive analysis must be updated at least annually, serving as a living document that evolves based on ever-changing circumstances.
- EUDR RISK MITIGATION
If the risk assessment concludes there is zero risk, no further action is required. However, if risks are identified, companies must explore risk mitigation measures. This could involve collecting additional data, carrying out independent surveys, or undergoing audits. This process is subject to regular audits to monitor the effectiveness of the company’s risk management policies. The EUDR also introduces the concept of “reasonable doubt.” If there’s even the smallest uncertainty about the origins of a product or commodity, businesses will be obligated to conduct a comprehensive risk assessment.