To streamline due diligence, the EU Deforestation Regulation introduced a country-risk classification system, categorizing nations as low, standard, or high risk based on deforestation risk.
On 22 May 2025, the European Commission published the first official list of country risk classifications through an Implementing Act on the EC’s Green Forum platform.
This marked a long-awaited milestone that brings clarity for companies sourcing commodities like soy, beef, palm oil, cocoa, coffee, rubber, and timber.
While this framework is designed to simplify compliance, it also introduces new challenges, particularly around material mixing from high-risk countries.
The classification system has significant implications for sourcing strategies, supplier expectations, and risk management. Companies must now align their due diligence practices with evolving risk profiles to ensure compliance and maintain supply chain integrity.
In this article, we break down how the system works, what it means for your due diligence, and how to embed it into your operations with practical strategies and technology solutions.
What Is Country Risk Classification and How Is It Assigned?
Country risk classification is the European Commission’s tool for assessing the deforestation risk associated with a country or region. It determines the level of due diligence required under the EUDR and is formally established in Article 29 of the regulation.
Through a structured benchmarking process, the Commission assigns each country a risk level (low, standard, or high) based on a defined set of criteria.
How Risk Levels Are Assigned
The country evaluation relies on quantitative indicators, including:
- The rate of deforestation and forest degradation,
- The extent of agricultural expansion for commodities in scope,
- Trends in the production of those commodities and derived products.
In addition to these data points, the assessment also considers a range of qualitative factors such as:
- each country’s commitment to international climate agreements, such as the Paris Agreement
- the existence of cooperation frameworks with the EU
- the strength of national legal systems and enforcement capacities, protections for Indigenous Peoples and human rights,
- data transparency regarding forest cover, land ownership, and commodity production.
Transparency of data and the presence of international sanctions are also factored into the evaluation.
This comprehensive methodology is outlined in a Staff Working Document that accompanies the Implementing Act, and reflects input from both EU Member States and some of the countries assessed.
Despite the Commission’s adherence to the outlined methodology, the publication of the risk classifications has sparked criticism from several quarters. Environmental NGOs have questioned why countries with well-documented deforestation issues, such as Brazil, Indonesia, and Malaysia, were not classified as high risk, suggesting that political considerations may have influenced the designations.
The Evolving Nature of the EUDR Classifications
It is worth noting that the classification is not fixed.
It can be revised as new data becomes available or as countries take action to address deforestation risks.
The first review of the country classification system is scheduled for 2026, aiming to update risk assessments based on the latest available data.
This makes the benchmarking a dynamic tool that will continue to evolve with implementation, giving regulators and companies a more responsive system to guide compliance efforts over time.
The Strategic Purpose Behind EUDR Country Classification
The EUDR’s benchmarking system is a strategic tool that shapes how companies must approach due diligence, procurement planning, and sustainability performance.
By adjusting the level of scrutiny based on the deforestation risk of a product’s origin, the classification system introduces meaningful differentiation in compliance obligations.
Operators sourcing from low-risk countries may follow simplified procedures, primarily focused on information gathering. In contrast, standard- and high-risk sourcing demands robust risk assessments, mitigation measures, and heightened documentation.
Understanding the practical implications of these classifications helps businesses:
- Prioritize compliance resources effectively,
- Identify potential bottlenecks in their supply chains,
- And prepare for enforcement thresholds aligned with each risk level.
Aligning your internal systems with the EUDR’s tiered expectations is essential not just for legal compliance, but also for maintaining supply chain transparency and resilience in a rapidly evolving regulatory landscape.
EUDR Country Risk Classifications: Benchmarking as of May 2025
The European Commission’s first official benchmarking release under the EUDR offers an initial categorization of countries based on their deforestation risk profile.
Here’s how countries are classified as of May 2025:
Countries Classified as Low Risk
A total of 140 countries fall under the low-risk tier.
This includes all EU Member States, along with the United States, Canada, China, Ukraine, Thailand, and others. Refer to a table below to see all countries included in the low-risk tier.
Operators sourcing from these regions can apply simplified due diligence procedures, provided there is no risk of circumvention or material mixing.
Important: If there is any risk that a shipment includes materials originating from standard- or high-risk countries, even partially, operators must apply full due diligence procedures. This means the simplified obligations available for low-risk sourcing are no longer valid.
According to Article 13 of the EUDR and accompanying guidance, the entire consignment is treated based on the highest applicable risk level.
This rule prevents circumvention of obligations through blending or sourcing from intermediaries and underscores the importance of strict traceability and risk segregation in supply chains.
Countries Assessed as Standard Risk
Fifty countries have been categorized as standard risk.
This tier includes key commodity exporters with complex deforestation histories such as Brazil and Indonesia.
Countries not explicitly listed as low or high risk default to this category, which requires full due diligence, including risk assessment and mitigation.
Countries Designated as High Risk
Only four countries: Russia, Belarus, Myanmar, and North Korea have been assigned high-risk status.
These countries will be subject to the strictest compliance requirements and highest levels of regulatory oversight.
Why These Classifications Matter
The risk classifications carry practical weight, as they shape not only the level of regulatory obligation but also the strategic sourcing decisions companies will need to make under the EUDR.
The diversity of countries included in the benchmarking highlights the importance of understanding different country risk contexts, as risk profiles can vary significantly depending on geopolitical and economic environments.
Below, we’re sharing a detailed table listing all countries along with their assigned deforestation risk classification under the EUDR benchmarking system as of May 2025.
EUDR Country Risk Classification Table
EUDR Due Diligence Implications Based on Country Risk
Due Diligence Implications for Low Risk Countries
For low-risk countries, the EUDR allows operators to follow simplified due diligence procedures. This means companies must still gather and store all required information, as outlined in Article 9.
That includes geolocation of the production plot, details of the commodity, and proof of legal harvesting.
However, they are not obligated to conduct a formal risk assessment or implement mitigation measures.
Despite this simplification, operators are still bound by the EUDR prohibition clause.
They must evaluate the risk of circumvention, especially in supply chains where mixing with material from standard or high-risk countries is possible.
If there’s any indication that the product may contain or be contaminated with non-low-risk material, full due diligence becomes mandatory.
Due Diligence Implications for Standard and High Risk Countries
Operators sourcing from standard or high-risk countries must carry out full due diligence.
This includes not only gathering information, but also assessing and mitigating any deforestation-related risks.
Standard risk applies by default to any country not explicitly listed as low or high.
High-risk countries face stricter oversight. Imports from these countries are subject to enhanced checks by competent authorities.
For companies operating across multiple risk categories, due diligence systems must be flexible and scalable to meet different compliance thresholds.
The Hidden Threats Within Low-Risk: Why Simplified Due Diligence Isn’t a Free Pass
Being classified as a low-risk country does not exempt operators from all EUDR obligations.
The “low-risk” label means that simplified due diligence may be applicable, but it does not apply automatically and depends on meeting specific conditions.
Under Article 9, companies must still collect complete information about the products they place on the EU market.
This includes geolocation coordinates, product description, quantity, supplier details, and production legality.
Operators must also demonstrate that the product is deforestation-free and assess whether there is any risk of forest degradation.
In other words, simplified due diligence removes the formal risk assessment and mitigation steps, but not the need for robust documentation.
If there’s a chance the material has been mixed with commodities from standard or high-risk sources, full due diligence is still required.
High-Stakes for Mixed-Origin Products
China is a good example of where low-risk status can be misleading.
Although it appears on the Commission’s low-risk list, China imports significant volumes of timber from Russia, a high-risk country.
Without proper controls, there is a real possibility that products processed in China may include high-risk material.
This poses a major challenge for companies relying on intermediary suppliers or complex supply chains.
To stay compliant, businesses must trace products back to the specific plot of land where the commodity was harvested.
That includes evaluating supply chains for circumvention risks and documenting the flow of materials across borders.
Competent authorities may request this evidence during audits. This means that even when sourcing from low-risk countries, operators must remain vigilant and fully map their supply chains to avoid enforcement risks.
Risk-Based Enforcement Expectations for Member States
Under the EUDR, national authorities across EU Member States must calibrate their inspection activities to reflect the deforestation risk classification of each country.
The regulation sets clear minimum thresholds for annual compliance checks:
- High-risk countries: At least 9% of relevant operators and 9% of associated product volumes must undergo inspection.
- Standard-risk countries: A minimum of 3% of relevant operators must be checked each year.
- Low-risk countries: At least 1% of relevant operators are subject to annual controls.
These requirements are structured to ensure that enforcement is targeted where deforestation and forest degradation risks are highest.
For businesses sourcing across multiple risk tiers, this necessitates adaptable compliance systems, capable of addressing varying levels of documentation, traceability, and verification.
As Jan Doubal, an EUDR Competent Authority Specialist and one of the regulation’s leading voices, emphasized during the EUDR Summit 2025:
“We expect many more inspections under EUDR. These duties will be much more intense compared to past regulations. Operators must prepare robust documentation and be ready to explain and justify their due diligence systems during inspections.”
This reinforces the critical need for operators to establish resilient systems that can withstand increasing scrutiny and evolving enforcement expectations.
Applying the Benchmarking System to Your EUDR Compliance Strategy
The EUDR’s country-risk classification defines the regulatory expectations, but the burden of implementation rests on how companies operationalize compliance across diverse sourcing environments.
The introduction of the benchmarking system will directly influence supplier expectations and drive the adoption of sustainability tools to manage risks and engage with suppliers.
The approach must be both rigorous and adaptable, taking into account different country risk contexts. Companies may need to shift sourcing patterns in response to the benchmarking list and collaborate closely with partner countries to ensure compliance and promote sustainable practices.
1. Supply Chain Mapping
Mapping the supply chain is the first critical step, required regardless of the risk tier of the sourcing country.
Operators must trace every product back to the specific geolocation where the raw material was produced.
This involves more than identifying suppliers; it requires visibility into land-level data and the movement of goods across borders.
Accurate geolocation information is foundational to verifying the deforestation-free status of a product, and non-negotiable for demonstrating legal compliance.
If you need more information, check out our guide: A Comprehensive Guide to Mastering EUDR Geolocation Data Collection
2. Risk Assessment & Mitigation
When sourcing from standard or high-risk countries, or when origin data is incomplete or potentially mixed, companies must carry out full due diligence.
This means assessing the likelihood of deforestation, forest degradation, or illegal production within the supply chain.
If risks are identified, mitigation measures must be applied.
These may include enhanced supplier engagement, audits, or shifting procurement to more transparent sources.
Even in low-risk sourcing scenarios, operators must remain vigilant.
If there’s a risk of mixing with material from non-low-risk regions or attempts to bypass compliance through trans-shipment, simplified due diligence no longer applies.
In such cases, a comprehensive risk assessment becomes mandatory.
Read more about risk assessment and mitigation in the article series we produced with a global legal firm, CMS:
3. Monitoring and Continuous Improvement
Country risk classifications under the EUDR are subject to change as new information becomes available.
To remain compliant, it is important that due diligence systems are equipped to respond to updates in benchmarking decisions.
This includes maintaining visibility over supply chain data, tracking risk developments, and adjusting procedures as necessary.
A proactive monitoring approach helps ensure that compliance efforts remain aligned with regulatory expectations and can support timely responses to enforcement actions.
How LiveEO Helps: Leveraging Technology for EUDR Compliance No Matter the Country-Risk Status
TradeAware by LiveEO combines satellite imagery with advanced analytics to help companies meet EUDR requirements, whether sourcing from low, standard, or high-risk countries.
Low-Risk Countries
- Collects and stores all required due diligence information, even under simplified obligations.
- Ensures you’re audit-ready by default—no scrambling if risk indicators emerge.
- Geolocation data captured and stored for each plot of land
- Enables on-demand precision analytics and satellite checks for added assurance.
- Provides instant access to documentation in case material mixing triggers full due diligence.
Standard- and High-Risk Countries
- Automates full due diligence workflows, including deforestation assessment, legality checks, and risk assessments.
- Flags non-compliant supplier
- facilitates mitigation actions with Risk mitigation workflows.
- Maintains detailed audit trails and documentation history for inspections.
Dynamic Risk Classification Monitoring
- Alerts users when a sourcing country’s risk level changes.
- Updates due diligence requirements in real time to reflect new risk profiles.
- Keeps compliance protocols aligned with the latest Implementing Acts and Commission guidance
Conclusion: Preparing for What’s Next
The release of the EU’s first country-risk classifications marks a turning point in EUDR implementation.
But understanding the risk status of sourcing countries is only the starting line.
Real compliance requires translating these benchmarks into day-to-day operational decisions across sourcing, supplier engagement, and documentation.
As the risk tiers evolve, and as enforcement tightens, businesses must not only keep pace with updates but embed adaptability into their compliance frameworks.
This means building systems capable of adjusting due diligence depth by risk level, maintaining full supply chain traceability, and proactively addressing emerging threats like material mixing and circumvention.
Regulatory clarity will continue to improve, but so will scrutiny. Companies that integrate real-time monitoring, invest in accurate data, and leverage technology will be best positioned to remain compliant and competitive.
Need help mapping your supply chain or verifying country-of-origin risks? TradeAware is built to support EUDR compliance across all risk levels. Contact us to learn more.
EUDR Benchmarking System: Frequently Asked Questions (FAQ)
What is the EUDR country-risk classification system?
The country-risk classification system is part of the EU Deforestation Regulation (EUDR). It assigns countries a deforestation risk level (low, standard, or high) based on quantitative and qualitative indicators. These classifications determine the level of due diligence operators must perform when sourcing regulated commodities.
When was the first official classification list published?
The European Commission released the first list of country classifications on 22 May 2025 via an Implementing Act published on the EC’s Green Forum platform. It marks a critical milestone in EUDR implementation.
What are the differences between low, standard, and high-risk countries?
- Low-risk countries qualify for simplified due diligence, focusing on information gathering.
- Standard-risk countries require full due diligence, including risk assessment and mitigation.
- High-risk countries face the strictest compliance checks, with enhanced scrutiny and higher inspection rates.
Does sourcing from a low-risk country exempt a company from due diligence?
No. Simplified due diligence still requires full documentation, including geolocation data and proof of legality. If there's a risk of material mixing with non-low-risk sources or if substantiated concerns have been raised by a third party, full due diligence becomes mandatory.
Which countries were classified as high risk?
As of May 2025, the four countries classified as high risk are:
- Russia
- Belarus
- Myanmar
- North Korea
These countries are subject to the most stringent compliance and verification requirements.
How often will the country classifications be updated?
The classifications are dynamic and will be reviewed periodically. The first update is scheduled for 2026, allowing the Commission to revise classifications based on new data or changes in a country’s deforestation profile.
What are the enforcement obligations for Member States?
Each EU Member State must conduct annual checks based on a country’s risk level:
- High risk: At least 9% of operators and product volumes
- Standard risk: At least 3% of operators
Low risk: At least 1% of operators
