Country risk is an input
Article 10 requires operators to verify and analyse collected information and assess the risk of product non-compliance. The country benchmark is part of that assessment. It cannot replace a review of the actual supply chain or the reliability of a particular supplier’s evidence.
Other criteria include forest conditions, relevant rights and claims, supply-chain complexity, mixing, document reliability and information suggesting non-compliance. Use the full legal criteria rather than reducing the decision to a traffic-light score.
Make the reasoning visible
A useful working record identifies the question, the evidence considered, the inconsistency or concern, the reviewer and the conclusion. Explain why the evidence resolves the issue or why the issue remains open. Record assumptions that would change the decision if they prove wrong.
For example, a lot linked to several suppliers may have complete location files for only some of them. The existence of good files for part of the lot does not answer where the remaining material came from. This is an illustrative review problem, not a legal finding about a real supplier.
Mitigation should answer the gap
Article 11 addresses adequate mitigation where an assessment finds more than negligible risk. Measures can include obtaining additional records and independent surveys or audits. The chosen action should address the specific uncertainty.
After receiving new evidence, review the conclusion again. A planned audit is different from a completed audit with usable findings. Where the evidence does not support the required risk outcome, a process should allow the affected product to remain on hold.
Review and exceptions
Risk assessments must be documented and reviewed at least annually. Material new information can also require action under the operator framework. Keep the assessment date and the underlying evidence versions visible.
Article 13 provides simplified due diligence for qualifying low-risk sourcing, subject to conditions concerning supply-chain complexity, circumvention and mixing. New information indicating non-compliance risk can trigger the full Articles 10 and 11 obligations. Read country benchmarking alongside the product-specific process.
Primary sources
Articles 10, 11 and 13. Legal review used the consolidated text dated 18 September 2026. Consolidated texts are documentation tools; authentic acts are published in the Official Journal.
Check the current sources and relevant competent authority guidance for your situation. This page is not legal advice or a compliance determination.