EUDR Risk Assessment Sample

produced by Big4

High Risk Criterion

Medium Risk Criterion
Low Risk Criterion
Criterion N/A on Country Level
Criterion currently not assessable

No Country Risk Level with EUDR Requirement Definition Basis for Source Rating Rating Description Background to Basis for Evaluation
respect to Assessment Evaluation
Criterion
1 Assignment of risk to the Art. 10(2) lit. a) N/A N/A N/A N/A N/A N/A
relevant country of
production or parts thereof
in accordance with Article
29
2a Presence of forests in the Art. 10(2) lit. b) ‘forest’ means land Global Forest [Link] 3 Methodology: Global Forest Watch (GFW) is an online
country of production or spanning more than 0,5 Wat ch Tool DN/?mainMap=eyJzaG93QW5hbHlzaXMiOnRydW Global tree cover average of natural platform that provides free, real-time data,
parts thereof hectares with trees forests: 27 % technology, and tools for monitoring the world's
V9&map=eyJjZW50ZXIiOnsibGF0IjotMi41Nzg0NT
higher than 5 metres category: Natural forests. The Natural Forest Dashboard for
and a canopy cover of Forest in Country MwNjA1NjA1NDIsImxuZyI6MTE4LjAxNTE1NTc5M 1= low presence of forest in the Indonesia on Global Forest Watch provides
more than 10 %, or (2020) DAzMDI0fSwiem9vbSI6NC43Mjk1NzY1NTY4MDk country (0-19%) detailed statistics and interactive charts about
trees able to reach 3MjYsImNhbkJvdW5kIjpmYWxzZSwiZGF0YXNldH forest cover, deforestation rates, and the
those thresholds in situ, MiOlt7ImRhdGFzZXQiOiJwb2xpdGljYWwtYm91b 2= average presence of forest in the drivers of forest change in Indonesia.
excluding land that is mRhcmllcyIsImxheWVycyI6WyJkaXNwdXRlZC1w country (19,01%-38%)
predominantly under
b2xpdGljYWwtYm91bmRhcmllcyIsInBvbGl0aWN
agricultural or urban land 3= high presence of forest in the
use, Art. 2(4) EUDR hbC1ib3VuZGFyaWVzIl0sImJvdW5kYXJ5Ijp0cnVl country > 38 %
LCJvcGFjaXR5IjoxLCJ2aXNpYmlsaXR5Ijp0cnVlfSx
7ImRhdGFzZXQiOiJuYXR1cmFsLWZvcmVzdHMiL For Indonesia:
CJsYXllcnMiOlsibmF0dXJhbC1mb3Jlc3RzLTIwMj
AiXSwib3BhY2l0eSI6MSwidmlzaWJpbGl0eSI6dH 53 % of the country was covered
with natural tree cover
J1ZSwicGFyYW1zIjp7InZpc2liaWxpdHkiOnRydWU
sImFkbV9sZXZlbCI6ImFkbTAifX1dfQ%3D%3D&
mapMenu=eyJkYXRhc2V0Q2F0ZWdvcnkiOiJsYW
5kQ292ZXIifQ%3D%3D

2b Presence of forests in the Art. 10(2) lit. b) ‘forest’ means land Global Forest [Link] 3 Methodology: Global Forest Watch (GFW) is an online
country of production or spanning more than 0,5 Wat ch Tool lobal/?category=land- 232 countries are ranked. platform that provides free, real-time data,
parts thereof hectares with trees technology, and tools for monitoring the world's
cover&location=WyJnbG9iYWwiXQ%3D%3D
higher than 5 metres category: Global 1= low presence of forest in the forests. The Global Location of Tree Cover
and a canopy cover of Ranking regarding country (Ranks 232-154: 0-57.8 Kha) Dashboard on Global Forest Watch provides
more than 10 %, or Tree Cover comprehensive data on tree cover across the
trees able to reach 2= average presence of forest in the world. This interactive tool allows users to
those thresholds in situ, country (Ranks 153-76: 57,81 Kha- explore and analyze tree cover change,
excluding land that is 3.69 Mha) deforestation rates, and other related metrics
predominantly under using satellite data.
agricultural or urban land 3= high presence of forest in the
use, Art. 2(4) EUDR country > 3.69 Mha
 2 Presence of forests in the Art. 10(2) lit. b) ‘forest’ means land N/A N/A TOTAL: High Presence of forests in the country of N/A
[total] country of production or spanning more than 0,5 production or parts thereof
parts thereof hectares with trees consolidated ranking methodology:
higher than 5 metres
and a canopy cover of category: Natural Forest in Country
more than 10 %, or counts 2/3, Global Ranking regarding
trees able to reach Tree Cover counts 1/3
those thresholds in situ,
excluding land that is 1= low risk
predominantly under
agricultural or urban land 2= medium risk
use, Art. 2(4) EUDR
3= high risk
3 Presence of indigenous Art. 10(2) lit. c) N/A LandMark Tool, LandMark 3 Methodology: The LandMark Tool is an interactive platform
peoples in the country of category 'National designed to provide comprehensive data on
production or parts thereof Level Maps' Percent of Indigenous Peoples per land rights and tenure globally. It offers
country: detailed maps and information about the legal
3: high presence= >12 % of and customary land rights of Indigenous
Indigenous Peoples per country Peoples and local communities.
2: medium presence: 6,01-12 % of
Indigenous Peoples per country
4 Consultation and Art. 10(2) lit. d) N/A Country Profile [Link] 3 1: low presence=<0-6 % of
Methodology The country profiles by IWGIA provide detailed
cooperation in good faith Indonesia by insights into the situation of Indigenous
with indigenous peoples in IWGIA 1=Low Risk: UNDRIP has been Peoples in various countries. They include
the country of production signed, national laws protecting demographic data on Indigenous populations,
or parts thereof Overview on laws indigenous rights are in place and an overview of national laws and policies
protecting there are no reports that those rules affecting Indigenous rights, and analysis of the
Indigenous are not appropriately enforced main challenges faced by Indigenous
Peoples communities.
2=Medium Risk: UNDRIP has been
signed and there are no reports that
those rules are not appropriately
enforced

3=High Risk: UNDRIP has not been

signed and/or national laws
protecting indigenous rights are
either not in place or according to
reputable sources not appropriately
enforced

For Indonesia:
Indonesia signed the United Nations
Declaration on the Rights of
Indigenous Peoples;
Article 18b-2 of the constitution;
Law No. 5/1960 on Basic Agrarian
5 Existence of duly reasoned Art. 10(2) lit. e) N/A N/A on country N/A N/A N/A N/A
claims by indigenous level [needs to be
peoples based on objective assessed on
and verifiable information transaction level]
regarding the use or
ownership of the area used
for the purpose of
producing the relevant
commodity
 6a Prevalence of Art. 10(2) lit. f) ‘deforestation’ means Appendix 2 - WWF Appendix 2 - WWF Biodiversity Risk Filter v2.0, 3,71 Methodology: Appendix 2 of the WWF Biodiversity Risk Filter
deforestation or forest the conversion of forest Biodiversity Risk Methodology Documentation, Oct 2024 v2.0 Methodology Documentation provides
degradation in the country to agricultural use, Filter v2.0, 1-2,6= low risk; detailed insights into the indicators and data
of production or parts whether human-induced Methodology 2,6-3,4= medium risk; sources used to assess biodiversity risks. It
thereof or not; Documentation, 3,4-5= high risk outlines the methodology for evaluating the
‘forest degradation’ Oct 2024 dependencies and impacts of various
means structural industries on biodiversity. The appendix
changes to forest cover, Category: Forest includes descriptions of the 33 indicators used
taking the form of the Canopy Loss to measure biodiversity health, such as
conversion of: ecosystem diversity, species abundance, and
6b Prevalence of Art. 10(2) lit. f) (a) primary forests
‘deforestation’ meansor WWF - Global [Link] N/A Methodology: ecosystem
The WWF's service
"Global provision.
Deforestation Fronts" report
deforestation or forest the conversion of forest Deforestation _practice/deforestation_fronts_/ N/A= country not listed in the WWF- highlights critical areas around the world where
degradation in the country to agricultural use, Fronts Global Deforestation Fronts; deforestation is occurring at alarming rates.
of production or parts whether human-induced 3= country listed in the WWF-Global These regions, known as deforestation fronts,
thereof or not; Deforestation Fronts; high risk are primarily located in the tropics and sub-
‘forest degradation’ tropics and are responsible for significant
means structural forest loss. Key drivers of deforestation
changes to forest cover, include agriculture, logging, mining, and
taking the form of the infrastructure development
conversion of:
6 Prevalence of Art. 10(2) lit. f) (a) primary forests
‘deforestation’ meansor N/A N/A TOTAL: High 1 match in the WWF-Global N/A
[total] deforestation or forest the conversion of forest Deforestation Fronts data leads
degradation in the country to agricultural use, automatically to High
of production or parts whether human-induced
thereof or not;
‘forest degradation’
means structural
changes to forest cover,
taking the form of the
conversion of:
7 Source, reliability, validity, Art. 10(2) lit. g) (a) primary
While forestsrefers
the criteria or N/A on country N/A N/A N/A N/A
and links to other available to the whole Art. 9 (1) level [needs to be
documentation of the only Art. 9 (1) lit. g and assessed on
information received lit. h are in scope in transaction level]
view of our interpretation

Art. 9 (1)

lit. (g)
adequately conclusive
and verifiable
information that the
relevant products are
deforestation-free;

lit. (h)

adequately conclusive
and verifiable
information that the
relevant commodities
8a Concerns in relation to the Art. 10(2) lit. h) have
N/A been produced in Corruption [Link] 34 Methodology: The Corruption Perceptions Index (CPI),
level of corruption, Perception Index published annually by Transparency
prevalence of document 2023 International, measures the perceived levels of
and data falsification 0-33= high risk; 33,1-66= medium public sector corruption in countries and
risk; >66 low risk territories around the world. The CPI scores
countries on a scale from 0 (highly corrupt) to
For Indonesia: 100 (very clean).

34/100
 8b Concerns in relation to the Art. 10(2) lit. h) N/A Economic [Link] 5 Methodology: The Judicial Effectiveness component of the
level of corruption, Freedom Index pages/indonesia 5 levels (1 = free (100-80), 2 = Economic Freedom Index evaluates the
prevalence of document 2023 mostly free (80-70, 3 = moderately efficiency and integrity of a country's judicial
and data falsification free (70-60), 4 = mostly unfree (60- system. It measures how well the judiciary
category: Judicial 50), 5 = repressed (0-50)) enforces laws, protects property rights, and
Effectiveness ensures fair and timely resolution of disputes
Lvl 1-2= Low Risk
Lvl 3= Medium Risk
Lvl 4-5= High Risk
8c Concerns in relation to the Art. 10(2) lit. h) N/A Economic [Link] 5 5 levels (1 = free (100-80), 2 = The Government Integrity component of the
level of corruption, Freedom Index pages/indonesia mostly free (80-70, 3 = moderately Economic Freedom Index assesses the extent
prevalence of document 2023 free (70-60), 4 = mostly unfree (60- to which a government operates transparently
and data falsification 50), 5 = repressed (0-50)) and free from corruption. It evaluates factors
category: such as the prevalence of bribery, the
Government Lvl 1-2= Low Risk effectiveness of anti-corruption measures, and
Integrity Lvl 3= Medium Risk the overall transparency of government
Lvl 4-5= High Risk operations
8d Concerns in relation to the Art. 10(2) lit. h) N/A WJP Rule of Law [Link] 2 Methodology: The Absence of Corruption part of the WJP
level of corruption, Index 2024 index/country/2024/Indonesia/Absence%20of%2 3 levels (3= high risk of corruption (0- Rule of Law Index measures how free public
prevalence of document 0,33); 2= average risk of corruption officials are from corruption, including bribery,
0Corruption/
and data falsification cateogry: (0,34-0,66); 1= low risk of corruption improper influence, and misappropriation of
Absence of (0,67-1) public funds. It reflects the integrity and
Corruption transparency of government operations, which
8 Concerns in relation to the Art. 10(2) lit. h) N/A N/A N/A TOTAL: High Each criteria is weighted the same: in N/A
[total] level of corruption, case of parity the higher risk
prevalence of document category gets chosen.
and data falsification
9 Concerns in relation to Art. 10(2) lit. h) concerns in relation to WJP Rule of Law [Link] 2 Methodology: The WJP Rule of Law Index measures how the
lack of law enforcement the country of Index 2024 index/country/2024/Indonesia/Regulatory%20En 3 levels (3= high risk of corruption (0- rule of law is experienced globally, covering
production and origin or 0,33); 2= average risk of corruption 142 countries. It assesses factors like
forcement/
parts thereof, such as category: (0,34-0,66); 1= low risk of corruption government constraints, corruption, open
level of corruption, Regulatory (0,67-1) government, fundamental rights, security,
prevalence of document Enforcement regulatory enforcement, civil justice, and
and data falsification, For Indonesia: 0,57 criminal justice.
lack of law enforcement,
violations of The Country Profile provides detailed insights
international human for each country, including overall scores,
10a Concerns in relation to Art. 10(2) lit. h) rights,
N/A ITUC Global [Link] 5 Methodology: factor
The scores,
2024 ITUCtrends,
Global and comparisons,
Rights Index reveals a
violations of international Rights Index (2024 [Link]/IMG/pdf/2024_ituc_global_rights_index_e decline in workers' rights worldwide. Nearly
human rights 1 = sporadic violations of rights, 2 = 90% of countries violated the right to strike,
[Link]?31226/ce28bb2139c2fe0d4e5f0a36d726
repeated violations of rights, 3 = and around 80% denied collective bargaining
ac7334d1c2d9be8b29dd88b4d2b9d89f5654 regular violations of rights, 4 = rights. Arbitrary arrests of trade union
systematic violations of rights, 5 = members occurred in 49% of countries, up
no guarantee of rights, 6 = no from 46% in 2023. Restriction of freedom of
guarantee of rights due to the speech and assembly was noted in 43% of
breakdown of the rule of law countries, a slight increase from 42% in 2023.
Key incidents include restrictions on street
10b Concerns in relation to Art. 10(2) lit. h) N/A Human Rights Human rights index, 2023 0,73 For Indonesia:
Methodology: 5 protests
The Human in Argentina andmeasures
Rights Index a new lawthe
in extent
violations of international Index (2023) 0= no rights, 1= most rights to which individuals enjoy fundamental human
human rights rights in various countries. It evaluates factors
0-0,33 high risk; 0,34-0,66 medium such as freedom from government torture,
risk; >0,66 low risk political killings, forced labor, and the
protection of property rights. Additionally, it
For Indonesia: assesses freedoms of movement, religion,
expression, and association. This index
0.73 provides a comparative measure of human
10 Concerns in relation to Art. 10(2) lit. h) N/A N/A N/A rights conditions globally, helping to identify
TOTAL: Medium Equal assessment: 1 high risk; 1 low N/A
[total] violations of international risk= medium risk
human rights
11 Concerns in relation to Art. 10(2) lit. h) N/A Conflict Index: [Link] 1 Methodology: The Conflict Index for December 2024,
armed conflict December 2024 0= Low/Inactive published by ACLED, assesses global conflict
1= turbulent situation levels based on four key indicators:
2= high conflict situation deadliness, danger to civilians, geographic
3= extreme conflict situation diffusion of conflict, and armed group
fragmentation.
1= low risk (0-1)
2= high risk (2-3)
12a Concerns in relation to Art. 10(2) lit. h) N/A United Nations UN Scurity Council Sanctions 1 Methodology: The United Nations Security Council Repertoire
sanctions imposed by the Security Council provides comprehensive coverage of the
UN Security Council or the Repertoire 3=sanction imposed:: high risk Security Council's interpretation and
Council of the European 1=no sanction imposed: low risk application of the UN Charter and its
Union Provisional Rules of Procedure. It documents
the Council's decisions, practices, and
activities, offering insights into how it
addresses issues of international peace and
12b Concerns in relation to Art. 10(2) lit. h) N/A EU Sanctions Map [Link] 1 Methodology: security.
The The Repertoire
EU Sanctions includesdetailed
Map provides information
and
sanctions imposed by the up-to-date information on the European Union's
UN Security Council or the 3=sanction imposed: high risk restrictive measures across the globe. It
Council of the European 1=no sanction imposed: low risk includes data on financial sanctions, travel
Union bans, and export restrictions imposed on
individuals, entities, and countries. The map
covers various thematic areas such as human
rights, cyber-attacks, and the proliferation of
weapons of mass destruction. It serves as a
12 Concerns in relation to Art. 10(2) lit. h) N/A N/A N/A TOTAL: Low Risk always high, whenever the comprehensive tool for monitoring and
N/A
sanctions imposed by the United Nations Security Council
UN Security Council or the Repertoire or the EU Sanctions Map
Council of the European show high risk
Union
13 Complexity of the relevant Art. 10(2) lit. i) N/A N/A on country N/A N/A N/A N/A
supply chain and the stage level [needs to be
of processing of the assessed on
relevant products, in transaction level]
particular difficulties in
connecting relevant
products to the plot of land
where the relevant
commodities were produced

14 Risk of circumvention of Art. 10(2) lit. j) N/A N/A on country N/A N/A N/A N/A
the EUDR or of mixing with level [needs to be
relevant products of assessed on
unknown origin or produced transaction level]
in areas where
deforestation or forest
degradation has occurred
or is occurring
15 Conclusions of expert Art. 10(2) lit. k) N/A Evaluation of [Link] 1 Methodology: N/A
groups meeting register/screen/meetings/consult?lang=en&do=gr
documents of the Analyzation of recommendations; if
[Link]&meetingId=23741
Meeting of the strict recommendations for certain
expert countries are published, those are
Group/Multistakeh [Link] deemed as high risk
olderplatform with register/screen/expert-
a focus on groups/consult?lang=en&groupId=3282&fromM 3= Country specific recommendations
deforestation and eetings=true&meetingId=23741 are published: high risk
forest degradation 1= No country specific
recommendations are published: low
risk
16 Substantiated concerns Art. 10(2) lit. l) Intersection with Art. 10 N/A on country N/A N/A N/A N/A
(2) lit. m level [needs to be
assessed on
17 Other information Art. 10(2) lit. m) N/A N/A on country N/A N/A N/A N/A
level [needs to be
assessed on
18 Verified schemes Art. 10(2) lit. n) N/A N/A on country N/A N/A N/A N/A
level [needs to be
assessed on
 *** EXAMPLE OF REQUIRED DOCUMENTATION BASED ON EU-INDONESIA VPA AGREEMENT***

L 150/276
LEGALITY STANDARD 3: THE STANDARD FOR PRIVATELY-OWNED FORESTS

No Principles Criteria Indicators Verifiers Related Regulations

1. P1. Timber ownership K1.1 Legality of ownership or 1.1.1 Private land or forest owner Valid land ownership or land Act 5/1960
can be verified land title in relation to the can prove ownership or use tenure documents (land title
timber harvesting area. rights of the land. documents recognized by Regulation of the Minister for

EN
competent authorities) Forestry P33/2010

Land Cultivation Right. Government Regulation PP12/1998

Deed of Establishment of the Regulation of the Minister for Trade

Company 36/2007

Business licence for companies Regulation of the Minister for Trade

Official Journal of the European Union

engaging in trading business (SIUP) 37/2007

Company registration (TDP) Act 6/1983

Tax payer registration (NPWP) Act 13/2003

Act 23/2003
Map of the area of private forest
and boundaries delineated on the Act 20/2009
ground.

1.1.2 Management units (either Certificate of Timber Origin or Log Regulation of the Minister for
owned individually or by a Transport Document Forestry P30/2012
group) demonstrate valid
timber transportation docu­
ments. Invoice/ sales receipt/ freight clear­
ance.

1.1.3 Management units show Proof of payment of Reforestation Regulation of the Minister for
proof of payment of Fund and/or Forest Resources Fee Forestry P18/2007
applicable charges related to and compensation to the state for
trees present prior to the the value of stumpage cut.

20.5.2014
transfer of rights or tenure of
the area.
 20.5.2014
No Principles Criteria Indicators Verifiers Related Regulations

2. P2. Compliance with K2.1 Permit holder has an 2.1.1 Permit holder has EIA EIA documents Government Regulation PP27/1999
environmental and approved Environmental documents approved by the
social aspects Impact Assessment (EIA) competent authorities which Regulation of the Minister for
related to timber document and has imple­ cover the entire work area. Forestry and Plantation 602/1998
harvesting in the mented measures identified
case of areas in it.

EN
subject to Land
Cultivation Rights

3. P3. Compliance with K3.1 Fulfilment of occupational 3.1.1 Availability of OSH Implementation of OSH procedures Regulation of the Minister for
labour laws and safety and health (OSH) procedures and their imple­ Manpower & Transmigration
regulations in the requirements mentation OSH equipment 01/1978
case of areas
subject to Land Employment injury records Regulation of the Minister for
Cultivation Rights Forestry P12/2009

Official Journal of the European Union

K.3.2 Fulfilment of workers' rights 3.2.1 Freedom of association for Workers belong to workers unions Act 21/2000
workers or company policies allow workers
to establish or get involved in Regulation of the Minister for
union activities Manpower & Transmigration
16/2001

3.2.2 Existence of collective labour Collective labour agreement Act 13/2003

agreements documents or company policy
documents on labour rights Regulation of the Minister for
Manpower & Transmigration
16/2011

3.2.3 Company does not employ There are no underage workers Act 13/2003
minors underage workers
Act 23/2003

Act 20/2009

L 150/277