The EU Deforestation Regulation: European Commission classifies countries as high, low or standard risk

The Implementing Regulation categorises countries of origin into three risk levels - low, standard and high - based on their association with deforestation risks linked to the production of seven key commodities (cattle, cocoa, coffee, oil palm, rubber, soya, and wood). The classification directly informs the scope of due diligence obligations for operators and traders, as well as the intensity of enforcement oversight by competent authorities.

The risk assessment draws on objective indicators such as deforestation rates, agricultural expansion, and commodity production trends, with data sourced primarily from the Global Forest Resources Assessment by the Food and Agriculture Organisation of the United Nations. Countries are designated:

• High risk where there is a significant likelihood that commodities are not deforestation-free;
• Low risk where such instances are rare or exceptional;
• Standard risk for all other cases.

As of the May 2025 classification:

• 140 countries, including all EU Member States, the UK, U.S., Canada, China, Japan, Australia, and South Africa, are classified as low risk;
• 4 countries - Russia, Belarus, Myanmar, and North Korea - are designated high risk, partly due to existing international sanctions;
• All remaining countries, including Brazil, Peru, Colombia, and the Democratic Republic of Congo, fall under the standard risk category. 

For commodities sourced from low-risk countries, operators and non-SME traders may apply a simplified due diligence procedure under Article 13 EUDR. This exempts them from conducting risk assessments and implementing mitigation measures, unless credible information suggests potential non-compliance. Nevertheless, the simplified process still entails substantive obligations and does not eliminate the need for vigilance.

The classification also influences the frequency and scope of compliance checks by supervisory authorities. Notably, several Member States, including Luxembourg and Austria, have advocated for the introduction of a “negligible risk” category, which would further streamline compliance for countries with demonstrably minimal deforestation risk.

Preparing for the EUDR

This update builds on our earlier article (Preparing for the EU Deforestation Regulation: What businesses need to know), which sets out the core obligations and compliance challenges under the EUDR. The adoption of the country benchmarking system adds important clarity to due diligence expectations and reinforces the need for robust sourcing controls, particularly when dealing with standard or high-risk jurisdictions.

Fieldfisher is advising clients across sectors on how to prepare for the EUDR, from conducting scoping assessments and mapping supply chains to assessing risk exposure and compliance planning. If your business imports or trades in regulated commodities or products, now is the time to act. Please contact our ESG and Regulatory team for tailored advice on EUDR compliance and how these developments may affect your operations.