ERWAY
All glossary terms
Risk & benchmarking
High risk (country)

Substantiated concern

Also known as: Article 31

A duly reasoned claim based on objective, verifiable information — it reopens full due diligence for affected goods and can end Article 13 simplification.

What it means

A substantiated concern is not a rumour. In the Commission’s framing it is a duly reasoned claim based on objective and verifiable information — from an NGO, a competent authority, a journalist, a whistleblower, or your own monitoring.

In the regulation

Under Article 31, any natural or legal person can submit a substantiated concern to a competent authority or to the operator. Where it goes to the operator, the operator is expected to inform the authority and of any mitigation taken. Once one exists for low-risk sourcing, simplified due diligence closes and full Articles 10 and 11 resume for the affected goods.

Downstream operators who become aware of a substantiated concern must act rather than rely in good faith on the upstream statement alone.

How ERWAY treats it

The obligation matrix and risk-assessment articles on this site treat substantiated concerns as a step-change for low-risk programmes and as an independent route to a check outside the 1%/3%/9% sampling floors.

See what this looks like on your own supplier data

ERWAY turns supplier plot geometry into deforestation risk intelligence and a submission-ready EU Due Diligence Statement. Take the two-minute interactive tour.