There’s been much talk about country benchmarking for the upcoming European Union Deforestation Regulation (EUDR), and for good reason. A country’s classification as high, standard or low risk could significantly influence commodity sourcing decisions.
Rumours and speculations can be put to rest. The European Commission (EC) has confirmed that just four countries are considered to be at high risk of deforestation: Belarus, North Korea, Myanmar, and Russia.
A total of 140 countries have been classed low risk, including all EU member states, leaving around 50 countries. Being neither high nor low risk, it’s assumed those countries - which include palm oil producing Indonesia and Malaysia, as well as major soy and beef producer Brazil - are at standard risk.
What is EUDR benchmarking?
The EUDR benchmarking system classes countries according to deforestation risk for seven key commodities: cattle, cocoa, coffee, oil palm, rubber, soy, and wood. Products derived from these commodities also fall under the scope of the EUDR.
Classifying countries into one of three risk categories will facilitate operators’ (including food and beverage manufacturers) due diligence processes and help authorities monitor and enforce compliance. “Additionally, it will incentivise countries to improve the sustainability of their agricultural production systems and minimise their deforestation impact,” explains the Commission.
From a due diligence perspective, sourcing from low-risk countries will be much simpler than from high-risk ones. For the latter, operators will be required to assess and mitigate risks.
The classification is subject to change and a first review of country benchmarking is scheduled for 2026.
All four high-risk countries under EU council sanctions
When one thinks of deforestation, it’s unlikely Belarus, North Korea, Myanmar and Russia are the first countries that come to mind.
According to NGO Earthsight, these countries are responsible for just 0.07% of imports of commodities relevant to the EUDR.
While imports into the EU are low, these countries are plagued by deforestation. According to Global Forest Watch, between 2020 and 2024 Russia lost 5.59m hectares of natural forest, equating to 816m tonnes of CO2.
Although deforestation in these countries is not publicised to the same extent as major palm oil or soy producing countries, their high risk classification is far from a surprise.
Earlier this year, the Commission suggested ‘special attention’ would be paid to countries under EU Council or UN Security Council sanctions as part of the benchmarking process. All four high-risk countries are under EU Council sanctions.
EUDR country benchmarking classification “a farce”
Although the vast majority of countries are considered low risk, many are critical of the classifications.
In Malaysia, a country considered standard risk, palm oil sector representatives told local media the Commission showed favouritism to its own member states by ranking them low risk.
Environmental group Mighty Earth has described the classification “a farce”, arguing that key countries with the “worst levels” of deforestation have been omitted from the high risk category.
“The risk benchmarking was supposed to reflect the likelihood that products such as beef, soy, palm oil, coffee, cocoa and timber entering the EU originated in areas that have been recently deforested or were produced illegally,” responds Mighty Earth policy director Julian Oram. “Instead, the risk list published today shows that it was based on political horse trading and favouritism.”
The NGO takes issue with Canada, Ghana, Papua New Guinea, and Romania’s low risk ranking, which Oram describes as “nonsensical”, ignoring “evidence of deforestation, forest degradation, and illegality” linked to commodities being imported from those countries for the EU market.