On 22 May, the European Commission adopted an implementing act establishing the country benchmarking system under the EU Deforestation Regulation (EUDR). This assessment is binding for the purposes of due diligence systems and for placing wood and wood‑based products on the EU market.
What are the EUDR requirements for placing products on the market originating from low‑risk countries?
It is commonly understood that companies may apply simplified due diligence under the EUDR — but what does this actually mean?
As the name suggests, “simplified due diligence” does not mean the absence of due diligence.
Let’s look more closely at what the Regulation requires.
Operators must still verify compliance with all relevant local laws in the country of production.
The legality requirement applies regardless of the risk classification.
Article 3 of the EUDR does not exempt operators sourcing from low‑risk countries from submitting a due diligence statement.
Article 13 explicitly requires companies to collect data, including geolocation data (Article 9).
The same article states that such companies are not required to carry out a full risk assessment or apply risk‑mitigation measures.
However, they must perform a parallel assessment and provide documentation demonstrating negligible risk with respect to:
If this simplified assessment identifies more than negligible risk, companies must then carry out the full due diligence process.
Simplified due diligence includes the following obligations:
High‑risk countries were selected based on UN and EU sanctions, not on direct evidence of deforestation or forest degradation risk.
In principle, sourcing from high‑risk countries is still permitted unless other international bans apply (as in the case of Russia).
Unless the European Commission issues further updates, companies must follow the standard due diligence process.
The only difference lies in enforcement and checks:
LOW‑RISK COUNTRIES
Afghanistan, Albania, Algeria, Andorra, Antigua and Barbuda, Armenia, Azerbaijan, Australia, Austria, Bahamas, Bahrain, Bangladesh, Barbados, Belgium, Bhutan, Bosnia and Herzegovina, Brunei Darussalam, Bulgaria, Burundi, Cabo Verde, Canada, Central African Republic, Chile, China, Comoros, Congo, Costa Rica, Croatia, Cuba, Cyprus, Czech Republic, Denmark, Djibouti, Dominica, Dominican Republic, Egypt, Estonia, Finland, France, Germany, Greece, Greenland, Guatemala, Honduras, Iceland, India, Indonesia, Iran, Iraq, Ireland, Italy, Japan, Jordan, Kazakhstan, Kenya, Kuwait, Latvia, Lebanon, Liechtenstein, Lithuania, Luxembourg, Madagascar, Malaysia, Malta, Mauritius, Mexico, Monaco, Mongolia, Montenegro, Morocco, Namibia, Netherlands, New Zealand, Niger, North Macedonia, Norway, Oman, Pakistan, Panama, Paraguay, Peru, Philippines, Poland, Portugal, Qatar, Romania, San Marino, Saudi Arabia, Serbia, Singapore, Slovakia, Slovenia, South Africa, South Korea, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Thailand, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom, United States, Uruguay, Vietnam, Zambia, Zimbabwe.
STANDARD‑RISK COUNTRIES
Angola, Argentina, Belize, Benin, Bolivia, Botswana, Brazil, Burkina Faso, Cambodia, Cameroon, Chad, Colombia, Democratic Republic of the Congo, Ecuador, El Salvador, Ivory Coast, Ethiopia, Ghana, Guinea, Guyana, Haiti, Indonesia, Laos, Liberia, Malaysia, Mali, Mozambique, Nepal, Nicaragua, Nigeria, Papua New Guinea, Peru, Senegal, Sierra Leone, Somalia, Sudan, Syria, Tanzania, Togo, Uganda, Venezuela, Yemen.
HIGH‑RISK COUNTRIES
