The EU Deforestation Regulation requires the European Commission to classify countries according to their risk of producing EUDR covered commodities that are not deforestation-free. The Commission adopted its country classifications late last week, in anticipation of compliance with the Regulation being required starting December 30. Country risk classifications are important to operators and traders since low risk country sourcing results in simplified due diligence relating to risk assessments and risk mitigation. Country risk classifications also determine EU member state competent authority compliance checks. In this post, we discuss the new country risk classifications and provide reference tables indicating the assigned risk levels of all countries.
Under the implementing regulation adopted by the European Commission, countries that present a low or high deforestation risk are listed on an Annex to that regulation (naming conventions below are those used in the Annex). Countries not listed in the Annex are categorized as standard risk. The Commission’s Country Classification List is available here.
Low Risk Countries
As reflected below, well in excess of a majority of countries are listed as low risk. Notably, the United States is in this category. As discussed in this Ropes & Gray post, constituencies on both sides of the US political aisle have had significant concerns about the potential effects of the EUDR on US paper and pulp producers in particular.
High Risk Countries
In contrast, a small number of countries have been characterized as high risk.
Standard Risk Countries
As noted above, countries not expressly listed on the Annex to the implementing regulation as low or high risk are to be treated as standard risk. The following countries fall into the standard risk category.
Many operators had been advocating for a much shorter standard risk country list. Many producer countries also have been vocal in their opposition to the Regulation. Of particular note, Brazil, Indonesia and Malaysia are classified as standard risk.
Risk Methodology; Future Updates
Under the Deforestation Regulation, the classification of low risk and high risk countries is to be based on an objective and transparent assessment by the European Commission, taking into account the latest scientific evidence and internationally recognized sources. The classification must be based primarily on the following assessment criteria:
- Rate of deforestation and forest degradation;
- Rate of expansion of agriculture land for relevant commodities; and
- Production trends of relevant commodities and of relevant products.
The implementing act adopting the country risk classifications was accompanied by a Staff Working Document outlining the benchmarking methodology used by the European Commission. The assessment is based on latest available data from the Global Forest Resources Assessment dataset by the UN Food and Agriculture Organization. Parroting back the statutory requirement, the Commission indicated that its methodology is “firmly rooted in a commitment to fairness, objectivity and transparency.”
Country risk classifications can change over time since the benchmarking process will be dynamic. The first review is scheduled for 2026. This review is intended to take updated October 2025 FAO FRA data into account.
About the Deforestation Regulation
The EUDR covers cattle, cocoa, coffee, oil palm, rubber, soy(a) and wood, as well as many derived products. The Regulation begins to apply to operators and traders on December 30. For further information on the Deforestation Regulation, including the due diligence requirement, see these Ropes & Gray posts (among others on this topic):
