EUDR - Commission publishes first country benchmarking list

On 22 May 2025, the European Commission published the first official list classifying countries according to their level of risk under Regulation (EU) 2023/1115 against deforestation. This classification assesses the risk that a country or region represents for the production of raw materials potentially linked to deforestation and forest degradation.

This classification is an important step forward in the implementation of the EUDR, as it allows due diligence requirements to be adapted to the level of risk identified for each country. However, a number of limitations need to be taken into account:

• a methodology based mainly on bibliographic criteria relating to deforestation and forest degradation. The legality criterion, which is central to the EUDR, plays a secondary role, reduced to a supplementary analysis. Yet illegal logging accounts for 15-30% of the timber traded in the world, with an estimated value of between $51 and $152 billion a year. This methodological bias limits the real scope of the risk analysis proposed by the Commission.
• possible confusion between two types of list: the list of countries subject to European sanctions (which prohibits all imports, particularly of timber products), and the list of countries classified as being at "high risk" of deforestation or degradation. As a reminder, it is strictly forbidden to import products from countries under sanctions, while imports from high-risk countries remain authorised subject to risk assessment and mitigation.
• the absence of certain major countries: in West and Central Africa, certain key countries have not been evaluated, such as Cameroon, Gabon, the DRC and Côte d'Ivoire. The same applies to Brazil, a strategic player in the timber and soya markets.

Finally, an important clarification: even for countries classified as low risk, operators must assess the risks of bypassing or mixing with supplies from unknown or high-risk (standard or high) sources. In this respect, we recommend giving preference to certified or audited supplies, including for "low risk" countries, in order to strengthen legal certainty and traceability.

What is the purpose of this benchmarking system?

The country assessment system makes it possible to tailor due diligence obligations for European upstream operators, non-SME downstream operators and non-SME traders.

For countries classified as low risk :

Operators benefit from a streamlined procedure:

• They must collect the information required by Article 9 (identity of suppliers, geographical coordinates, legal documents, etc.). It is important to remember that even for low-risk countries, operators will have to collect GPS coordinates of plots and data on legality.
• And assess the risks of bypassing or mixing with high-risk or standard products (Art. 13.1),
• However, they are exempt from assessing and mitigating risks (Articles 10 and 11), except in the event of new information or concerns indicating a real risk.

The aim is to concentrate verification efforts on the most sensitive areas, while reducing the administrative burden for responsible supply chains.

What can be done for standard or high-risk countries?

For all countries not assessed (standard risk) or classified as high risk, full due diligence applies:

1. Collection of information (Art. 9),
2. Risk assessment (Art. 10),
3. Mandatory mitigation measures if a non-negligible risk is identified (Art. 11).

What methodology?

The classification methodology is based on scientifically-based quantitative criteria, derived in particular from the Global Forest Resources Assessment (FAO), and qualitative criteria: forest legislation, data transparency, respect for the rights of indigenous peoples, international sanctions, etc. It is defined in article 29 of the EU Regulation.

Countries classified as low risk (selected by continent) :

According to the list published by the European Commission:

• Europe

Albania, Andorra, Armenia, Austria, Belgium, Bosnia-Herzegovina, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Georgia, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Moldova, Monaco, Montenegro, Netherlands, Norway, Poland, Portugal, Romania, San Marino, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey, Ukraine, United Kingdom.

• America

Antigua and Barbuda, Bahamas, Barbados, Canada, Chile, Costa Rica, Cuba, Dominica, Dominican Republic, Grenada, Jamaica, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Suriname, Trinidad and Tobago, United States, Uruguay.

• Africa

Algeria, Burundi, Cape Verde, Central African Republic, Comoros, Congo, Egypt, Eswatini, Gabon, Ghana, Kenya, Libya, Lesotho, Madagascar, Mali, Mauritius, Rwanda, Sao Tome and Principe, Seychelles, South Africa, South Sudan, Togo, Tunisia.

• Asia

Afghanistan, Bahrain, Bangladesh, Bhutan, Brunei, China, India, Iran, Iraq, Israel, Japan, Jordan, Kazakhstan, Kyrgyzstan, Kuwait, Laos, Lebanon, Maldives, Mongolia, Nepal, Oman, Palestine, Philippines, Qatar, Saudi Arabia, Singapore, South Korea, Sri Lanka, Syria, Tajikistan, Thailand, Timor-Leste, Turkmenistan, United Arab Emirates, Uzbekistan, Vietnam, Yemen.

• Oceania

Australia, Fiji, Kiribati, Marshall Islands, Federated States of Micronesia, Nauru, New Zealand, Palau, Papua New Guinea, Samoa, Solomon Islands, Tonga, Tuvalu, Vanuatu.

Countries classified as high risk

• Belarus
• North Korea
• Myanmar
• Russian Federation

Wood products from these countries are banned from being imported into the EU, even if the risk has been mitigated. This ban is based not only on the EUDR but also on a specific European sanctions regime.

What about other countries?

All countries not listed retain the default status of 'standard risk', implying full due diligence. This classification is evolving, based on a structured dialogue with the Commission.

Significantly, Brazil, a major exporter of timber and soya, has not been assessed at this stage, nor has Côte d'Ivoire, the world's leading cocoa producer.

And what about certification?

For certain countries classified as low risk, we strongly recommend that certified or audited supplies are preferred.

Certification:

• makes it easier to obtain the information required under Article 9 of the EU Regulation, in particular as regards the legality of production and activities (including social and environmental aspects);
• reinforces the reliability of the data and documents collected, based on annual multidisciplinary and on-site audits, and structured and verified traceability systems;
• reduces the risk of bypassing or mixing with raw materials from unknown or non-compliant sources.

Certification is therefore an essential means of ensuring security, even in cases where the regulations provide for lighter obligations.