EUDR: The Country Risk Classification Has Been Published!

EUDR: The Country Risk Classification Has Been Published!

On May 22, the European Commission released the long-awaited country risk classification list, categorizing countries into three levels of deforestation risk: low, standard, and high.

The Commission states that its classification is based on a methodology grounded in objective quantitative criteria, complemented by qualitative assessments when necessary.

Key indicators used include:

• Net deforestation rate, measured in absolute and relative terms (percentage of annual forest loss).

• Agricultural land expansion for products regulated by EUDR (such as soy, palm oil, cocoa, coffee, rubber).

• Production trends of key products such as timber and livestock.

The main data source is the Global Forest Resources Assessment (FAO FRA). The next data update is expected in 2025, which may lead to a revision of the classification in 2026.

It is worth noting that this initial assessment does not formally integrate indicators on forest degradation due to insufficient data. Their inclusion is expected in the 2026 update.

Key points from the list:

• Most countries are classified as low-risk, including all EU Member States, the USA, Australia, Canada, and many more.

• Most Asian countries are also low-risk, except for notable exceptions in Southeast Asia such as Cambodia, Malaysia, and Indonesia, which are classified as standard risk.

• Most South American countries (Argentina, Bolivia, Brazil, Colombia, Ecuador, Paraguay, Peru, Venezuela) fall into the standard risk category.

• In Africa, classifications are split between low and standard risk, with standard being more common.

• Only four countries are classified as high-risk: Russia, Belarus, North Korea, and Myanmar.

What does this classification mean for companies?

The classification of countries as low, standard, or high risk directly affects the scope of due diligence obligations under EUDR. This classification:

• Helps operators and traders adapt their processes based on the origin country’s risk level.

• Allows Member State authorities to plan annual checks (1% for low-risk countries, 3% for standard risk, 9% for high-risk).

• When a commodity comes from a low-risk country, a simplified due diligence procedure may apply — but obligations still remain.

The operator must still:

• Collect all required information under Article 9:

  • Exact geolocation of production plots

  • Date or period of production

  • Statement of legal compliance and deforestation-free status

  • Verifiable documentation

• Assess and document the risk of circumvention or mixing with products from non-low-risk countries. This includes:

  • Mapping the supply chain

  • Supplier assessment

  • Evidence of material flow and existing controls

Only if it can be demonstrated that the risk of circumvention and mixing is negligible, the risk analysis (Art. 10) and mitigation measures (Art. 11) may be omitted.

Even in low-risk scenarios, operators must maintain strong evidence and full traceability. Competent authorities may request this documentation during any inspection.