EUDR risk assessment for coffee: how to classify and mitigate

The risk assessment is the DDS block that raises the most questions. Capturing the plot is not enough: the operator must classify the risk and, where applicable, apply mitigation measures before marking the dossier ready for TRACES. This page explains how to do it for coffee, step by step.

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1. The three country-risk levels

Regulation (EU) 2023/1115 distinguishes three categories of producing-country risk:

• Low risk: the Commission publishes a list of low-risk countries. Reduced due-diligence burden.
• Standard risk: most coffee-producing countries fall here by default.
• High risk: countries with relevant deforestation or legality signals.

The low-risk list is updated by the Commission. Always verify the current version before classifying.

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2. The four assessment factors

Beyond country risk, the assessment considers:

1. Country risk (official lists).
2. Supply chain complexity (number of intermediaries, opacity).
3. Mixed lots (whether coffee from several farms is blended before export).
4. Documentary gaps (missing contracts, land titles or traceability).

Each factor adds up. The result is a Low / Standard / High classification you justify with a short narrative.

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3. How scoring works in practice

A good platform guides you: you answer four questions and get a 0-100 score and a level. For example:

• Low-risk country + short chain + no blending + complete documents → Low.
• Standard country + cooperative chain + moderate blending → Standard.
• High-risk country or opaque chain or severe documentary gaps → High.

The narrative accompanying the result is the justification you keep for audit.

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4. Mitigation measures

If the risk is not low, you must apply mitigation measures before the dossier can be marked ready. For coffee, the most common are:

• Request additional documentation from the supplier (contracts, land titles).
• Audit or visit high-risk suppliers.
• Isolate suspicious lots and do not blend them with the rest.
• Re-run satellite screening with denser layers.

Each measure is documented with an owner, date and evidence, and kept for five years.

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5. Manual override: use with care

Some platforms let you overwrite the calculated level. It is legitimate when you have information the algorithm lacks, but you must justify it in writing. An override without a reason is a red flag in an audit.

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6. How it sits in the DDS dossier

The risk block of the DDS contains:

• Country-risk level.
• Final classification (Low / Standard / High).
• Score and justifying narrative.
• Mitigation measures (if any) with owner and evidence.
• Override and reason (if applicable).

Without this block, the dossier is incomplete.

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Conclusion

The risk assessment is not a formality: it is where you show you have thought about your chain. With a guided flow and documented mitigation, a coffee SME can justify its classification in minutes. Try the guided assessment in EUDR-Comply.