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).
See also
Authoritative sources
- Implementing Reg. (EU) 2025/1093 (CELEX: 32025R1093, published 22 May 2025).
- Reg. (EU) 2023/1115 Art. 13 + Art. 16 + Art. 29.
This page last changed on . It describes the Regulation as it stood then; where a date or a code matters to a decision, check it against the EUR-Lex text it cites.