EUDR country benchmarking: low, standard and high-risk explained
The EUDR sorts producing countries into three tiers — low, standard and high risk — and the tier changes how much due diligence you must do. [Reg. 2023/1115, Art. 29] The classification is set by Implementing Regulation (EU) 2025/1093. As at 9 July 2026: around 140 countries are low risk (including every EU member state); Belarus, North Korea (DPRK), Myanmar and Russia are high risk; everything not listed is standard. [Impl. Reg. 2025/1093]
What the three tiers mean for you
| Tier | Countries | What it changes |
|---|---|---|
| Low risk | ~140 countries, incl. all EU member states | Simplified due diligence: collect the information and confirm no red flags; full risk assessment and mitigation not required absent concern [Reg. 2023/1115, Art. 13] |
| Standard risk | Everything not listed as low or high (the default) | Full due diligence: information + risk assessment + mitigation until risk is negligible [Reg. 2023/1115, Art. 8–11] |
| High risk | Belarus, North Korea (DPRK), Myanmar, Russia | Full due diligence plus enhanced scrutiny by authorities; higher check rates [Reg. 2023/1115, Art. 29] |
Low risk does not mean no obligations
A common misreading: "my coffee is from a low-risk country, so I'm exempt." Not so. Low-risk origin unlocks simplified due diligence — you still collect the origin information, still need a geolocated supply chain, and (as the operator) still submit a DDS. [Reg. 2023/1115, Art. 13] What you save is the full Article 10–11 risk-assessment-and-mitigation cycle, unless you have reason to believe there is a problem.
The mixed-origin trap
The tiers can move — state the position, and its date
Country benchmarking is reviewed periodically, and a first review was expected in 2026. A country can be re-tiered, which changes the diligence you owe on that origin. [Impl. Reg. 2025/1093] For that reason a responsible answer always states the tier as at a date, citing Implementing Regulation (EU) 2025/1093, rather than treating a classification as permanent. Re-check your key origins before each deadline.
How to check a specific country
Look the country up in the Annex to Implementing Regulation (EU) 2025/1093. [Impl. Reg. 2025/1093] If it is listed as high risk, it is high; if it is listed as low risk, it is low; if it appears in neither list, it is standard by default. When in doubt, treat an origin as standard and run full due diligence — that is the safe direction to be wrong in.
General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free. Confirm your classification with counsel before relying on it for a market-access decision.
Find out where you actually stand
You don't need a traceability platform to start — you need to know your position and exactly what to ask your suppliers for. The EUDR position report screens your products against Regulation (EU) 2023/1115, names your role and deadline, tiers your origin countries, and hands you ready-to-send supplier data-request letters.
Check if my product is caught → get my EUDR position reportQuestions
What are the EUDR country risk tiers?
Low, standard and high risk. As at 9 July 2026, Implementing Regulation (EU) 2025/1093 classifies around 140 countries as low risk (including all EU member states), lists Belarus, North Korea (DPRK), Myanmar and Russia as high risk, and treats every country not listed as standard risk by default.
Which countries are high risk under the EUDR?
Under Implementing Regulation (EU) 2025/1093, the high-risk countries are Belarus, the Democratic People's Republic of Korea (North Korea), Myanmar and the Russian Federation. This can change at a benchmarking review, so confirm against the current implementing regulation.
Does a low-risk country mean I have no obligations?
No. A low-risk origin allows simplified due diligence — you still collect the origin information, still need a geolocated supply chain, and, as the operator, still submit a Due Diligence Statement. What is waived is the full risk-assessment and mitigation cycle, unless you have reason to suspect a problem.
What happens with mixed-origin shipments?
If a consignment blends commodity from more than one country, or the origin cannot be cleanly attributed to a country, the low-risk simplification is lost for the whole shipment and full due diligence applies. Keep origins separable and documented per plot.
Sources
- Implementing Regulation (EU) 2025/1093 (country risk benchmarking) — https://eur-lex.europa.eu/eli/reg_impl/2025/1093/oj — the country risk classification (low / high lists; standard as default); first review expected 2026.
- Regulation (EU) 2023/1115 (EU Deforestation Regulation) — https://eur-lex.europa.eu/eli/reg/2023/1115/oj — Art. 29 (three-tier country benchmarking), Art. 13 (simplified due diligence for low-risk), Art. 8–11 (full due diligence).
- European Commission — EUDR implementation, guidance & FAQ — https://green-business.ec.europa.eu/deforestation-regulation-implementation_en