Segregating Higher-Risk Supply

Filed under EUDR Risk Assessment and Mitigation Explained

Plot record: legal status and review details

Jurisdiction: European Union
Status: Current consolidated Regulation (EU) 2023/1115, including the 2025 amendment and September 2026 consolidation. Main obligations are not yet generally applicable on the verification date.
Application: Generally 30 December 2026; 30 June 2027 for qualifying micro and small operators established by 31 December 2024 under Article 38(3), except products covered by the EUTR Annex; some newly added products apply from 30 December 2027. Check the product and actor-specific rules.
Relevant provisions: Articles 3, 9, 10 and 11

Review this page when:

Amendments to Articles 9 to 13
New Commission due diligence or certification guidance
Changes in country benchmarking, supply routes or relevant adverse information
Product-scope and application-date amendments

Understand what segregation can achieve

Segregation can reduce an assessed lot's exposure to uncertain or non-compliant material when it reliably keeps that material outside the lot. It changes the supply boundary and the route of the goods. It does not make excluded material compliant, erase a deforestation finding or resolve missing origin information about goods that remain in the covered product set.

The distinction is practical. A warehouse may have identifiable bags from assessed farms alongside bags from an unknown collector. Controlled separation could preserve the assessed stream. If those inputs have already been blended into an indistinguishable bulk pile, a spreadsheet allocation does not recreate physical separation. An equivalent quantity of clean material elsewhere cannot offset the unknown contribution.

Within the risk assessment and mitigation framework, define the proposed compliant lot and explain how segregation addresses the identified mixing risk. The assessment still needs evidence of deforestation-free and lawful production for every origin actually included. A segregated stream is a traceability control, not a universal compliance conclusion.

Map every point where streams can meet

Draw the material route from receiving through storage, processing, rework and dispatch. Include temporary holding areas, shared equipment, subcontractors and returns. Mixing often occurs at a less visible step: a loader used for two stockpiles, an overflow silo during peak harvest or rejected material returned to a general process line.

Identify the relevant unit of separation at each step. It might be sealed bags, dedicated compartments, physically divided stockpiles or production runs separated by an effective cleaning procedure. The control needs to fit the commodity and equipment. A floor marking may help staff organise pallets but does little to prevent liquids or loose bulk material crossing boundaries.

Record how the business knows a stream's identity. Lot labels, receiving references and stock records should follow the physical goods and survive repacking. If staff transfer a label without confirming the source, the system can preserve a convincing record while losing the underlying identity. Test transfers and exceptions, not only routine deliveries that arrive perfectly labelled.

Specify controls that survive normal operations

Set receiving rules identifying accepted origins and the evidence required before a delivery enters the assessed stream. Provide a separate destination for unverified arrivals. Without an operational alternative, staff under pressure may put a questionable delivery in the nearest available store and intend to sort the records later.

Control access, transfers and process changeovers. Define who can authorise movement, how quantities are recorded and what happens after a spill, damaged label or unexplained stock discrepancy. Where cleaning is relied upon, assess whether it actually prevents relevant carryover in that equipment and process. A generic cleaning checklist cannot establish that a particular line was clear before the relevant run.

Reconcile incoming assessed material, stock, processing outputs and dispatches using credible conversion factors. Reconciliation helps detect unexplained additions but cannot by itself prove origin. A balanced ledger can still be wrong if entries are fabricated or mixed inputs are relabelled. Combine transaction checks with physical observations, access controls and investigation of unusual movements, especially during busy periods.

A palm oil tank example

An operator proposes purchasing oil from a supplier with one tank reserved for assessed sources. Tank records show deliveries from named mills, each linked to assessed production origins. A second tank accepts wider market purchases. Both tanks use a shared transfer manifold, and staff can direct incoming oil by changing valves manually.

The segregation assessment should examine valve controls, transfer logs, maintenance events, cleaning where relevant and the actual route used for the proposed batch. A dedicated tank label does not settle whether an accidental or undocumented transfer occurred. Ask operators to demonstrate the procedure and check whether the recorded volumes and timing are consistent with the claimed route.

If evidence supports a controlled, identified stream and the underlying compliance assessment is satisfactory, the operator can define the covered quantity accordingly. If the shared manifold allowed unknown inputs into the tank and their contribution cannot be excluded, the supplier cannot restore the claim by allocating a matching clean volume on paper. Further investigation may resolve a recording error, but accounting cannot reverse an actual unidentified mixture.

Verify effectiveness and retain clear limits

Use targeted checks to test whether the segregation plan works as designed. Compare records with physical stock, follow transfers and ask staff how they handle exceptions. Independent surveys or audits can be useful where the chain is complex or confidence in records is limited. Their scope needs to include the points where mixing could defeat the control.

Document which goods were excluded and how the remaining lot was identified. Preserve the reason for exclusion and the revised risk assessment. If known non-compliant goods are removed from the proposed supply, that removal protects the remaining assessed lot only where separation is reliable. It does not rehabilitate the removed goods or allow them back through a different label.

Review controls when volumes, machinery, warehouses, subcontractors or origins change, and review mitigation decisions at least annually. A new overflow arrangement can invalidate a previously sound segregation conclusion. Where separation cannot reliably protect the intended stream, consider changing suppliers or production areas and assessing the replacement route before release.

Primary sources on the record

Articles 3, 9, 10 and 11. This entry was checked against the consolidated text dated 18 September 2026. Consolidated texts are documentation tools; the authentic acts are those published in the Official Journal.

Check the current sources and the guidance of the relevant competent authority for your situation. This page is not legal advice or a compliance determination.