EU Deforestation Regulation Country benchmarking under the EUDR

Country benchmarking is the Article 29 system that assigns countries, or parts of countries, to a low, standard, or high risk category for EUDR purposes. The category is about the country-of-production risk context; it does not decide by itself whether a shipment, product line, supplier, or plot complies with the Regulation.

Use the benchmark as one input in the EUDR due diligence file. The starting question remains whether the product is a relevant commodity or relevant product under Annex I and whether it can meet the Article 3 conditions: deforestation-free, produced in accordance with relevant legislation of the country of production, and covered by the required due diligence statement or simplified declaration.

For relevant products produced in a country, or part of a country, classified as low risk under Article 29, Article 13 can relieve operators from the Article 10 risk assessment and Article 11 risk mitigation steps. That relief is conditional: the operator must still assess supply-chain complexity and the risk of circumvention or mixing with products from other origins, and must be able to show documentation demonstrating negligible risk.

Low-risk status therefore narrows the due diligence work only after the operator has confirmed the production origin and checked for mixing or circumvention. It should not be used as a blanket rule for every supplier invoice, warehouse lot, or product batch connected to the country.

Low-risk benchmarking does not remove Article 9 information collection. Operators still need information and evidence for the relevant product, including production origin, geolocation of plots or establishments where required, and documentation showing the product is deforestation-free and produced in accordance with relevant legislation of the country of production.

The operator also still needs the required EUDR submission route. The Regulation describes due diligence statements through the Article 33 information system, and simplified declarations for micro or small primary operators where the amended Regulation allows them. Downstream operators and traders still need the required supply-chain information, including due diligence statement reference numbers or declaration identifiers when those apply.

Do not name country lists unless the page is citing the current official Commission list or implementing act used for that claim. A country name copied into static guidance can become misleading if the official list changes, if the classification applies only to part of a country, or if the product's real production origin differs from the trading route.

A safer public answer is to explain how the benchmark category affects the due diligence analysis, then require the working file to capture the exact official source, the country or part of country, the date the list was checked, the production-origin evidence, and the conclusion on mixing or circumvention risk.