Risk mitigation (EUDR)
Under the EUDR, risk mitigation is the third step of due diligence: where risk assessment finds a non-negligible risk, the operator adopts adequate measures, such as requiring more information, independent surveys or audits, or supporting suppliers, until the risk becomes negligible.
Also known as: Article 11 risk mitigation
Why does it matter?
Under Article 11 of the EUDR, mitigation is mandatory whenever risk assessment does not conclude that risk is none or negligible. Decisions must be documented, reviewed at least annually and made available to authorities.
What measures are typical?
Article 11 lists:
- requiring additional information, data or documents;
- carrying out independent surveys or audits;
- other measures on the information requirements;
- supporting suppliers, in particular smallholders, through capacity building and investments.
In a first-mile context, this can mean re-mapping plots with a flagged polygon, a field visit to check an alert, collecting tenure documents, excluding a plot from a lot, or training farmers.
Non-SME operators must also have policies, controls and procedures, including a compliance officer at management level and an independent audit function (Article 11(2)).
Common pitfalls
- Treating exclusion of farmers as the only mitigation tool, which can push risk elsewhere and harm livelihoods.
- Mitigating on paper without re-assessing the risk afterwards.
- No record of why a flagged plot was cleared.
Farmer1st sends verification tasks to field teams and tracks their outcomes through its field agent management service.
Frequently asked questions
What if risk cannot be mitigated?
The operator must not place the product on the market or export it. Article 4(4) prohibits placing where due diligence revealed a non-negligible risk.
Can supporting smallholders count as risk mitigation?
Yes. Article 11(1) states that mitigation may include supporting compliance by the operator's suppliers, in particular smallholders, through capacity building and investments.
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