The European Commission's country benchmarking system under Article 29 of Regulation (EU) 2023/1115 sets its first review for 2026, drawing on the updated FAO Global Forest Resources Assessment to reclassify producer countries as low, standard, or high risk. That shift changes the due diligence obligations operators owe under the EU Deforestation Regulation (EUDR). Any operator treating a current low-risk origin as a permanent status is underestimating what a reclassification does to their evidence workload.

The review lands in the same year operators become subject to EUDR obligations. On 18 December 2025 the Council adopted the targeted revision postponing EUDR application to 30 December 2026 for large and medium operators as well as for micro/small operators already covered by the EU Timber Regulation, with other micro and small operators covered from 30 June 2027. The first benchmark reshuffle and the first day of enforcement likely fall inside the same twelve months. Systems designed for today's country classification may need to run under a different one before they ever process a shipment.

What the 2026 benchmark review actually changes

The 2026 review is the first scheduled update to the country classification the Commission published in Implementing Regulation (EU) 2025/1093. It can move any producer country between low, standard, and high risk. The Regulation was adopted on 22 May 2025 under Article 29(2) of the EUDR. Its Annex lists the countries considered low or high risk for the seven in-scope commodities: cattle, cocoa, coffee, oil palm, rubber, soya, and wood.

The Commission has said the benchmarking process is dynamic, with a first review scheduled for 2026. That review will draw on the updated FAO Forest Resources Assessment (FRA) dataset, which FAO published in October 2025. All countries in the current classification were assessed against the quantitative criteria in Article 29(3): deforestation and forest degradation rates, expansion of agricultural land for relevant commodities, and production trends.

The classification is the operational reference. The Commission publishes and maintains the Country Classification List on its Green Forum platform for operators and Member State competent authorities. The tier that applies to a shipment is the tier in force at the moment the product is placed on the market, not the tier that applied when the supply contract was signed. A supplier agreement that runs from Q2 2026 into 2027 can start under one regime and end under another.

Operators sourcing the seven scope commodities from currently low-risk origins carry the largest exposure to an unfavourable reclassification. The compliance jump between low and standard risk is not a small uplift. It changes which articles of the EUDR the operator has to run for every shipment.

How risk tier drives due diligence intensity under Articles 10 and 13

Tier assignment determines whether operators run the full due diligence procedure or the simplified regime for low-risk sourcing. Sourcing from low-risk countries entails simplified due diligence. The operator must collect information but does not need to assess and mitigate risks. That still means gathering geolocation coordinates, legality documentation, and supplier attestations. Since the December 2025 amendment, the DDS is submitted only by the operator that first places the product on the EU market. Downstream operators retain that statement's reference number instead of filing their own, and micro or small primary operators may submit a one-time simplified declaration. What a low-risk classification removes is the Article 10 risk assessment and Article 11 mitigation work — not the underlying due diligence statement.

Standard and high-risk sourcing pull the operator back into the full Article 10 procedure. That means examining supplier information, considering deforestation indicators for the country and region, and documenting a conclusion that the risk is negligible before the DDS can be submitted. Where the assessment shows more than negligible risk, Article 11 mitigation applies. Mitigation can mean additional supplier audits, third-party verification, or dropping the source.

Enforcement intensity scales with tier as well. Member State competent authorities must check at least 1% of operators sourcing from low-risk countries, 3% for standard-risk and 9% for high-risk countries annually. A reclassification from low to standard risk triples the probability that any given operator sourcing from that country is picked for an authority check. A move from standard to high risk triples it again. That is the enforcement signal the compliance function needs to price into 2026 planning.

Geolocation obligations stay identical across tiers. What changes is the analytical work on top of the coordinates.

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Which sourcing origins carry the biggest exposure to a tier change

Operators sourcing the seven in-scope commodities from currently low-risk origins carry the biggest workflow exposure to an upward reclassification. Implementing Regulation (EU) 2025/1093 states that the risk of products not being deforestation-free varies depending on the country of origin and production. The Article 29 criteria are anchored in observable trends rather than fixed designations, which is why the Commission built in a review cycle at all. A country's tier in 2025 is not a guarantee of its tier in 2027.

The commodity mix drives exposure as much as the country. Cattle, cocoa, coffee, oil palm, rubber, soya, and wood each have different production geographies. An operator whose in-scope volumes concentrate in a single producing country carries binary tier risk: the whole book moves with the benchmark. A sourcing base spread across several producing countries absorbs a reclassification more smoothly, because only part of the volume shifts regime.

The downside asymmetry matters too. Moving from low to standard risk reinstates full Article 10 assessment and Article 11 mitigation for every shipment. Moving from standard to high risk keeps the same due diligence workflow but triples the authority check probability from 3% to 9%. Low-risk origins therefore concentrate operational rebuild risk, while standard-risk origins concentrate enforcement exposure.

Building a benchmark-resilient due diligence system before the review lands

Build your due diligence workflows to the standard-risk baseline, not the low-risk one. Standard-risk is the regime that runs the full Article 10 and Article 11 procedure under Implementing Regulation (EU) 2025/1093, and it is where any low-risk origin lands if its tier moves up. Systems built to that baseline absorb a reclassification without an emergency rebuild.

Collect the same evidence (plot-level geolocation, legality documentation, and supplier attestations) for every origin, even low-risk ones. The simplified regime still requires operators to gather this information, and the moment a country leaves the low-risk tier that same data has to feed a risk assessment. Collecting once is cheaper than collecting twice.

Contractual clauses that let the operator require additional traceability data, or switch suppliers, if a country's EUDR tier changes mid-contract carry the reclassification risk back to the source. The revision adopted by the Council on 18 December 2025 streamlined some due diligence requirements and postponed application, but it did not alter the country benchmarking mechanism. Contracts signed today for delivery across the 2026 review need to give the operator room to react to whatever the review concludes.

Tracking the Commission's benchmarking communications and the FAO FRA release cycle keeps the compliance team ahead of customers and authorities. The Country Classification List and the associated Staff Working Document are the primary channels. The Parliament resolution of 9 July 2025 on the initial implementing act, filed under procedure 2025/2739(RSP), confirms that the benchmarks are politically contested.

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How to approach reassessment around the 2026 update

A benchmark-focused reassessment starts with mapping the current supplier base against the country classification list, sorted by spend, volume, and commodity. That view shows where a reclassification would trigger the most rework, not only where it is statistically most likely. Concentration in a single low-risk origin is the clearest exposure signal in that map.

The next layer is a paper exercise: running each low-risk origin through the risk assessment it would face under a standard-risk designation, using data already on file. Gaps that appear in this exercise are the same gaps that would cause an Article 10 failure on day one of a reclassification. Closing them before the review is cheaper than closing them after.

Procurement and compliance benefit from a shared view of tier risk across multi-year contracts. A supplier in a country with a plausible upward tier move carries a compliance-cost premium that belongs in the total-cost calculation. Board and executive reporting on EUDR-scope commodities is more useful when benchmark exposure sits alongside volume and margin rather than in a separate compliance line. 

On 13 July 2026 the Commission adopted the Delegated Act updating the Annex I product scope and an Implementing Act on the Information System, completing the simplification package presented in May 2026. The Delegated Act has been sent to the European Parliament and Council for scrutiny and is not yet in force. The newly added products (soluble coffee, certain palm oil derivatives, frozen cattle tongues) become subject to the Regulation from 30 December 2027. Neither measure alters the Article 29 country benchmarking mechanism.

Where to start before the 2026 review

Start by confirming that the geolocation and legality evidence already on file for low-risk origins would survive an Article 10 assessment under a standard-risk designation. That single check exposes the largest operational tail hidden in the current sourcing book.

Frequently asked questions

What is the EUDR benchmarking and country classification system?

It is the mechanism under Article 29 of Regulation (EU) 2023/1115 by which the Commission classifies producer countries as low, standard, or high risk of producing EUDR-scope commodities that are not deforestation-free. The list was first set out in Implementing Regulation (EU) 2025/1093 and is maintained on the Commission's Green Forum platform.

When is the first benchmarking review?

The Commission has scheduled the first review of the country benchmarks for 2026. It is intended to take account of the updated FAO Global Forest Resources Assessment dataset, which was published in October 2025.

What countries are currently high risk under the EUDR?

The list of countries designated low or high risk sits in the Annex to Implementing Regulation (EU) 2025/1093 and is republished on the Commission's Country Classification List.

What is the EUDR risk assessment methodology?

The Commission assessed all countries against the quantitative criteria set out in Article 29(3) of the EUDR, using the FAO Forest Resources Assessment dataset. The criteria cover deforestation and forest degradation rates, expansion of agricultural land for relevant commodities, and production trends, complemented by qualitative factors such as enforcement of forest laws.

Does the December 2025 postponement change the benchmarking review?

No. The revision adopted by the Council on 18 December 2025 postpones application of the regulation to 30 December 2026 for large and medium operators as well as micro/small operators that are already subject to the EU Timber Regulation, and to 30 June 2027 for other micro and small operators. The Article 29 benchmarking system and its scheduled 2026 review are not affected.

https://environment.ec.europa.eu/publications/delegated-act-product-scope-eu-deforestation-regulation_en