EUDR Country Benchmarking: What Low, Standard and High Risk Really Mean for Your Due Diligence

Under the EU Deforestation Regulation, Implementing Regulation (EU) 2025/1093 classifies four countries as high risk (Belarus, North Korea, Myanmar and Russia), lists a large group as low risk, including the UK and all EU Member States, and leaves every other country at standard risk. Sourcing exclusively from low-risk countries allows simplified due diligence, so you can skip the formal risk assessment and mitigation. You still have to gather the full Article 9 information, check for mixing and circumvention, and file a due diligence statement. Mistaking "low risk" for "exempt" is the most common error in supplier risk mapping.

This article covers the EU regime only, using the sources indexed in the EUDR knowledge base.

What the classification measures, and what it does not

Article 29 of the consolidated EUDR sets up a three-tier system for countries "or parts thereof". The tiers are defined by reference to Article 3, point (a): the risk of producing commodities that are not deforestation-free. A high-risk country is one where that risk is high; a low-risk one is where there is "sufficient assurance" that such cases are exceptional; standard risk covers the rest.

The assessment is based primarily on rates of deforestation and forest degradation, the expansion of agricultural land for relevant commodities, and production trends (Article 29(3)). Secondary factors include the country's own information, agreements with the EU, national laws and their enforcement, data transparency, protection of human and indigenous rights, and UN or EU sanctions (Article 29(4)). According to Implementing Regulation (EU) 2025/1093, the data come primarily from the FAO's Global Forest Resources Assessment, and "a large majority of countries worldwide will be classified as low risk".

The current list

The Commission's guidance of 20 July 2026 still describes 2025/1093 as the latest iteration of the list. Article 29(2) says it must be reviewed "as often as necessary in light of new evidence"; any revision after that date is not in the base, so verify the current version before you rely on a tier.

Low, standard, high: the practical differences

• Information collection (Article 9): identical in all three tiers, including geolocation, supplier and customer details, and conclusive evidence of deforestation-free and legal production.
• Risk assessment and mitigation (Articles 10 and 11): may be skipped under Article 13 only where everything comes from low-risk countries; mandatory for standard and high risk.
• Due diligence statement: required in all tiers; only micro or small primary operators established in a low-risk country use the simplified declaration.
• Enforcement intensity (Article 16): authorities must check at least 1% of operators and non-SME downstream operators and traders each year for low-risk origins, 3% for standard risk, and 9% for high risk, plus 9% of the quantity of each relevant product from high-risk countries.
• Political follow-up: the Commission must hold a specific dialogue with countries that are, or risk being, classified high risk (Article 29(5)).

The Article 13 test, step by step

1. Assess supply-chain complexity. The guidance gives indicators: several processors, several plots or countries, highly processed products, and for timber, several species, trading through several countries or processing in third countries.
2. Assess circumvention and mixing. You must rule out mixing with goods of unknown origin or from standard- or high-risk countries.
3. Ascertain origin. All commodities and products must have been produced in low-risk countries or parts thereof.
4. Keep the proof. Be ready to show authorities documentation that the risk of circumvention or mixing is negligible.
5. Stay alert. Any information pointing to non-compliance, including substantiated concerns, brings back full Articles 10 and 11 and a duty to inform the competent authority (Article 13(2)).

Authorities are told to watch one pattern in particular: commodities from standard- or high-risk countries that are processed in a low-risk country and then placed on or exported from the EU market (Article 13(3)).

Complexity cuts both ways. The guidance notes that due diligence is likely to be simpler in short supply chains, and that a short chain may, particularly under Article 13, be one factor that helps demonstrate a negligible risk of circumvention. Conversely, unidentified steps in the chain, or difficulty obtaining the Article 9 information at any point, can on their own lead to the conclusion that the risk is non-negligible.

Why "low risk" is not "no due diligence"

The guidance states that all operators, including those using simplified due diligence, must exercise due diligence under Article 8, meet Article 9 and keep a due diligence system under Article 12. In practice, that means:

• plot geolocation (a polygon above four hectares, except for cattle) and the production date or time range;
• conclusive, verifiable information that the land was not deforested after 31 December 2020;
• evidence of legal production under the country's relevant legislation, as defined in Article 2(40);
• an annual review of the due diligence system (Article 12(2));
• records kept for five years.

Risk assessment for standard and high-risk origins

Where Article 13 is not available, the operator's assessment must cover the Article 10(2) criteria and be tailored to each product, assessing risk for each source or geolocation. Beyond the country tier, those criteria include the presence of forests and indigenous peoples, the prevalence of deforestation, corruption and document falsification, sanctions, supply-chain complexity, mixing, substantiated concerns and complementary certification data that meets Article 9. The guidance stresses that certification "does not imply a green lane" and that mass-balance chains of custody are not compatible with the EUDR. Risk assessments must be documented, reviewed at least annually and shown to authorities on request (Article 10(4)).

These obligations apply from 30 December 2026, or 30 June 2027 for qualifying micro and small undertakings. To test a sourcing scenario, ask the EUDR base: "Which countries are currently classified as high risk for EUDR country benchmarking?"