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.

If relevant information or a substantiated concern points to non-compliance or circumvention, Article 13(2) requires the operator to carry out the Article 10 assessment and Article 11 mitigation and immediately communicate the relevant information to the competent authority. Keep the concern, authority notification, assessment and outcome with the affected product records; the low-risk country label does not preserve simplification in that case.

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.

Use Commission Implementing Regulation (EU) 2025/1093 for the current low- and high-risk lists. Its Annex lists, for example, Germany, the United States, China, and Ghana as low risk; Belarus, the Democratic People's Republic of Korea, Myanmar, and the Russian Federation are the high-risk countries. Brazil is not on either list and therefore remains standard risk under Article 1(2). These are classifications under that act, not permanent labels.

Because the Commission may review and update the list when new evidence warrants it, record the act and date checked rather than copying an unversioned country tier into a supplier record.

Match the benchmark to the country or part of country where the commodity was produced, not the supplier's address, exporter location, or port of shipment. Then document the product origin and any mixing or circumvention risk before relying on low-risk simplified due diligence.