EUDR country benchmarking explained: low, standard and high risk

Every producing country sits in one of three EUDR risk tiers — low, standard or high — set by Commission Implementing Regulation (EU) 2025/1093 under Article 29 of Regulation (EU) 2023/1115. The tier decides how much due diligence you must do and how often authorities check your shipments; it does not decide whether you need a due diligence statement at all. That applies regardless of tier.

The three tiers, and what each one actually sets

Article 29 requires the Commission to classify every country, or part of a country, as low, standard or high risk. The classification criteria are deforestation and forest degradation rates, expansion of agricultural land for the seven EUDR commodities, production and trade trends, and — for the high-risk tier specifically — whether the country is subject to UN Security Council or EU Council sanctions covering the relevant commodities. Article 29 allows the Commission to split a single country into different tiers by region, but the first list published under it did not use that option: every classification so far is national, not sub-national.

The first classification took effect on 22 May 2025, under Commission Implementing Regulation (EU) 2025/1093. It named:

• 4 high-risk countries: Belarus, Myanmar, North Korea and Russia — all under UN Security Council or EU sanctions covering EUDR-relevant commodities.
• Around 140 low-risk countries, including all 27 EU member states, the UK, the US, Canada, Australia, New Zealand, Japan, South Korea, China, South Africa and Turkey.
• Everything else — roughly 50 countries, standard risk by default. This is where most of the world's actual commodity production sits: Brazil, Indonesia, Malaysia, Côte d'Ivoire, Ghana, Vietnam, Colombia and Peru are all standard risk, not high risk. Being a major exporter of cocoa, coffee, palm oil or soya does not by itself move a country to the high tier — sanctions do, or a Commission finding on deforestation rates.

Tier	Countries (approx.)	Authority check rate (Art. 16)	What you must do
Low	~140	1% of operators	Simplified due diligence
Standard	~50	3% of operators	Full due diligence
High	4 (BY, MM, KP, RU)	9% of operators and 9% of volume	Full due diligence, heightened scrutiny

What low risk actually buys you

Low risk unlocks simplified due diligence under Article 13 — it does not remove due diligence. If every commodity in a consignment comes from a low-risk country, or from a country where the relevant part is low risk, you may skip the risk assessment and risk mitigation steps in Articles 10 and 11. You still have to:

• Collect the standard information set: product description, quantity, country of production, and geolocation of every plot of land where the commodity was produced.
• Confirm the product is deforestation-free after the 31 December 2020 cut-off and was produced in accordance with the relevant laws of the country of production.
• Submit a due diligence statement through the EU Information System (TRACES) before the product is placed on the market.

Micro and small operators get two further concessions when sourcing exclusively from low-risk countries: a single simplified declaration covering multiple consignments rather than one statement per shipment, and postal codes in place of precise geolocation polygons. Neither concession is available once any part of the supply chain touches a standard- or high-risk origin.

If your sourcing mixes tiers — say, coffee from Colombia (standard) blended with coffee from a low-risk origin — the consignment is only eligible for simplified due diligence if every plot in it is low risk. One standard-risk plot in the mix pulls the whole consignment into full due diligence.

Simplified due diligence is not a lighter version of the risk assessment; it removes that step entirely. Under full due diligence, an operator has to gather evidence on legality, supply chain complexity and deforestation risk, weigh it, and — where risk is anything above negligible — put mitigation measures in place before the product can be placed on the market or exported. Article 13 lets a low-risk operator skip straight from data collection to filing, provided nothing gives it "reason to believe" a specific consignment may not comply, in which case full due diligence applies regardless of the country's tier.

What every tier still requires

Tier only ever removes work; it never adds an exemption from filing. A due diligence statement is mandatory for every relevant product regardless of country, including goods from EU member states themselves. Geolocation is required for every tier — low risk changes the format (postal code allowed for qualifying micro and small operators) but not the requirement to provide it. Geolocation requirements are the most common reason a due diligence statement cannot be filed, whatever tier the country sits in.

Standard and high risk both require full due diligence: an actual risk assessment against the criteria in Article 10 — prevalence of deforestation, presence of indigenous peoples' rights concerns, complexity of the supply chain, risk of trans-shipment — and, if that assessment finds anything other than negligible risk, mitigation measures before the product can be placed on the market. High risk adds nothing extra to what an operator must do beyond that; the difference is entirely on the enforcement side, where the 9% check rate means a materially higher chance any given shipment is examined.

Why benchmarking is not the same as commodity risk

Country tier and commodity risk are separate questions that get conflated. A country's classification is set once, for all seven commodities together, based on national-level deforestation data. It says nothing about which specific commodity, region or supplier within that country is actually risky. A standard-risk classification for Brazil does not mean every hectare of Brazilian soya land is risky, and a low-risk classification for a country does not mean every supplier in it is clean — it means the country-level starting point for due diligence is lighter, and the operator still has to look at its own actual supply chain. Operators sourcing from standard- or high-risk countries frequently find that most of their individual suppliers pose negligible risk on inspection; the tier sets the default level of scrutiny, not the answer.

The Parliament's objection, and why it didn't change anything

In July 2025 the European Parliament adopted a resolution objecting to the benchmarking methodology, with 373 MEPs voting to reject it over concerns about data quality, transparency and the robustness of the underlying methodology; some MEPs argued for a fourth risk category. The resolution was a political signal, not a legal act. It did not annul or suspend Implementing Regulation (EU) 2025/1093, which remained — and remains — in force throughout. Operators should treat the current list as binding and ignore any suggestion that the objection changed a country's tier: as of this writing, it has not.

How and when the list can change

The Commission committed to a first review of the classifications during 2026, informed in part by updated FAO Forest Resource Assessment data published in October 2025. A country's tier can move in either direction — worsening indicators can push a low-risk country to standard, and improving ones (reforestation, stronger law enforcement) can in principle move a country the other way. No revised list had been formally adopted as of this guide's publication.

The practical risk is timing: a business that has built its sourcing and documentation around a country's low-risk status can have that status withdrawn with as little as three months' operational notice once a revision is adopted. If a material share of your sourcing sits in one country, check the current classification before every filing cycle rather than once at onboarding — see the European Commission's country classification list directly, since third-party summaries lag official updates.

Finding your country's tier

Three steps, in order:

1. Identify the actual country and, where relevant, the specific region or part-country the commodity was produced in — Article 29 classifications can apply below national level.
2. Check the current Annex to Implementing Regulation (EU) 2025/1093 against that country, not a cached list from a blog post or supplier questionnaire.
3. If low risk, confirm every other plot in the same consignment is also low risk before relying on simplified due diligence — mixed-tier consignments default to full due diligence.

This sits alongside, not instead of, the other two questions that decide your obligations: which deadline applies to your size of business, and whether you are the operator who must file the due diligence statement in TRACES or a downstream trader who only needs to record its reference number. Country tier changes how much work the filing takes; it never removes the filing itself.

Commodity-specific guides carry the same point through in practice: coffee importers sourcing from Colombia or Vietnam are working with standard-risk countries and need full risk assessments even where individual farms are low risk, while cocoa and chocolate makers buying from Ghana or Côte d'Ivoire face the same standard-risk starting point. Neither commodity has a country on the current high-risk list, so the practical question for most operators is whether their origin is low or standard, not whether it is high risk.

Check what your business's EUDR obligations are, including which due diligence route your sourcing countries put you on.