.jpg)
Last week, we hosted a webinar exploring a critical but often overlooked aspect of EUDR compliance: risk assessment.
The EUDR conversation has largely focused on data collection – mapping supply chains, gathering geolocations, and collating documentation. But what happens after that?
Risk assessment is more than a box-ticking exercise. It is the legal and practical obligation that determines whether you can place products on the EU market. Without it, even the most comprehensive data collection falls short of compliance.
In our session, hosted by Anna Roberts (Head of Market Development at Interu) and featuring Eduard de Boer (EUDR expert at Ingenieursbureau Evan Buytendijk BV), and Dick Anning, Carl Ronnow and Timber Compliance Subject Matter Expert at Interu we went beyond the checklists to unpack:
- What meaningful risk assessment entails
- How to use third-party field audits strategically
- Real-world insights from the wood products industry
- Practical guidance EU operators can act on now
We received some excellent questions from attendees, ranging from rubberwood scope to cosmetics imports. Here are some of the key Q&As from the session:
EUDR Risk Assessment Webinar Q&A Highlights
Q1. Does the EUDR include straw and bamboo?
Straw and bamboo are not in scope of the EUDR.
Q2. For tyres that use a fabric infused with rubber but are not under a relevant HS code, do I need to conduct due diligence on the rubber-infused component?
No, you don’t. However, it’s always best to check the HS-code Annex I of the regulation to be certain.
Q3. Are trees used for rubber within scope?
Yes, rubberwood (the wood from rubber trees) is in scope of the EUDR and was already included under the EUTR.
Q4. Does this apply to rubberwood from Thailand, even though it is classed there as an agricultural crop?
Yes. While Thailand classifies rubberwood as an agricultural crop, the EUDR focuses on the HS code under which the product is imported into the EU or UK. Other agricultural crops like cocoa, palm oil, and coffee are also in scope of EUDR.
Q5. I’m based in the UK and import palm derivatives from the EU. Many focus only on the commodity itself, but what about packaging? If the packaging industry isn’t ready in time, will this risk EU movement of goods? Is the packaging sector better prepared due to EUTR?
When packaging is used solely to protect a product (including during transport), it is not subject to EUDR. However, if packaging is produced or sold as packaging material from one company to another, it does fall under EUDR. Check out our blog on packaging here.
We are supporting a number of packaging businesses with EUDR readiness, but preparedness is not consistent across the industry.
Q6. If I’m sourcing from EU countries and a product has a Due Diligence Statement (DDS) with reference numbers, does that mean all risk is mitigated and member state authority has approved it? Can I just refer to the DDS numbers when manufacturing and exporting back to the EU without additional risk assessment or mitigation?
The presence of a DDS does not mean that a member state authority has ‘approved’ the products and that no risks are present. Checking the validity of DDS reference and verification numbers simply demonstrate that they exist for a particular transaction, not that any checks on that transaction have been made by a competent authority.
When you export the product (to be re-imported into the EU), even with upstream DDS numbers, the EU Operator will have to be able to evidence that during its production it has not been mixed with products that are not accompanied by an upstream DDS number or which might be non-compliant.
As a non-EU based exporter you are not subject to EUDR risk assessment obligations. You may be subject to other non-EU national legislation which requires due diligence and risk assessment.
Q7. What does a distributor of cosmetics (e.g. lipstick, moisturiser) need to import these goods into the EU if they contain palm oil?
Lip balm falls under HS-code 3304 (make-up) and is not subject to the EUDR.
Q8. Are the country documentation lists specific to timber, or do they also cover other products under EUDR?
They are approximately 80% generic and 20% timber-specific.
Q9. Can FSC certification be used to mitigate labour rights risks, given it includes clauses on labour and human rights?
It depends. In areas of low risk, with low corruption levels per the Corruption Perception Index (CPI), it could probably be replied upon.
But if a country has a high level of corruption (i.e., it is red or yellow per the CPI), then an FSC certificate alone might not be reliable enough on its own and additional mitigating measures will be needed.
Q10. How can I know exactly what is necessary per country?
Get in touch with Ingenieursbureau Evan Buytendijk for country-specific guidance.
Preferred by Nature also has information for certain commodities and certain countries on its Sourcing Hub.
Q11. Do you have evidence that the timber source has ‘Use Rights’?
Yes, you need to collect proof of use rights from the place of harvest to ensure the timber has been legally harvested.
Want to dive deeper into these topics?
You can now watch the full webinar on demand, where Eduard de Boer and Anna Roberts unpack effective EUDR risk assessment and share practical advice to keep your business compliant and ready.
