Introduction

The EU Deforestation Regulation (EUDR) has set clear due diligence requirements and a growing consensus is emerging: compliance alone is not enough. What matters now is how companies move from assessing risk to actively reducing it in practice. A new guide on risk mitigation measures under the EUDR reflects this transition, focusing not just on what companies need to know, but on what they can to do for forests and communities. 

During our latest webinar, shocking deforestation statistics highlight the need to move fast and implement legislation quickly. “Global deforestation remains alarmingly high. According to the 2025 Forest Declaration Assessment, the world lost around 8.1 million hectares of forest in 2024, with permanent agriculture being responsible for about 86% of this forest loss in the last decade” said Rita Raleira, Researcher & Policy Analyst Deforestation-free supply chains at AidEnvironment. 

At the same time, agricultural production continues to put pressure on standing forests beyond national borders. The EU alone is estimated to import around 250,000 hectares of deforestation each year through agricultural commodities, alongside the embedded greenhouse gas emissions and biodiversity loss.  

Against this backdrop, four key takeaways appeared from the webinar about the pace, method and plan to embed the EUDR legislation, particularly in relation to risk mitigation measures 

The evolution of risk mitigation 

Early approaches to reducing deforestation risk focused heavily on traceability, data collection, and risk assessment. These remain essential foundations, but they are no longer sufficient on their own. One of the clearest lessons from early implementation is that traceability systems, while necessary, have limits. Knowing where commodities come from does not automatically change how they are produced. Risk mitigation is not simply about identifying exposure; it is about transforming it. 

As a Policy Officer at the European Commission Directorate-General for Environment explained: “The whole point of this risk mitigation approach is to make sure that you convert the situation where there were some risks involved, by taking away this specified risk into a situation where there is no or negligible risk.”  

The emerging shift is therefore towards prevention: influencing land-use decisions, supporting sustainable production, and addressing the drivers of deforestation at source. This marks a move from passive compliance to active intervention. 

What’s driving the shift: from traceability to prevention 

Different geographies, commodities, and supply chain structures require different responses. That’s why flexibility and context matter. “The risk assessment is not prescriptive in the approach for the risk mitigation because risk varies. One region or one commodity, even in a region, might be subject to other kinds of risks than in another region. So to make sure that the mitigation approach can be really focused on a specific risk, the EUDR only gives some suggestions,” said a representative from the European Commission Directorate-General for Environment . 

A one-size-fits-all approach risks missing the underlying drivers of deforestation. 

Fostering collective action 

Another key driver is the growing recognition that companies cannot address these challenges alone. Fragmentation across standards, tools, and individual company efforts limits impact and scalability. 

A shift in mindset is underway: “Mitigation strategies don't have to hang on disengagement from risk areas nor from risk-prone supply chains. There is room and opportunity for a constructive engagement that can address the risk drivers and promote inclusion of suppliers,” said Rita Raleira. 

Rather than exiting high-risk areas, companies are increasingly looking to engage with suppliers, governments, and other stakeholders to improve conditions on the ground. This is where collective systems come in. Such approaches can align incentives, reduce duplication, and create shared frameworks that are more efficient and scalable. 

Collaboration also enables more systematic progress: “A cost-effective build-up of capacity ends up creating ways of mitigating the risk systematically,” said Felipe Carazo, Head of Sustainable Commodities at the Tropical Forest Alliance. 

Acting on the ground

Ultimately, the effectiveness of risk mitigation depends on what happens at the production level. That is why the new guide ‘Risk Mitigation Measures for Forests and People under the EUDR’ was launched emphasizing practical implementation: 

“The purpose is really to demonstrate how risk mitigation strategies can be operationalized in practice and how they can build on existing efforts to implement voluntary zero-deforestation commitments,” said Franziska Rau Advisor EUDR & Deforestation-Free Supply Chains at GIZ’s Sustainable Agricultural Supply Chains Initiative (SASI).  

This includes combining different types of interventions: “Adopting a sort of smart mix of actions allows to better address what is realistic, what is impactful, and what is context appropriate…” she added. 

Some actions, such as traceability or supplier engagement, can be implemented directly by companies. Others, such as land-use planning or governance improvements require broader, often jurisdictional approaches. What matters is not choosing one over the other but aligning them effectively. 

For example, from its inception, VISEC is a platform that brings together members of different value chains to trace and track soy and meat production systems to help make them deforestation-free and traceable. The platform has acted as a risk mitigation mechanism, aligning the whole industry around one credible solution, with the industry working together on deforestation and traceability requirements. 

And crucially, these solutions must work in real-world conditions: “We have a clear vision that the system needs to be developed, and it needs to be something that companies can actually use on the ground. More importantly, it needs to be at scale, as a collective action - a single national solution to a coordinated response to market requirements, led by and for the private sector. From my perspective, the spirit of the EUDR and the processes involved is basically companies taking responsibility. So having a private sector-led platform like VISEC is very much in line with that,” said Daniel Kamierzki, Secretariat - Manager of Institutional & External Affairs at VISEC. 

Inclusion and implementation challenges 

As risk mitigation approaches evolve, so do the challenges, particularly regarding inclusion. Smallholders and producers in high-risk regions are often the most affected by new requirements. There is a real risk that stricter rules could lead to exclusion rather than improvement. 
However, this is not inevitable: “The idea is about responsible sourcing from regions where there are risks. The idea is not to seclude those areas that are high risk. And for this to be effective, we need good tools,” said Felipe Carazo. 

This highlights the importance of designing systems that support, rather than sideline, producers or regions. It also depends on how companies interpret risk: “Encourage meaningful engagement with smallholders, cooperatives, and Indigenous peoples and local communities (IPLCs) that supports more proactive risk prevention. The EUDR requires risks to be reduced to a negligible level, and the guide emphasizes that the approach taken matters. So, risk mitigation can mean to disengage and eventually exclude, but it can also be done differently, in a way that strengthens resilience, inclusivity, and long-term forest protection,” said Rita Raleira. 

Practical implementation also depends on enabling conditions. Capacity building, for example, is essential but must be paired with incentives: “The six components—capacity building, livelihood support, certifications, traceability, including forest management, and the jurisdictional approach—form an interconnected system. We cannot just address them one by one. For example, when we talk about capacity building, we have to align it with livelihood support. Technical training must be paired with economic incentives. There is an example at the district level, especially for smallholders or farmers. When they get land recognition, the challenge comes afterward, which is how the post-permission management is handled. This kind of interconnected ecosystem is important,” explained Ristika Putri Istanti, Head of Secretariat at Lingkar Temu Kabupaten Lestari (LTKL).  

Without viable economic pathways, behavioral change is unlikely to be sustained. 

Finally, effective mitigation requires long-term collaboration: “The multi-stakeholder process is not just about sitting at the table, but also about how we can manage the system in the long run,” said Ristika Putri Istanti. 

“Mostly, the bottleneck comes from human resources. The multi-stakeholder process is not just about sitting at the table and discussing one time, but also about how we can manage the system in the long run,” concluded Ristika Putri Istanti. Capacity building alone is not enough; connections between actors across the supply chain, including government and policy stakeholders, must be actively developed. Multi-stakeholder processes should go beyond a one-time meeting at the table; they must be designed for sustained collaboration and systemic impact. As emphasized in the webinar, risk mitigation measures are not merely checklists but essential infrastructure for building inclusive and resilient systems. 

Conclusion: The bigger picture 

Risk mitigation is one aspect of due dilligence and it is not just a technical evolution; it reflects a broader transformation in how sustainability is understood and implemented as a system. As Rita Raleira noted: “Mitigating risks supports not only compliance with regulations and voluntary commitments, but it also reduces exposure to reputational and financial risks while facilitating access to key markets” . 

In other words, effective risk mitigation is not only about protecting forests; it is also about building resilient, future-proof supply chains and interconnected systems. 

The opportunity now is to scale what works, building on proven approaches, strengthening human readiness to move beyond isolated initiatives and embed risk mitigation into the systems that shape global trade. In the end, the success of the EUDR will not be measured only by compliance rates but by whether it helps transform supply chains in ways that benefit both people and forests in the long run.