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EUDR country risk list: every country under Implementing Regulation (EU) 2025/1093

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Since 26 May 2025 the European Commission's country list for the EUDR has applied: 140 low risk countries, four high risk countries, standard risk for everyone else. The level of the country of production decides whether simplified due diligence under Article 13 is enough, how deep the risk assessment under Article 10 has to go and how often the authorities check. This page lists every country with its level, the place in the legal act and its ISO code in one alphabetical table, explains the consequences per level and is available as an Excel file, in English and German.

Key facts

  • Legal basis. Article 29 of Regulation (EU) 2023/1115 provides for three levels: high, low and standard risk. The Commission classifies countries or parts thereof by implementing acts; when the Regulation entered into force on 29 June 2023, all countries were assigned a standard level of risk.
  • The list. Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025, published on 23 May 2025 and in force since 26 May 2025, names in its Annex 140 low risk countries and four high risk countries: Belarus, Myanmar, North Korea (Democratic People's Republic of Korea) and Russia (Russian Federation).
  • Default rule. There is no list of standard risk countries. Under Article 1(2) of the Implementing Regulation a standard level is maintained for all countries not listed, among them Brazil, Indonesia, Malaysia, Côte d'Ivoire, Colombia, Argentina, Cameroon and Nigeria.
  • Low risk. All 27 EU Member States, plus among others the United States, Canada, the United Kingdom, Norway, Switzerland, Türkiye, Ukraine, China, India, Vietnam, Thailand, Japan, South Korea, Australia, Ghana, Kenya, Chile and Uruguay.
  • Consequences. For low risk, simplified due diligence under Article 13 applies (no risk assessment and no risk mitigation, but information, geolocation and due diligence statement). For standard and high risk, full due diligence under Articles 10 and 11 applies. The authorities check at least 1 % of operators per year for low risk, 3 % for standard risk and 9 % for high risk, plus 9 % of the quantity for high risk (Article 16(8) to (10)).
  • Mixing. The simplification requires that all relevant commodities come from low risk countries and that there is only a negligible risk of circumvention or of mixing with goods of unknown origin or from standard or high risk countries (Article 13(1)).
  • Status. As at 17 October 2026 EUR-Lex shows the Implementing Regulation as in force, without an amending act. The Commission reviews the list and updates it as necessary (Article 29(2)).

As at 17 October 2026. Legal basis: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, consolidated version of 18 September 2026; Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025 (OJ L, 23 May 2025).

Legal basis: Article 29 and Implementing Regulation (EU) 2025/1093

Article 29 of Regulation (EU) 2023/1115 creates a three-tier system. High risk countries are those with an exceptionally high risk that relevant commodities are not produced deforestation-free; low risk countries offer sufficient assurance that such cases are exceptional; everything in between is standard risk (paragraph 1). From 29 June 2023 all countries had a standard level of risk; the Commission had to identify the low and high risk countries by implementing acts by 30 June 2025 and has reviewed the classification since, updating it as necessary (paragraph 2). The assessment is based primarily on the rate of deforestation and forest degradation, the rate of expansion of agricultural land for relevant commodities and production trends (paragraph 3), and may take into account further aspects such as agreements with the EU, national laws and their enforcement, transparency of data and sanctions imposed by the UN Security Council or the Council of the EU (paragraph 4).

Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025 puts this into effect. It has two articles and an Annex: Article 1(1) refers to the Annex for the low and high risk countries, Article 1(2) provides that a standard level is maintained for all countries not listed, and Article 2 sets the entry into force on the third day following publication in the Official Journal of 23 May 2025, that is on 26 May 2025. The Annex consists of two lists, “Low risk countries” and “High risk countries”; no parts of countries are classified. According to the recitals, the assessment relies primarily on the FAO Global Forest Resources Assessment and on the methodology described in a Commission Staff Working Document; the Commission itself states there that a large majority of countries worldwide are classified as low risk.

The classification has three functions, which the Implementing Regulation names expressly in recital 6: it steers the risk-based checks of the authorities under Article 16, it determines when simplified due diligence under Article 13 is available, and it has to be taken into account as criterion (a) in the risk assessment under Article 10. It classifies countries, not commodities: according to Commission FAQ 5.11 there is no “negligible risk” status for a particular commodity from a particular country.

The three levels and their consequences

What the level means for the operator is set out in Articles 10, 11, 13 and 16 of the Regulation. Geolocation and the due diligence statement are mandatory at all three levels; the simplification only concerns risk assessment and risk mitigation.

LevelCountriesOperator's due diligenceAnnual minimum check rateLegal basis
low140 (all 27 EU Member States and 113 third countries)Simplified due diligence under Article 13: collect the information under Article 9, including geolocation; assess the complexity of the supply chain and the risk of circumvention and mixing and document it on request; submit the due diligence statement. Risk assessment (Article 10) and risk mitigation (Article 11) do not apply as long as there is no indication of a risk.1 % of operators, downstream non-SME operators and non-SME traders (Article 16(10))Article 13, Article 29(1), point (b); Annex to the Implementing Regulation
standard53 (every country not listed)Full due diligence: information under Article 9, risk assessment under Article 10 with all 14 criteria, risk mitigation under Article 11 down to negligible risk, due diligence statement.3 % (Article 16(8))Articles 10 and 11, Article 29(1), point (c); Article 1(2) of the Implementing Regulation
high4 (Belarus, Myanmar, North Korea, Russia)Full due diligence as for standard risk; the classification is criterion (a) of the risk assessment and weighs accordingly.9 % of operators, downstream non-SME operators and non-SME traders and 9 % of the quantity of each relevant product (Article 16(9))Articles 10 and 11, Article 29(1), point (a); Annex to the Implementing Regulation

The Regulation knows one exception for micro and small primary producers and natural persons established in a low risk country who produce there themselves: under Article 4a they submit a one-off simplified declaration and may replace the geolocation with the postal address (details in the article on supplier geodata). How the authorities in Germany apply the check rates is explained in the article on enforcement and penalties; the overall picture is in the EUDR guide.

The list: every country in alphabetical order

The table lists 197 countries: the 193 member states of the United Nations, the observer states Palestine (listed in the Annex) and Vatican City, and Kosovo and Taiwan, which appear as separate countries in EU customs procedures. 140 countries are low risk, 4 high risk, 53 standard risk. Country names are given in their short form; where the Annex uses a different designation, the wording is shown in the note. The ISO code is the two-letter code under ISO 3166-1, as used by the Information System for the country of production. Use your browser's search function (Ctrl+F or Cmd+F) to find a country.

CountryISOLevelBasis in the legal actNote
AfghanistanAFlowAnnex: low risk countries
AlbaniaALlowAnnex: low risk countries
AlgeriaDZlowAnnex: low risk countries
AndorraADlowAnnex: low risk countries
AngolaAOstandardArt. 1(2): not listed in the Annex
Antigua and BarbudaAGlowAnnex: low risk countries
ArgentinaARstandardArt. 1(2): not listed in the Annex
ArmeniaAMlowAnnex: low risk countries
AustraliaAUlowAnnex: low risk countries
AustriaATlowAnnex: low risk countriesEU Member State.
AzerbaijanAZlowAnnex: low risk countries
BahamasBSlowAnnex: low risk countries
BahrainBHlowAnnex: low risk countries
BangladeshBDlowAnnex: low risk countries
BarbadosBBlowAnnex: low risk countries
BelarusBYhighAnnex: high risk countriesWood from Belarus is in addition subject to the EU sanctions import ban in place since 2022.
BelgiumBElowAnnex: low risk countriesEU Member State.
BelizeBZstandardArt. 1(2): not listed in the Annex
BeninBJstandardArt. 1(2): not listed in the Annex
BhutanBTlowAnnex: low risk countries
BoliviaBOstandardArt. 1(2): not listed in the Annex
Bosnia and HerzegovinaBAlowAnnex: low risk countries
BotswanaBWstandardArt. 1(2): not listed in the Annex
BrazilBRstandardArt. 1(2): not listed in the Annex
Brunei DarussalamBNlowAnnex: low risk countries
BulgariaBGlowAnnex: low risk countriesEU Member State.
Burkina FasoBFstandardArt. 1(2): not listed in the Annex
BurundiBIlowAnnex: low risk countries
Cabo VerdeCVlowAnnex: low risk countries
CambodiaKHstandardArt. 1(2): not listed in the Annex
CameroonCMstandardArt. 1(2): not listed in the Annex
CanadaCAlowAnnex: low risk countries
Central African RepublicCFlowAnnex: low risk countries
ChadTDstandardArt. 1(2): not listed in the Annex
ChileCLlowAnnex: low risk countries
ChinaCNlowAnnex: low risk countries
ColombiaCOstandardArt. 1(2): not listed in the Annex
ComorosKMlowAnnex: low risk countries
Congo (Democratic Republic of the)CDstandardArt. 1(2): not listed in the AnnexNot listed in the Annex; not to be confused with the Republic of the Congo (low risk).
Congo (Republic of the)CGlowAnnex: low risk countriesIn the Annex: “Congo”. Republic of the Congo (Brazzaville). The Democratic Republic of the Congo is not listed in the Annex.
Costa RicaCRlowAnnex: low risk countries
Côte d'IvoireCIstandardArt. 1(2): not listed in the Annex
CroatiaHRlowAnnex: low risk countriesEU Member State.
CubaCUlowAnnex: low risk countries
CyprusCYlowAnnex: low risk countriesEU Member State.
CzechiaCZlowAnnex: low risk countriesEU Member State.
DenmarkDKlowAnnex: low risk countriesEU Member State.
DjiboutiDJlowAnnex: low risk countries
DominicaDMlowAnnex: low risk countries
Dominican RepublicDOlowAnnex: low risk countries
EcuadorECstandardArt. 1(2): not listed in the Annex
EgyptEGlowAnnex: low risk countries
El SalvadorSVstandardArt. 1(2): not listed in the Annex
Equatorial GuineaGQstandardArt. 1(2): not listed in the Annex
EritreaERstandardArt. 1(2): not listed in the Annex
EstoniaEElowAnnex: low risk countriesEU Member State.
EswatiniSZlowAnnex: low risk countries
EthiopiaETstandardArt. 1(2): not listed in the Annex
FijiFJlowAnnex: low risk countries
FinlandFIlowAnnex: low risk countriesEU Member State.
FranceFRlowAnnex: low risk countriesEU Member State.
GabonGAlowAnnex: low risk countries
GambiaGMstandardArt. 1(2): not listed in the Annex
GeorgiaGElowAnnex: low risk countries
GermanyDElowAnnex: low risk countriesEU Member State.
GhanaGHlowAnnex: low risk countries
GreeceGRlowAnnex: low risk countriesEU Member State.
GrenadaGDlowAnnex: low risk countries
GuatemalaGTstandardArt. 1(2): not listed in the Annex
GuineaGNstandardArt. 1(2): not listed in the Annex
Guinea-BissauGWstandardArt. 1(2): not listed in the Annex
GuyanaGYlowAnnex: low risk countries
HaitiHTstandardArt. 1(2): not listed in the Annex
HondurasHNstandardArt. 1(2): not listed in the Annex
HungaryHUlowAnnex: low risk countriesEU Member State.
IcelandISlowAnnex: low risk countries
IndiaINlowAnnex: low risk countries
IndonesiaIDstandardArt. 1(2): not listed in the Annex
IranIRlowAnnex: low risk countriesIn the Annex: “Iran (Islamic Republic of)”.
IraqIQlowAnnex: low risk countries
IrelandIElowAnnex: low risk countriesEU Member State.
IsraelILstandardArt. 1(2): not listed in the Annex
ItalyITlowAnnex: low risk countriesEU Member State.
JamaicaJMlowAnnex: low risk countries
JapanJPlowAnnex: low risk countries
JordanJOlowAnnex: low risk countries
KazakhstanKZlowAnnex: low risk countries
KenyaKElowAnnex: low risk countries
KiribatiKIlowAnnex: low risk countries
KosovoXKstandardArt. 1(2): not listed in the AnnexNot listed in the Annex; standard risk under Article 1(2).
KuwaitKWlowAnnex: low risk countries
KyrgyzstanKGlowAnnex: low risk countries
LaosLAlowAnnex: low risk countriesIn the Annex: “Lao People's Democratic Republic”.
LatviaLVlowAnnex: low risk countriesEU Member State.
LebanonLBlowAnnex: low risk countries
LesothoLSlowAnnex: low risk countries
LiberiaLRstandardArt. 1(2): not listed in the Annex
LibyaLYlowAnnex: low risk countries
LiechtensteinLIlowAnnex: low risk countries
LithuaniaLTlowAnnex: low risk countriesEU Member State.
LuxembourgLUlowAnnex: low risk countriesEU Member State.
MadagascarMGlowAnnex: low risk countries
MalawiMWstandardArt. 1(2): not listed in the Annex
MalaysiaMYstandardArt. 1(2): not listed in the Annex
MaldivesMVlowAnnex: low risk countries
MaliMLlowAnnex: low risk countries
MaltaMTlowAnnex: low risk countriesEU Member State.
Marshall IslandsMHlowAnnex: low risk countries
MauritaniaMRstandardArt. 1(2): not listed in the Annex
MauritiusMUlowAnnex: low risk countries
MexicoMXstandardArt. 1(2): not listed in the Annex
MicronesiaFMlowAnnex: low risk countriesIn the Annex: “Micronesia (Federated States of)”.
MoldovaMDlowAnnex: low risk countriesIn the Annex: “Republic of Moldova”.
MonacoMClowAnnex: low risk countries
MongoliaMNlowAnnex: low risk countries
MontenegroMElowAnnex: low risk countries
MoroccoMAlowAnnex: low risk countries
MozambiqueMZstandardArt. 1(2): not listed in the Annex
MyanmarMMhighAnnex: high risk countriesCheck the sanctions position in addition.
NamibiaNAstandardArt. 1(2): not listed in the Annex
NauruNRlowAnnex: low risk countries
NepalNPlowAnnex: low risk countries
NetherlandsNLlowAnnex: low risk countriesEU Member State. Listed as “Netherlands (Kingdom of the)”.
New ZealandNZlowAnnex: low risk countries
NicaraguaNIstandardArt. 1(2): not listed in the Annex
NigerNEstandardArt. 1(2): not listed in the Annex
NigeriaNGstandardArt. 1(2): not listed in the Annex
North KoreaKPhighAnnex: high risk countriesIn the Annex: “Democratic People's Republic of Korea”.
North MacedoniaMKlowAnnex: low risk countries
NorwayNOlowAnnex: low risk countries
OmanOMlowAnnex: low risk countries
PakistanPKstandardArt. 1(2): not listed in the Annex
PalauPWlowAnnex: low risk countries
PalestinePSlowAnnex: low risk countriesListed as “Palestine” in the Annex.
PanamaPAstandardArt. 1(2): not listed in the Annex
Papua New GuineaPGlowAnnex: low risk countries
ParaguayPYstandardArt. 1(2): not listed in the Annex
PeruPEstandardArt. 1(2): not listed in the Annex
PhilippinesPHlowAnnex: low risk countries
PolandPLlowAnnex: low risk countriesEU Member State.
PortugalPTlowAnnex: low risk countriesEU Member State.
QatarQAlowAnnex: low risk countries
RomaniaROlowAnnex: low risk countriesEU Member State.
RussiaRUhighAnnex: high risk countriesIn the Annex: “Russian Federation”. Wood from Russia is in addition subject to the EU sanctions import ban in place since 2022.
RwandaRWlowAnnex: low risk countries
Saint Kitts and NevisKNlowAnnex: low risk countries
Saint LuciaLClowAnnex: low risk countries
Saint Vincent and the GrenadinesVClowAnnex: low risk countries
SamoaWSlowAnnex: low risk countries
San MarinoSMlowAnnex: low risk countries
São Tomé and PríncipeSTlowAnnex: low risk countries
Saudi ArabiaSAlowAnnex: low risk countries
SenegalSNstandardArt. 1(2): not listed in the Annex
SerbiaRSlowAnnex: low risk countries
SeychellesSClowAnnex: low risk countries
Sierra LeoneSLstandardArt. 1(2): not listed in the Annex
SingaporeSGlowAnnex: low risk countries
SlovakiaSKlowAnnex: low risk countriesEU Member State.
SloveniaSIlowAnnex: low risk countriesEU Member State.
Solomon IslandsSBlowAnnex: low risk countriesIn the Annex: “Solomon Island”.
SomaliaSOstandardArt. 1(2): not listed in the Annex
South AfricaZAlowAnnex: low risk countries
South KoreaKRlowAnnex: low risk countriesIn the Annex: “Republic of Korea”.
South SudanSSlowAnnex: low risk countries
SpainESlowAnnex: low risk countriesEU Member State.
Sri LankaLKlowAnnex: low risk countries
SudanSDstandardArt. 1(2): not listed in the Annex
SurinameSRlowAnnex: low risk countries
SwedenSElowAnnex: low risk countriesEU Member State.
SwitzerlandCHlowAnnex: low risk countries
SyriaSYlowAnnex: low risk countriesListed as “Syrian Arab Republic”; the German version carries two entries (“Arabische Republik” and “Syrien”).
TaiwanTWstandardArt. 1(2): not listed in the AnnexNot listed in the Annex; standard risk under Article 1(2).
TajikistanTJlowAnnex: low risk countries
TanzaniaTZstandardArt. 1(2): not listed in the Annex
ThailandTHlowAnnex: low risk countries
Timor-LesteTLlowAnnex: low risk countries
TogoTGlowAnnex: low risk countries
TongaTOlowAnnex: low risk countries
Trinidad and TobagoTTlowAnnex: low risk countries
TunisiaTNlowAnnex: low risk countries
TürkiyeTRlowAnnex: low risk countriesGerman version of the Annex: “Türkei”.
TurkmenistanTMlowAnnex: low risk countries
TuvaluTVlowAnnex: low risk countries
UgandaUGstandardArt. 1(2): not listed in the Annex
UkraineUAlowAnnex: low risk countries
United Arab EmiratesAElowAnnex: low risk countries
United KingdomGBlowAnnex: low risk countriesIn the Annex: “United Kingdom of Great Britain and Northern Ireland”.
United StatesUSlowAnnex: low risk countriesIn the Annex: “United States of America”.
UruguayUYlowAnnex: low risk countries
UzbekistanUZlowAnnex: low risk countries
VanuatuVUlowAnnex: low risk countries
Vatican CityVAstandardArt. 1(2): not listed in the AnnexNot listed in the Annex; standard risk under Article 1(2).
VenezuelaVEstandardArt. 1(2): not listed in the Annex
VietnamVNlowAnnex: low risk countries
YemenYElowAnnex: low risk countries
ZambiaZMstandardArt. 1(2): not listed in the Annex
ZimbabweZWstandardArt. 1(2): not listed in the Annex

How to read the column “Basis in the legal act”: “Annex” means the country is named in the respective list of the Annex; “Art. 1(2)” means the country is not listed and therefore has standard risk under the default rule. Dependent territories such as Hong Kong, Greenland or French Guiana are not listed separately in the Annex; the legal act classifies countries and does not say whether a territory shares the level of its parent country. Clarify such cases with the competent authority and document the answer.

Several countries of production, mixing and parts of countries

What counts is the country of production of the commodity, not the supplier's seat and not the country of further processing. For furniture made in Vietnam, the country where the wood was harvested counts; for pulp, the plantation or harvesting area; for coffee that comes through a trader in Hamburg, the country of the plot. How this plays out per commodity is shown in the sector articles on coffee and cocoa, timber, rubber, palm oil, paper and furniture imports.

If a product contains commodities from countries at different levels, there is no partial simplification. Article 13(1) allows operators to dispense with risk assessment and risk mitigation only where they have ascertained that all relevant commodities were produced in low risk countries, after assessing the complexity of the supply chain and the risk of circumvention or of mixing with products of unknown origin or from standard or high risk countries. A piece of furniture made in Vietnam with veneer from Indonesia is subject to full due diligence; plywood or pellets that may contain wood of unclear origin carry the risk of the riskiest possible origin. If the operator obtains information pointing to non-compliance or circumvention, it must fulfil all obligations under Articles 10 and 11 regardless of the simplification and inform the competent authority without delay (Article 13(2)).

Article 29 allows the Commission to classify parts of countries as well. The first list does not; every classification applies to the whole country. A region with high deforestation in a low risk country does not change the level, but belongs in the assessment of the circumvention and mixing risk and, for standard risk, in criteria (b) and (f) of the risk assessment.

Download: the list as Excel

The Excel file contains the full table with autofilter (sheet “Country list”), the three levels with due diligence, check rate and legal basis (sheet “Levels and consequences”) and notes on source, status, coverage and country names (sheet “Notes”). It may be used freely and imported into your own systems; the legal act in the Official Journal prevails.

Status, updates and change log

The Commission reviews the classification and updates it as necessary (Article 29(2)); a reclassification of individual countries would come as an amending implementing regulation in the Official Journal. As at 17 October 2026 EUR-Lex shows Implementing Regulation (EU) 2025/1093 as in force, without an amending act and without an end date; the list has been unchanged since 26 May 2025. Reclassifications are announced in advance: before changing a country's risk category the Commission formally notifies the country concerned of its intention, states the reasons and informs the competent authorities (Article 29(6)); with countries classified as high risk or at risk of such classification it engages in a dialogue (paragraph 5). We check the status whenever this page is maintained and record changes here. Set a reminder for your main origins so that a reclassification does not surface at the next customs clearance; the EUDR status page tracks the ongoing legal changes.

DateEventReference
29 June 2023Entry into force of Regulation (EU) 2023/1115; all countries are assigned a standard level of risk.Article 29(2)
22 May 2025The Commission adopts Implementing Regulation (EU) 2025/1093 with the first list: low risk and high risk countries.Implementing Regulation (EU) 2025/1093, Annex
23 May 2025Publication in the Official Journal of the European Union, L series.OJ L, 2025/1093
26 May 2025Entry into force on the third day following publication.Article 2 of the Implementing Regulation; EUR-Lex “Date of effect”
17 October 2026Check on EUR-Lex: in force, no amending act, no end date. List unchanged.EUR-Lex, document 32025R1093

How Polygon One helps

In Polygon One the risk level of the country of production comes from the EU benchmarking under Implementing Regulation (EU) 2025/1093; it sits next to the satellite comparison of every plot with its state on 31 December 2020 and the evidence that an AI reads and matches to the right supplier, country and commodity, for each delivery. Which role and which depth of due diligence applies to you is shown by the EUDR check in two minutes; what the software covers overall is on the EUDR product page.

Frequently asked questions

Which countries are high risk under the EUDR?

Four: Belarus, Myanmar, North Korea (in the Annex “Democratic People's Republic of Korea”) and Russia (“Russian Federation”), Annex to Implementing Regulation (EU) 2025/1093. Goods from there are subject to full due diligence, and the authorities check at least 9 % of operators and 9 % of the quantity of each product per year (Article 16(9)). Wood from Russia and Belarus is in addition subject to the import ban under EU sanctions.

Which countries are low risk?

140 countries: all 27 EU Member States and 113 third countries, among them the United States, Canada, the United Kingdom, Norway, Iceland, Switzerland, Türkiye, Ukraine, Serbia, China, India, Vietnam, Thailand, Sri Lanka, Japan, South Korea, Australia, New Zealand, Ghana, Kenya, South Africa, Chile, Uruguay, Costa Rica and Papua New Guinea. The full list is in the table above and in the Excel file.

Is there a list of standard risk countries?

No. The Annex names only low and high risk; under Article 1(2) of the Implementing Regulation a standard level is maintained for all countries not listed. Of the 197 countries in the table this applies to 53, among them Brazil, Indonesia, Malaysia, Côte d'Ivoire, Colombia, Peru, Honduras, Argentina, Paraguay, Cameroon, Nigeria, Liberia, Cambodia and the Democratic Republic of the Congo. In the table they carry the note “Art. 1(2): not listed in the Annex”.

Does the list of May 2025 still apply, and when will it change?

Yes. As at 17 October 2026 EUR-Lex shows Implementing Regulation (EU) 2025/1093 as in force, date of effect 26 May 2025, without an end date and without an amending act. The Commission reviews the classification and updates it as necessary by an amending implementing regulation (Article 29(2) of the Regulation). As soon as one appears, we record it in the change log on this page.

What applies if a product contains commodities from countries at different levels?

Then full due diligence applies to the whole product. Simplified due diligence under Article 13(1) requires the operator to have ascertained that all relevant commodities were produced in low risk countries and that there is only a negligible risk of circumvention or of mixing with goods of unknown origin or from standard or high risk countries. A piece of furniture made in Vietnam with veneer from Indonesia therefore falls under full due diligence.

Does the supplier's country count, or the country of production?

The country of production of the commodity. The supplier's seat, the country of further processing and the country of dispatch play no role for the level. For furniture from Vietnam with wood from Indonesia, Indonesia counts (standard); for pulp, the plantation or harvesting area; for coffee, the plot. In the due diligence statement the country of production is given per plot with the two-letter ISO code.

Do I still have to provide geodata and submit a due diligence statement for low risk?

Yes. Article 13 only dispenses with the risk assessment under Article 10 and the risk mitigation under Article 11. The information under Article 9 including geolocation, the assessment of supply chain complexity and of the circumvention and mixing risk, and the due diligence statement remain mandatory. Only micro and small primary producers and natural persons established in a low risk country who produce there themselves submit a one-off simplified declaration under Article 4a and may give the postal address instead of the geolocation.

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650 (consolidated version of 18 September 2026, EUR-Lex), Articles 2, 4a, 9, 10, 11, 13, 16 and 29. Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025 (OJ L, 2025/1093, 23 May 2025; EUR-Lex: in force, date of effect 26 May 2025, retrieved 17 October 2026), Articles 1 and 2 and Annex. Commission FAQ on the EUDR, version 5 (April 2026, revised 21 August 2026), question 5.11. As at 17 October 2026. This article is not legal advice.

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