Yes, you can perform the risk assessment that the EUDR requires of you in basic terms yourself. The regulation does not prescribe an external party. What is certain: the legal responsibility for that assessment always lies with you as a market participant or trader, regardless of who helps you with the administration surrounding it. Software, advisors or platforms such as eudri.com can structure, organize data and generate documents, but the substantive assessment of whether a risk is negligible remains a decision that you make yourself and for which you are yourself responsible.
Whether doing it yourself is practically feasible depends on the scope of your product streams, the number of suppliers and countries of origin, and how much time you can spare to collect and assess data. For a trader with one fixed supplier in a country with a favorable risk classification, that is different from an importer who sources cocoa from multiple countries via intermediaries.
What the risk assessment exactly entails
The regulation requires that you collect information about your product and its origin, analyze that information for possible risks of deforestation or non-compliance with local legislation, and on that basis determine whether the risk is negligible. If that is not the case, you must take measures to reduce that risk before you place the product on the market or trade it. This entire process is called due diligence, and the risk assessment is its substantive core.
The first step is often the one most easily underestimated: determining exactly what role you have in the chain, as this determines which obligations apply to you and from when. in a few questions, see which role fits your situation provides an initial direction in that regard, without you needing to have a file in place for that yet.
What you can reasonably do yourself
In most cases, collecting basic data is within the reach of an SME: ask suppliers for origin information, request geolocation data of plots, and check in which country and which risk class that origin falls. Keeping an overview per product stream, with the associated documents, is also something you can organize yourself, especially if you bring structure before the amount of data grows.
Where it becomes more complex for many companies is translating all that loose data into a coherent assessment that aligns with what the regulation requires, and into a document you can submit. This is also the point at which we structure and validate: worked out per subject what the regulation precisely requires gives you a basis to determine what you already have in order yourself and what is still missing.
Where doing it yourself becomes more difficult
In practice, the assessment becomes particularly time-consuming when you work with multiple countries of origin, when suppliers are not accustomed to providing geolocation data, or when a product passes through multiple stages before it reaches you. Then you must not only collect data, but also verify that it is complete and consistent, and document that verification so that you can demonstrate it at a later time.
Also generating the due diligence statement or the simplified statement from your file, and submitting it to the EU information system, is a step where many companies choose to seek guidance. This can be done in two ways: you submit yourself with support in the process, or you have it submitted on your behalf. You can read how that process exactly works and where data comes from on the page that explains how the information is produced.
What always remains with you, even with support
No service provider can declare on your behalf that a product is deforestation-free or that you are in compliance with the Regulation. The substantive risk assessment, and the decision whether a risk is to be considered negligible, is and remains the responsibility of the market participant or trader itself. What platforms and advisers can do is help you collect the correct data, structure it according to what the Regulation requires, and generate the documents you need. The legal assessment of your specific situation belongs with yourself, possibly with a lawyer, or with the competent supervisory authority if you have questions about it.
Are you uncertain whether your current approach is complete, or do you want to know what steps are still missing for your product stream? Review the answers to questions that other SMEs ask us or take the free role check to see where you stand for your situation.