European Commission publishes first list of Country Benchmarks under the EU Deforestation Regulation
Yesterday (22 May 2025), The European Commission (EC) released its long-awaited first list of country risk classifications under the EU Deforestation Regulation (EUDR), marking a critical milestone in the road towards the regulation’s implementation.
Published through an Implementing Act on the EC’s Green Forum platform, the list ranks countries as high, standard, or low risk for deforestation and forest degradation linked to the production of relevant EUDR commodities.
These risk levels will directly influence due diligence obligations for companies acting as Operators under the regulation, when placing or exporting products made from soy, beef, palm oil, wood, cocoa, coffee, and rubber on or from the EU market.
The Commission’s three-tier benchmarking system is designed to support consistent implementation and enforcement across the EU and provide clarity for both companies and national authorities. The classification follows the framework set out in Article 29 of the regulation.
A long-awaited milestone
The EUDR entered into force on 29 June 2023. Under Article 29, the Commission was required to develop a risk classification system for assessing the risk level of countries or parts of countries, to help guide the due diligence process and enforcement.
Initially, the Regulation set a deadline of 30 December 2024 for the publication of the first list. However, following stakeholder concerns around the regulation, including delays in the development of the country benchmarks, the European Parliament and Council of the European Union adopted an amending regulation in late 2024, extending the publication deadline by six months to 30 June 2025.
In parallel, the Commission issued a Communication* on international cooperation related to the EUDR, with an annex outlining the general principles behind the benchmarking methodology. This was intended to provide some transparency and prepare partner countries for the implications of their risk classification.
The final Implementing Act was developed and agreed through the EU comitology process, ensuring input and alignment across Member States.
* Communication from the Commission on the Strategic Framework for International Cooperation Engagement in the context of Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation.
How countries have been assessed
As outlined in Article 29, the Commission evaluated countries based on both quantitative and qualitative indicators. Key quantitative criteria included:
- Historical rates of deforestation and forest degradation,
- Agricultural land expansion linked to relevant commodities, and
- Production and trade trends for the seven EUDR commodities and derived products.
Qualitative factors included information submitted by the countries themselves, as well as other stakeholders, regarding:
- carbon emissions and removals from agriculture and forestry related to the Paris agreement;
- cooperation agreements between the countries and the EU or its Member States;
- the strength of national legal frameworks and enforcement capacities,
- human rights and Indigenous People’s protections,
- transparency of data, and
- the status of international sanctions.
The benchmarking methodology was further outlined in a Staff working document that accompanies the Implementing Act, building upon the previously published Communication last year. The process appears to have also included dialogue with some of the countries assessed. The classification list is expected to be updated periodically as new information becomes available, with the next update already planned for 2026.
Benchmarking results
The first list of country benchmarks revealed that the vast majority of countries have been classified as low risk. Specifically, 140 countries were categorised as low risk, with 50 countries concluded as standard risk, and only four countries as high risk.
Preferred by Nature makes the following additional observations:
- High-Risk Countries: Only four countries were classified as high risk: Belarus, Myanmar, North Korea and Russia. Imports from these nations, if not already prohibited, will undergo the most stringent compliance checks.
- Standard-Risk Countries: Major forested nations such as Brazil and Indonesia, despite their historically high deforestation rates, are classified as standard risk. This means they will face moderate scrutiny under the regulation.
- Low-Risk Countries: Countries like the United States, Canada and China, all EU member states, and other countries such as Ukraine and Thailand are concluded as low risk, subjecting them to the least stringent requirements.
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What the classification means in practice
The classification affects both companies and national authorities.
For Operators sourcing from low-risk countries, due diligence requirements will be simplified. By contrast, those sourcing from standard- or high-risk countries must meet the full scope of EUDR obligations, including the assessing of risks for legal production, deforestation and forest degradation, as well as the mitigating of non-negligible risks.
National competent authorities in EU Member States must also adjust their enforcement efforts based on the country risk level. Annual checks must cover:
- Low-risk countries: At least 1% of relevant Operators, placing or making available on the market or exporting relevant products
- Standard-risk countries: At least 3% of relevant Operators
- High-risk countries: At least 9% of relevant Operators and 9% of relevant product volume
These thresholds reflect the EU’s expectation of enhanced scrutiny where the likelihood of deforestation and forest degradation is higher.
Potential implications on sourcing strategies
The introduction of the benchmarking list is likely to shift sourcing patterns and supplier expectations. Preferred by Nature anticipates that this will also affect how companies use sustainability tools, manage risks, and engage with suppliers across different country-risk contexts.
Low-risk countries: Fewer checks, new risks
Starting within the European Union, domestic Operators will no longer need to assess and mitigate risks in relation to their own forests or farms.
For EU-based Operators sourcing products from outside the EU, in theory, low-risk countries could become more attractive due to perceived lighter due diligence requirements. However, Operators should not let their guard down. They should also evaluate the risk of mixing products with those of unknown origin or originating from standard- or high-risk countries, as well as a risk of circumvention – where products are traded to bypass the regulation’s requirements by re-routing them through low-risk countries so that they (falsely) appear to comply with the regulation.
Where substantiated concerns arise—even in low-risk contexts—Operators are obliged to investigate and, if needed, carry out a full risk assessment. These obligations apply regardless of the country’s risk classification.
Standard-risk sourcing: Caution continues
In standard-risk countries, companies can make no assumptions about low deforestation risk. Operators should ensure robust due diligence procedures, including land-level traceability, assessment of legal compliance, and documentation of mitigation efforts.
What should companies do now?
Preferred by Nature recommends that companies immediately review and consider how their due diligence systems are impacted by the new country risk classifications. However, as above, a “low-risk” label is not a free pass: effective risk management remains essential across all sourcing countries.
"Companies seeking to align closely with the regulation, and take advantage of the simplified due diligence option, will likely reassess their sourcing strategies based on the classification of countries as low, standard, or high risk.”
David Hadley
Regulatory Impact Programme Director at Preferred by Nature
“Additionally, there are nuances to the country benchmarks and to the simplified due diligence option that Operators must be aware of and take into account. Preferably, prior to making fundamental changes to their due diligence systems,” added David.
The benchmarking system will play a pivotal role in the effective application of the EUDR ahead of its enforcement deadline of 30 December 2025 for large companies, and 30 June 2026 for some micro and small enterprises.
Preferred by Nature will continue supporting companies and stakeholders in adapting to these developments. Further guidance and tools will be made available to help navigate due diligence requirements based on the new risk classifications.
Our experts are already diving deeper into the benchmark list and its methodology – and what it really means for your sourcing strategies. We’ll be sharing fresh analysis and practical guidance very soon. Stay tuned!
For more information on the EUDR, visit our dedicated webpage.
Unsure if your business is impacted by the EUDR? Find out with our EUDR Scoping Tool.
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