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Country benchmarking

Art. 29 of Reg. (EU) 2023/1115 directs the Commission to publish a country (or sub-country) benchmark classifying every jurisdiction by deforestation risk. The first benchmark was adopted as Implementing Reg. (EU) 2025/1093 on 22 May 2025.

The three tiers

Low risk: substantially below average chance of producing covered commodities that fail the Art. 3 tests. Unlocks Art. 13 simplified due diligence.- Standard risk: the default. Full Art. 8(2) due-diligence pipeline applies (collect → assess → mitigate).- High risk: substantially above-average risk. The full pipeline applies plus enhanced supplier-information requirements; competent authorities are directed to check ≥ 9 % of operators sourcing from these countries (Art. 16(2)).

The first benchmark (22 May 2025) classified only four countries as high risk: Belarus, North Korea, Myanmar, Russia. The vast majority of the world is currently standard-risk; a smaller set is low-risk.

The engine returns the live table at /v1/reference/countries. The source-of-truth file is bundled at data/country_benchmarks_2025_1093.json.

What changes per tier

Step	Low	Standard	High
Art. 9 info collection	required	required	required
Art. 10 risk assessment	skipped (simplified DD)	required	required
Art. 11 mitigation	skipped (simplified DD)	when assessment is not negligible	when assessment is not negligible
Supplier-information thresholds	baseline	baseline	enhanced (Art. 10(2)(c))
Member-State check rate target	1 %	3 %	9 % (Art. 16(2))
Substantiated-concern handling (Art. 31)	same	same	competent authority must act faster

Simplified due diligence (Art. 13) in detail

Triggered when the operator can demonstrate that all sourcing within the consignment is from low-risk countries. Exclusivity, not majority. The simplified path waives Art. 10 + Art. 11; the operator still owes Art. 9 information collection, the mixing test, and the DDS itself.

If even one plot in the consignment is in a standard- or high-risk country, the consignment is not eligible for simplified DD.

When the benchmark changes

The Commission must review the list at least every 5 years (Art. 29(3)). First review by 30 June 2028. The Commission can re-classify a country at any time via a new implementing act. The engine reads the table from disk on every request, so a deployer can drop in an updated country_benchmarks_2025_1093.json (or its successor) without restarting the server.

The engine emits a warning at startup if the bundled table is older than 180 days, prompting the deployer to refresh.

How to check a country

curl https://eudr.dev/v1/reference/countries | jq '.countries.IDN'

returns the tier and any sub-national qualifiers for Indonesia. The response is cacheable (24-hour Cache-Control + strong ETag).

Authoritative sources

Implementing Reg. (EU) 2025/1093 (CELEX: 32025R1093, published 22 May 2025).
Reg. (EU) 2023/1115 Art. 13 + Art. 16 + Art. 29.