EU Deforestation Regulation: country risk classification adopted by the Commission

On 22 May 2025, the European Commission adopted an Implementing Regulation classifying countries under the EU Deforestation Regulation (“EUDR”) into three risk categories: low, standard, or high risk. 

Four countries have been designated as "high risk": Belarus, Myanmar, North Korea, and Russia. 140 countries have been classed low risks, including all EU Member States, the UK, the U.S., Canada, China, Japan, Australia and South Africa. Around 50 countries, including Indonesia, Malaysia or Brazil, are at standard risk. The complete classification is available here.  

This classification determines whether operators can benefit from simplified due diligence obligations under Article 13 EUDR, and the level of annual compliance checks to be conducted by supervisory authorities on imports and exports of EUDR-relevant commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and derived products. 

Classification methodology

Upon the EUDR's entry into force, all countries were assigned a standard risk level while the Commission had to refine this classification based on the likelihood of EUDR-relevant commodities and products failing to meet the Regulation’s "deforestation-free" criterion. As per the EUDR, the classification must be based on an objective and transparent assessment and updated as often as necessary in light of new available data. The key data source for the classification was the Food and Agriculture Organization (“FAO”)’s 2020 Global Forest Resources Assessment. 

The published Commission Staff Working Document explains the methodology used, in accordance with Article 29 EUDR and the Annex to the Commission’s Communication on the Strategic Framework for International Cooperation Engagement in the context of the EUDR.

Countries fall into the low-risk category based on thresholds regarding deforestation rates, agricultural land expansion, and increased production of commodities linked to deforestation. Countries subject to UN Security Council or EU Council sanctions on imports or exports of the EUDR-relevant commodities and products are automatically designated as high risk.

The impact in practice

The classification system’s impact under the EUDR is mostly threefold: 

• Simplified due diligence for low-risk countries: with respect to EUDR-relevant commodities sourced from low-risk countries, operators and traders benefit from simplified due diligence obligations under Article 13 EUDR. They are not required to perform risk assessments (Article 10 EUDR) and take risk mitigation measures (Article 11 EUDR), unless specific evidence emerges that products may not comply with the Regulation. They still need to collect information in line with Article 9 EUDR, submit a Due Diligence Statement into the Information System, and assess the complexity of the supply chain, the risk of circumvention and the risk of mixing the product with products of unknown origin or origin of standard or high-risk countries. 
• Risk assessment: the due diligence measures to be adopted by operators and traders are based on, and should be proportionated to, their risk assessment of the deforestation risks, for which the assignment of risk is a key factor (Article 10(2)(a) EUDR).
• Compliance checks: the classification system also serves as a basis for the risk-based approach whereby Member States’ competent supervisory authorities define and plan their minimum annual compliance checks of operators, namely: 
  • 1% for low-risk countries,
  • 3% for standard-risk countries, and
  • 9% for high-risk countries

The Commission Staff Working Document adds that it “serves as an incentive for producers to enhance the sustainability of their agricultural production systems and to minimise their deforestation impact, and enables the European Commission, European Union Member States and other partners to target their support measures”.

Next steps 

Looking forward, the FAO's next Global Forest Resources Assessment (FRA) is expected to be published in October 2025. According to the Commission, a first review of the country classification is therefore envisaged in 2026, to reflect the latest scientific data.

Further reading 

For more information on the EUDR, see our previous blog posts:

• Deforestation Regulation: EU imposes new due diligence duties on operators and traders
• EU Deforestation Regulation: Commission publishes guidance and proposes 12-month delay to application date
• EU Deforestation Regulation: final green light for the one-year postponement
• EU: Commission publishes new guidance and draft Delegated Act to simplify due diligence requirements under Deforestation Regulation