EUDR Country and Regional Risk Benchmarking System and Simplified Due Diligence Requirements
ENFORCEMENT TIMELINE
Regulation entered into force on June 29, 2023 (country risk classifications updated periodically by the European Commission)
Overview
This card focuses on the structure of the Country Benchmarking System under Article 29 of the EU Deforestation Regulation (EUDR: Regulation (EU) 2023/1115), its risk classification criteria, and the associated Member State sampling inspection rates and simplified due diligence requirements.
Based on objective and transparent scientific assessment, the European Commission classifies and publishes countries or specific regions worldwide into one of three risk categories: Low Risk, Standard Risk, or High Risk. Assessment factors include the rate of deforestation and forest degradation, trends in agricultural expansion, UN and EU restrictive measures, the protection of indigenous peoples' rights, and compliance with the UN Framework Convention on Climate Change. Where a product's country of production is designated Low Risk, operators may apply Simplified Due Diligence, which exempts them from the second and third steps of due diligence — risk assessment and risk mitigation.
Enforcement Timeline
June 29, 2023: The legal framework for the Country Benchmarking System is established.
May 2025: The European Commission published its first official country and regional risk classification list (Low/Standard/High) under Implementing Regulation (EU) 2025/1093 (adopted on May 22, 2025; published in the Official Journal on May 23, 2025).
December 30, 2026: Inspection rates tied to risk category (1% for Low Risk, 3% for Standard Risk, 9% for High Risk) and Simplified Due Diligence take effect.
Ongoing: The European Commission periodically reassesses and revises country and regional risk levels based on updated data.
Business Impact
Where a sourcing country or region is classified Low Risk, operators still need to collect geolocation data and submit a DDS, but are exempt from preparing detailed risk assessment reports and risk mitigation documentation, significantly reducing administrative burden. Conversely, sourcing from a country or region designated High Risk sharply increases the sampling inspection rate applied by Member State authorities at customs and in market surveillance to at least 9% (compared with 3% for Standard Risk and 1% for Low Risk), raising the risk of customs delays and rigorous on-site audits.
Companies should therefore continuously monitor updates to the European Commission's benchmarking list, work to limit and optimize their sourcing share from high-risk countries, and put in place a flexible risk-management policy that allows them to immediately switch to standard or enhanced due diligence if a sourcing country's risk classification is revised upward.