EUDR country benchmarking and simplified due diligence

Country benchmarking is not a substitute for the EUDR product-scope and compliance test. Relevant commodities and products still must be deforestation-free, produced in accordance with relevant legislation of the country of production, and covered by a due diligence statement or simplified declaration where required.

The benchmark tier changes whether an operator may use the Article 13 simplified due diligence route. Under Implementing Regulation (EU) 2025/1093, Belarus, the Democratic People's Republic of Korea, Myanmar, and the Russian Federation are high risk. The Annex names the low-risk countries; all countries not listed in either category remain standard risk. Check the current Annex rather than copying a country list into a static supplier record.

Simplified due diligence is available only for relevant products produced in countries or parts of countries classified as low risk under Article 29. It is not a general shortcut for trusted suppliers, low-value shipments, familiar commodities, or products with incomplete plot data.

Even for low-risk production, the operator must assess supply-chain complexity and the risks of circumvention or mixing. If that check does not show negligible risk, the operator cannot rely on the simplified route and must complete the normal risk assessment and mitigation work before placing the product on the market or exporting it.

Low-risk status does not remove Article 9 information collection. The operator still needs an evidence file showing the product, commodity, quantity, supplier, country of production, production location evidence, and the documentation needed to demonstrate deforestation-free and legal production.

The EUDR source material specifically calls out geolocation of plots of land or establishments, plus documentation demonstrating deforestation-free and legal production. For micro or small primary operators, it also notes a separate simplified declaration regime and a limited replacement of geolocation with postal address information for plots or the establishment.

A country-risk decision should not be treated as permanent. The EUDR benchmarking list is maintained through Article 29 implementing acts, and the Article 13 simplification depends on the production location being low risk at the time the operator relies on that route.

Monitoring also has a supply-chain side. Downstream operators and traders that obtain relevant new information indicating a product they placed or made available is at risk of non-compliance must inform competent authorities and downstream recipients. Non-SME downstream operators and non-SME traders have an additional statutory verification and stop condition before placing, making available, or exporting when they receive a substantiated concern.

The record should let a reviewer see why the product was treated as low-risk simplified due diligence or full due diligence. Keep the benchmark tier, production-location basis, Article 9 information file, supply-chain complexity review, mixing or circumvention conclusion, and statement or declaration reference together.

Operators keep due diligence statement records for five years. Downstream operators and traders keep Article 5(3) supply-chain information for at least five years and provide it to competent authorities on request. Record the country-risk decision with the evidence file rather than leaving it in a procurement note.