On May 20, the European Commission published its long-awaited Country Classification List for the implementation of the EU Deforestation Regulation (EUDR), a milestone many businesses have been waiting for in order to better navigate compliance requirements.
The list classifies countries into three risk categories for deforestation and forest degradation: low risk, standard risk and high risk.
This three-tier country categorization system is key as it determines the level of due diligence obligations that in-scope companies (operators and traders) must fulfill when placing commodities or relevant products (goods) or making them available on the EU market. In addition, such classification allows national competent authorities to define and plan their annual compliance checks as part of their risk-based approach.
EUDR Due Diligence for Goods Produced in Low-Risk Countries:
For countries classified as low risk, the EUDR requires simplified due diligence as apposed to full due diligence. While in-scope companies still need to collect information, they are not required to conduct a risk assessment or risk mitigation. This results in less extensive compliance requirements.
EUDR Due Diligence for Goods Produced in either Standard and High-Risk Countries:
In-scope companies sourcing from standard and high-risk countries (or regions within them) are subject to the same due diligence requirements. In addition to gathering relevant information about the commodity or product, this level of due diligence entails conducting a risk assessment and mitigating identified risks.
While EUDR due diligence requirements for high-risk countries are the same as those for countries categorized as standard risk, products from high-risk countries will be subject to enhanced scrutiny by EU competent authorities.[1]
Only Four High-Risk Countries: Questioning the Logic Behind EUDR Classifications
One of the most controversial elements of the EUDR Country Classification List is the logic underlying the classification. The approach taken by the European Commission does not appear to be based primarily on actual deforestation risks. Instead, it seems heavily influenced by geopolitical considerations, especially when categorizing a country as high-risk.
The list designates only four countries as “high risk”: Belarus, Myanmar, North Korea and Russia. The classification is justified solely by the fact that these countries are subject to UN Security Council or EU Council sanctions on the import or export of relevant commodities. According to the EU Commission, due diligence cannot be meaningfully conducted in such contexts, justifying their automatic high-risk status. While this in practice may be true, an exclusively sanction-driven focus as this one risks of overlooking regions with substantial ongoing forest loss.
Forests Under Pressure: The Real Risks
It is important to revisit why regulations like the EUDR exist in the first place. Forest ecosystems are globally under increasing pressure. Wood is in high demand across industries, from packaging and construction to textiles and even weapon manufacturing. At the same time, large-scale deforestation continues in many regions to make way for agricultural expansion, particularly for cattle grazing, palm oil, coffee, and soy production.
But forests are vital not only for biodiversity and climate regulation but also for purifying air and water and supporting the livelihoods of millions of people. They act as critical carbon sinks, helping to mitigate climate change and prevent soil erosion.
In a recent project we conducted on paper-based packaging and deforestation risks, we found that despite the rise in certification schemes on forest management (e.g., FSC, PEFC), deforestation and forest degradation are continuing at an alarming rate.
The social and environmental risks tied to wood and agricultural commodities are growing. Reforestation is becoming increasingly difficult due to the compounded effects of climate change and ecosystem degradation, and monoculture plantations simply cannot replicate the functions of natural forest ecosystems.
The Origins and Requirements of EUDR Due Diligence
The EUDR came into life seeking to prevent deforestation and forest degradation driven by EU demand on certain commodities and to “bring down greenhouse gas emissions and biodiversity loss”.[2] [For more information, check our blogpost on the five things you should know about the EUDR].
The regulation requires companies placing or making available any of the relevant commodities or products on the EU market, or exporting from it, to demonstrate that their products neither originate from deforested land nor contribute to forest degradation.
In addition to proving that the commodity or relevant product is legal (i.e. it has been procuded in accordance with relevant legislation of the country of production) and providing a due diligence statement for each of them, companies are required to show that the commodity or product is also “deforestation-free”,[3] i.e., sourced from land that has remained forested and undegraded since 31 December 2020[4].
Why the Current List May Undermine the Regulation’s Goals
At the core of the EUDR lies the prevention of deforestation and forest degradation. Given the objectives of the EUDR, such classification may divert attention away from where it is most needed.
For instance, countries such as Brazil and Indonesia, are widely recognized for their significant deforestation risks, particularly those linked to large-scale agricultural expansion for commodities like soy, palm oil, and cattle. But these concerns are not limited to tropical regions. Even within the European Union, forest degradation remains a serious issue, even though these have been classified as low risk in the list.
Our recent research highlighted extensive forest degradation risks in Sweden and Finland, where intensive logging practices have put ecosystems under pressure and adversely affected the Sámi people, Europe’s only officially recognized Indigenous population, who depend on intact forest landscapes for traditional reindeer herding practices.
Romania presents another case that illustrates the complexity of the issue. Despite being part of the EU, the country has faced persistent challenges with illegal logging and poor forest governance. Ancient and biodiverse forest areas, including parts of the Carpathian Mountains, have been heavily impacted. These forests are not only vital for biodiversity and carbon storage but are also home to some of Europe’s last remaining virgin woodlands.
A Misalignment with the Risk-Based Approach
Based on our conversations with clients, businesses are indeed looking forward to a clear country classification to help them operationalize the EUDR requirements. However, in our view, the country classification list, in its current form, may undermine the risk-based approach that lies at the heart of human rights and environmental due diligence. It is not aligned with the real risks associated with sourcing relevant commodities and products globally.
What Companies Conducting EUDR Due Diligence Should Know
Companies should not rely solely on the EU’s Country Classification List when conducting due diligence under the EUDR. A risk-based approach, grounded in credible data, stakeholder engagement, and supply chain specifics, remains essential for identifying and mitigating deforestation and forest degradation risks, regardless of a country’s official label. Only then can companies come closer to tackling real deforestation and forest degradation risks in their supply chains where it is most pressing and needed.
Lisa and Cecilia for the CORE team
[1] See Art. 16 (3) of the EUDR. Competent authorities will follow a risk-based approach when determining which checks to conduct on companies. The law lists several factors to be considered, among which, the country’s risk level, based on the classification system to be established by the EU Commission, with special attention on high-risk countries. See also EU Commission Staff Working Document on the methodology used for the benchmarking system (22.05.2025) page 1.
[2] European Commission, Regulation on Deforestation-free Products
[3] Art. 3 of the EUDR
[4] Art. 2 (13) of the EUDR
