20.1 The three-tier system (Article 29)
| Category | Definition | Main effects |
|---|---|---|
| Low risk | Sufficient assurance that the production of commodities failing the deforestation test is exceptional | Simplified due diligence (Article 13); MSPO status possible; 1% of checks |
| Standard risk | Neither high nor low — the default category for every country not listed | Full due diligence; 3% of checks |
| High risk | A high risk of producing commodities that fail the deforestation test | Full due diligence; 9% of checks (operators and quantity); systematic risk criteria in the plans; a dedicated dialogue with the Commission |
20.2 Criteria
The classification rests on an objective and transparent assessment, using recent scientific data and international sources, principally (Article 29(3)):
- the rate of deforestation and forest degradation;
- the rate of expansion of agricultural land for relevant commodities;
- production trends for the relevant commodities and products.
It also takes into account (Article 29(4)): information from the country, from regional authorities, companies, NGOs, indigenous peoples and civil society; agreements with the EU on deforestation; laws and their effective enforcement against deforestation, with sufficient penalties; data transparency; laws protecting human rights and the rights of indigenous peoples; and UN or EU sanctions. The methodology is set out in the annex to the Strategic Framework of 02/10/2024 and in a Commission staff working document, based principally on the FAO's Global Forest Resources Assessment (FAQ 6.2).
Before reclassifying a country, the Commission notifies it, explains the reasons and the consequences and allows time for a response (Article 29(6) and (7)). With high-risk or potentially high-risk countries it maintains a specific dialogue aimed at reducing the risk (Article 29(5)).
20.3 The list in force: Implementing Regulation (EU) 2025/1093
Adopted on 22/05/2025, it classified:
- High risk (4): Belarus, North Korea, Myanmar and Russia.
- Low risk (around 140 countries): among them all EU Member States, the United States, Canada, China, India, Japan, the United Kingdom, Norway, Switzerland, Uruguay, Chile, Costa Rica, Ukraine, Türkiye, Vietnam, Thailand, the Philippines, South Africa, Australia, New Zealand and Ghana.
- Standard risk: all the rest — among them Brazil, Argentina, Paraguay, Bolivia, Colombia, Peru, Indonesia, Malaysia, Côte d'Ivoire and Cameroon.
In July 2025 the European Parliament adopted a non-binding objection to the list, criticising the methodology; the list remained in force. The May 2026 report left the system unchanged. The list may be revised whenever new evidence emerges (Article 29(2)).
20.4 What benchmarking does not do
- It exempts nobody from geolocation (FAQ 1.28).
- It does not create a "negligible-risk commodity" by country (FAQ 5.11).
- It does not change the obligations of those buying from standard- or high-risk countries: the difference lies in the intensity of enforcement (FAQ 6.9). The Commission neither expects nor justifies drastic shifts of supply chains because of the classification.
20.5 Cooperation with third countries (Article 30)
The Commission is to engage with producing countries, high-risk ones above all, through partnerships and cooperation mechanisms aimed at forest conservation, restoration and sustainable use, at the transition to sustainable production, at land-use planning, at tenure security, at the transparency of supply chains and at the rights of smallholders, indigenous peoples and local communities. It is also to engage with other major consumer countries and in multilateral forums (CBD, FAO, UNFCCC, WTO, G7, G20).
The Team Europe Initiative on deforestation-free value chains (FAQ 6.6 and 6.7):
- a current budget of 86 million euros;
- the Deforestation-Free Platform — information and knowledge management for partner countries;
- SAFE — Sustainable Agriculture for Forest Ecosystems — the cooperation pillar, with 65 million euros running from 2024 to 2028, being implemented in Brazil, Ecuador, Indonesia, Zambia, the Democratic Republic of the Congo, Vietnam, Peru, Uganda, Cameroon and Burundi, with a focus on smallholders;
- a Technical Assistance Facility — experts on demand for geolocation, land use mapping and traceability.
Report COM(2026) 191 records more than 25 producing countries running over 60 government initiatives linked to the EUDR, such as the VISEC soy traceability platform in Argentina, the Cocoa Traceability System in Ghana, the EUDR THAI platform in Thailand and Selo Verde in Brazil.