--- title: "EUDR country benchmarking and simplified due diligence" canonical_url: "https://www.sorena.io/artifacts/eu/deforestation-regulation/country-benchmarking-and-simplified-due-diligence" source_url: "https://www.sorena.io/artifacts/eu/deforestation-regulation/country-benchmarking-and-simplified-due-diligence" author: "Sorena AI" description: "How EUDR country-risk benchmarking affects low-risk simplified due diligence, full due diligence, information collection, risk monitoring, and evidence records." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EUDR country benchmarking" - "EUDR simplified due diligence" - "EU Deforestation Regulation low risk" - "EUDR Article 13" - "EUDR Article 29" - "EUDR" - "EU Deforestation Regulation" - "country benchmarking" - "simplified due diligence" - "deforestation-free" - "due diligence statement" - "geolocation" - "country risk" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EUDR country benchmarking and simplified due diligence How EUDR country-risk benchmarking affects low-risk simplified due diligence, full due diligence, information collection, risk monitoring, and evidence records. *EUDR* *Country risk* *EU* ## EUDR country benchmarking and simplified due diligence Use country-risk benchmarking only to decide whether EUDR low-risk simplification is available for a production country or part of a country. Low-risk status can reduce the risk-assessment and mitigation work, but it does not remove the Article 9 information file, the Article 3 compliance test, or recordkeeping. The EU Deforestation Regulation uses country benchmarking to classify countries or parts of countries as low, standard, or high risk. For operators, the main practical consequence grounded in the EUDR text is narrow: simplified due diligence may be available for relevant products produced in low-risk countries or parts of countries, but only after checking supply-chain complexity and risks of circumvention or mixing. Standard-risk and high-risk production should be treated as full due diligence unless a grounded low-risk classification and the Article 13 conditions are both met. ## What country benchmarking changes under EUDR 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. The EUDR text supports this operating rule: low-risk production may remove the need to perform Article 10 risk assessment and Article 11 risk mitigation only when the operator has also checked supply-chain complexity and risks of circumvention or mixing. The available source material does not provide a public list of specific low-risk or high-risk countries, so this page does not name countries. - Low-risk country or part of a country: check whether Article 13 simplified due diligence is available, then keep Article 9 information and evidence. - Standard-risk country or part of a country: do not use the low-risk simplification; run the full Article 9, Article 10, and Article 11 due diligence sequence. - High-risk country or part of a country: do not use the low-risk simplification; treat the product as requiring full due diligence unless another grounded EUDR rule applies. - Unknown or changed risk tier: pause the simplification decision until the Article 29 benchmark status and production location are verified. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the Article 29 benchmarking framework, including the initial standard-risk assignment and the Commission benchmark-list obligation. - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the scope rule that products must be deforestation-free, legal in the country of production, and covered by the required statement or declaration. ## When simplified due diligence is available 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 should not rely on the simplified route and should complete the normal risk assessment and mitigation work before placing the product on the market or exporting it. - Record the production country or part of country used for the benchmark decision. - Confirm that the relevant products were produced in the low-risk area, not merely shipped from it. - Check whether supply-chain complexity could hide non-low-risk origin, substitution, or mixed lots. - Document why circumvention or mixing risk is negligible before skipping Articles 10 and 11. - Keep documentation ready for competent authorities if they request proof of the low-risk simplification. Sources for this answer: - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the limits on Article 13 simplified due diligence for products produced in low-risk countries or parts of countries. *Recommended next step* *Placement: after evidence section* ## Build an EUDR country-risk evidence file Use this page to separate low-risk simplified due diligence from full EUDR due diligence, then keep the benchmark source, Article 9 information, statement identifiers, and risk-change log together. - [Open Research Copilot](/solutions/research-copilot.md): Check EUDR country-risk and due diligence questions against cited source material. - [Discuss EUDR implementation](/contact.md): Review EUDR scope, benchmark evidence, and due diligence record design with Sorena. ## Information that still has to be collected 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. - Commodity and relevant product classification tied to Annex I scope. - Supplier and upstream actor details connected to the exact lot, batch, or shipment. - Country of production and, where applicable, the part of country used for benchmarking. - Geolocation or allowed substitute location information where the EUDR simplified primary-operator rule applies. - Documentation showing deforestation-free production and production in accordance with relevant local law. - Due diligence statement reference number, simplified declaration identifier, or downstream supply-chain reference where applicable. Sources for this answer: - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the Article 9 information and evidence file, including geolocation and proof of deforestation-free and legal production. - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the limited simplified-declaration treatment for micro or small primary operators, including declaration identifiers and postal-address substitution. ## Monitoring risk-tier changes and new risk information 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 grounded stop condition before placing, making available, or exporting when information indicates non-compliance. - Recheck benchmark status before each new sourcing country, production-region change, or long-running supplier renewal. - Treat a move from low risk to standard or high risk as a trigger to restore Article 10 risk assessment and Article 11 mitigation. - Escalate supplier evidence that suggests mixing, circumvention, false origin, or missing production-location data. - Keep a log of new risk information, who reviewed it, which products it affects, and which authorities or recipients were notified where required. Sources for this answer: - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the duty for downstream operators and traders to act on new information indicating non-compliance risk. - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the Article 29 benchmark-list milestone that teams should track when maintaining country-risk decisions. ## Evidence records for low-risk and full due diligence decisions 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. Those retention rules make the country-risk decision an auditable evidence record, not just a procurement note. - Country benchmark record: country or part of country, source used, tier, date checked, and products covered. - Simplification memo: why Article 13 applies, how supply-chain complexity was assessed, and why circumvention or mixing risk is negligible. - Full due diligence record: Article 9 information, Article 10 risk assessment, Article 11 mitigation decision, and approval before placing or export. - Statement and declaration log: due diligence statement reference numbers, simplified declaration identifiers, authorised-representative submissions, and downstream communications. - Change-monitoring log: benchmark changes, new risk information, authority notifications, downstream-recipient notices, and resulting hold or release decisions. Sources for this answer: - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports five-year operator retention for due diligence statement records and supply-chain communication of reference numbers. - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports at-least-five-year retention of Article 5(3) information by downstream operators and traders. - [Commission Implementing Regulation (EU) 2024/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3084&ref=sorena.io) - Supports use of the EUDR information system as the channel connected to due diligence statements and simplified declarations. ## Primary sources - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Primary legal source for EUDR country benchmarking, low-risk and high-risk country-list mechanics, application timing, and the Article 29 benchmark framework. - Quote: "Commission must publish the benchmarking list of low-risk and high-risk countries or parts thereof." - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Extracted EUDR source support for Article 9 information collection, Articles 10 and 11 due diligence, Article 13 simplified due diligence, Article 5 monitoring, and five-year evidence records. - Quote: "Due diligence includes information collection (Article 9), risk assessment (Article 10), and risk mitigation (Article 11)." - [Commission Implementing Regulation (EU) 2024/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3084&ref=sorena.io) - Supports references to the EUDR information system used for due diligence statements and simplified declarations. - Quote: "Commission Implementing Regulation (EU) 2024/3084 (EUDR information system)" - [European Commission EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - Commission overview used for high-level EUDR context and application-date cross-checking without adding country-tier claims. - Quote: "EUDR overview (European Commission)" ## Related Topic Guides - [EU Deforestation Regulation FAQ](/artifacts/eu/deforestation-regulation/faq.md): Concise EU Deforestation Regulation answers on scope, covered commodities, operator and trader roles, due diligence statements, geolocation, low-risk countries, customs release, SME timing, enforcement, and records. - [EUDR Annex I product lookup: how to check scope](/artifacts/eu/deforestation-regulation/faq/annex-i-product-lookup.md): How to check whether a product is in EUDR Annex I, connect it to a covered commodity, and keep supplier and trade evidence without relying on unsupported code lists. - [EUDR Applicability Test: Products, EU Market Activity, and Actor Roles](/artifacts/eu/deforestation-regulation/applicability-test.md): Test whether the EU Deforestation Regulation applies by checking Annex I product scope, EU market placement or export, operator/trader status, downstream role, SME status, and simplified due diligence conditions. - [EUDR compliance checklist for products, suppliers, and DDS filing](/artifacts/eu/deforestation-regulation/checklist.md): A practical EU Deforestation Regulation checklist covering product scope, supplier evidence, geolocation, risk assessment, mitigation, due diligence statements, recordkeeping, and customs readiness. - [EUDR compliance obligations for operators and traders](/artifacts/eu/deforestation-regulation/compliance.md): Source-grounded EUDR compliance guide covering operator and trader duties, Article 9 information, Article 10 risk assessment, Article 11 mitigation, due diligence statements, records, and authority-readiness. - [EUDR country benchmarking FAQ: low, standard, and high risk](/artifacts/eu/deforestation-regulation/faq/country-benchmarking.md): What EUDR country benchmarking means, how low-risk production affects simplified due diligence, and what operators still need to collect. - [EUDR country benchmarking triage workflow](/artifacts/eu/deforestation-regulation/country-benchmarking-triage-workflow.md): Route EUDR consignments and suppliers after country benchmarking: low-risk simplification checks, standard or high-risk due diligence, monitoring triggers, and evidence records. - [EUDR customs and import release FAQ](/artifacts/eu/deforestation-regulation/faq/customs-and-import-release.md): How to prepare EUDR due diligence statement references, information-system handoffs, importer checks, and release evidence before customs or export clearance. - [EUDR DDS Reference Numbers: What to Record and Pass Down](/artifacts/eu/deforestation-regulation/faq/dds-reference-numbers.md): FAQ on EU Deforestation Regulation DDS reference numbers, including operator submissions, downstream handoffs, Article 33 information-system context, and evidence records. - [EUDR deadlines and compliance calendar](/artifacts/eu/deforestation-regulation/deadlines-and-compliance-calendar.md): A grounded EUDR calendar covering application dates, benchmarking milestones, the due diligence statement system, and preparation tasks for operators and traders. - [EUDR deadlines, phasing, and first actions](/artifacts/eu/deforestation-regulation/deadlines-phasing-and-what-to-do-first.md): Source-grounded EUDR readiness guide covering application dates, operator and trader first actions, geolocation evidence, due diligence statements, the information system, and country benchmarking. - [EUDR Due Diligence Statement Evidence: DDS records, geolocation, and supplier proof](/artifacts/eu/deforestation-regulation/due-diligence-statement-and-evidence.md): Build an EUDR evidence file for due diligence statements: Article 9 information, geolocation records, supplier proof, risk assessment, mitigation, reference numbers, and retention. - [EUDR due diligence statement filing workflow](/artifacts/eu/deforestation-regulation/dds-filing-workflow.md): A grounded workflow for filing EUDR due diligence statements: prerequisites, Article 33 information-system use, reference numbers, role handoffs, and records. - [EUDR Due Diligence Statement Template](/artifacts/eu/deforestation-regulation/eudr-due-diligence-statement-template.md): A source-grounded EUDR due diligence statement template covering operator data, product scope, geolocation evidence, risk conclusion, reference numbers, and attachment records. - [EUDR Geolocation Data Requirements: plots, suppliers, and DDS evidence](/artifacts/eu/deforestation-regulation/eudr-geolocation-data-requirements.md): How to collect, check, and use EUDR geolocation evidence for relevant commodities and products, Article 9 information, risk assessment, supplier records, and due diligence statements. - [EUDR Geolocation Evidence and Annex I Commodity Lookup](/artifacts/eu/deforestation-regulation/geolocation-evidence-and-commodity-lookup.md): Build an EUDR evidence file that links Annex I commodity scope, supplier and trader records, geolocation evidence, product lots, risk assessment, and due diligence statement support. - [EUDR geolocation plots and polygons FAQ](/artifacts/eu/deforestation-regulation/faq/geolocation-plots-and-polygons.md): How EUDR teams should collect, link, and use plot-level geolocation evidence for due diligence statements, suppliers, consignments, and risk assessment. - [EUDR Geolocation Traceability Systems: records, DDS handoffs, and supplier evidence](/artifacts/eu/deforestation-regulation/geolocation-traceability-and-systems.md): How to structure EUDR traceability records for geolocation, supplier evidence, product lots, risk assessment inputs, and due diligence statement handoffs. - [EUDR in-scope commodities and products](/artifacts/eu/deforestation-regulation/in-scope-commodities-and-products.md): How to check EUDR scope for the seven commodities, Annex I relevant products, operator and trader roles, and the evidence needed to support a scope decision. - [EUDR information system filing: DDS references and handoffs](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md): FAQ guidance on EUDR information system filing, due diligence statement submission, declaration identifiers, downstream handoffs, representatives, and evidence retention. - [EUDR non-negligible risk: what stops product release?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md): FAQ on how EUDR Articles 10 and 11 handle non-negligible risk, when operators should stop placement or export, and what evidence belongs in the file. - [EUDR operator, trader, and downstream roles FAQ](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md): How to classify EUDR operators, downstream operators, and traders, including market-placement triggers, DDS reference handoffs, non-SME duties, and evidence records. - [EUDR Penalties and Enforcement: Checks, Corrective Action, and Sanctions](/artifacts/eu/deforestation-regulation/penalties-and-enforcement.md): Grounded guide to EUDR enforcement: competent authority checks, interim measures, corrective action, EU penalty categories, and records to keep ready. - [EUDR Penalties, Fines, and Enforcement Consequences](/artifacts/eu/deforestation-regulation/penalties-and-fines.md): Grounded guide to EUDR enforcement exposure: Member State penalties, competent authority checks, corrective measures, product holds, and evidence records without invented national fine tables. - [EUDR requirements for operators, traders, and DDS filing](/artifacts/eu/deforestation-regulation/requirements.md): Source-grounded guide to EU Deforestation Regulation requirements: scope, due diligence, geolocation, risk assessment, mitigation, DDS filing, records, and simplified regimes. - [EUDR risk assessment and mitigation under Articles 10 and 11](/artifacts/eu/deforestation-regulation/risk-assessment-and-mitigation.md): How to run an EUDR Article 10 risk assessment, decide when risk is not negligible, apply Article 11 mitigation, and keep release evidence before placing products on the EU market or exporting. - [EUDR simplified due diligence: low-risk country evidence FAQ](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md): FAQ answer on when EUDR simplified due diligence applies, what Article 9 information remains required, when Articles 10 and 11 return, and what records to keep. - [EUDR SME timing: which dates apply to micro, small, and medium businesses?](/artifacts/eu/deforestation-regulation/faq/sme-timing.md): FAQ on EUDR SME timing, including the 30 December 2026 main application date, the 30 June 2027 later date for certain micro and small undertakings, and first evidence records to prepare. - [EUDR Supplier Evidence FAQ](/artifacts/eu/deforestation-regulation/faq/supplier-evidence.md): What supplier evidence to collect for EUDR Article 9 information, geolocation, risk assessment, due diligence statements, and downstream recordkeeping. - [EUDR Supplier Onboarding Template](/artifacts/eu/deforestation-regulation/supplier-onboarding-template.md): A practical EUDR supplier onboarding template for Annex I product scope, supplier roles, geolocation evidence, risk inputs, mitigation records, DDS references, and five-year records. - [EUDR vs CSDDD: product due diligence vs corporate due diligence](/artifacts/eu/deforestation-regulation/eudr-vs-csddd.md): Compare EUDR product-level deforestation controls with high-level corporate due-diligence workstreams, focusing on scope, actors, due diligence statements, geolocation, country benchmarking, and evidence. - [How is the EU Deforestation Regulation enforced?](/artifacts/eu/deforestation-regulation/faq/enforcement.md): EUDR FAQ on competent authority checks, evidence requests, due diligence records, and grounded non-compliance consequences. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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