EUDR Country Benchmarking: What They Mean for Due Diligence

Last week, a little earlier than expected, we received the  country-level classifications under its benchmarking system for the EU Deforestation-Free Regulation.

Ultimately, the benchmarking system is a tool to manage enforcement of the legislation by guiding how many audits are expected to be carried out by the competent authorities. The expected rates are:

• 1% of operators for low-risk countries
• 3% of operators for standard-risk countries
• 9% of operators for high-risk countries

A full list of the benchmarked countries can be found here.

Simplified Due Diligence for Low-Risk Countries

The Benchmarking system also brings a simplified due diligence for some. Operators sourcing exclusively from low-risk countries are still required to provide the information outlined in Article 9. But, are no longer expected to carry out risk assessments and risk mitigation requirements as described in Articles 10 and 11.

In practice, this means operators must still provide information such as:

• Geolocation of production plots,
• Country of origin,
• Description of goods,
• Supplier and operator information, and
• a statement confirming the goods are deforestation-free

However, they are not required to carry out additional assessments—such as evaluating the presence of Indigenous peoples, corruption levels, or the national prevalence of deforestation. Nor are they required to implement mitigation measures like audits, additional documentation, or risk management protocols – unless there is substantiated concern indicating potential non-compliance.

The EU has shared its criteria for determining these classifications, in Article 29(3), where they consider factors such as deforestation rates, land conversion for agriculture, and commodity production trends based on the latest FAO data.

Sharing this information with operators is an important milestone toward the full implementation of the EUDR by the end of 2025. The reduced due diligence does ease some of the burden, however, fundamentally, all operators must still comply with the basics of the EUDR legislation, which includes demonstrating through geolocation data that their products have not originated from deforested land.

Supporting Deforestation-free small suppliers

Trade in Space has been working on service for one-off checks and small batches – we’ve recognised the challenges smaller organisations are facing to prepare for EUDR, and even the desire for co-operatives and producer organisations to take advantage of preparedness, sustainable practises and profit from EUDR premiums.  Reach out to our team to find out more here.