The European Union's Deforestation Regulation (EUDR) was adopted in 2023 and enters into application by the end of 2026. The EUDR is designed to stop products linked to deforestation from entering the EU market by requiring companies to trace their supply chains and prove legality and sustainability. 

To make this process more targeted, the EU introduced a risk benchmarking system that classifies countries into low, standard, and high-risk categories based on their deforestation risk profiles. This guide explains what simplified due diligence means for operators sourcing from low-risk countries and what obligations remain unchanged.

What is EUDR country risk benchmarking?

The EUDR requires the European Commission to classify countries based on their deforestation risk. The classification determines the level of due diligence operators must conduct when sourcing commodities from those countries.

The risk classification was adopted via Commission Implementing Regulation (EU) 2025/1093 on 22 May 2025. Under the three-tier system, countries are classified as low, standard, or high risk. The classification is reviewed periodically.

For a detailed breakdown of how the risk classification works and how it affects your specific due diligence obligations, see our EUDR country risk benchmarks guide.

What does simplified due diligence mean in practice?

Operators sourcing products exclusively from countries classified as low-risk are entitled to simplified due diligence under Article 13 of the EUDR. Simplified due diligence means:

• You must still collect all information required under Article 9 (geolocation, production dates, legality documentation, etc.)
• You must still establish and maintain a due diligence system under Article 12
• You are not required to carry out risk assessment (Article 10) or risk mitigation (Article 11) — unless you obtain or become aware of information indicating a risk of non-compliance

This significantly reduces the compliance burden for operators sourcing from low-risk countries. However, information collection remains mandatory.

What stays the same regardless of country risk?

Several obligations apply to all operators regardless of the country risk classification of their supply chains:

• Full due diligence must be conducted for any commodities sourced from standard- or high-risk countries or parts thereof
• A Due Diligence Statement (DDS) must be submitted for each shipment placed on the EU market or exported
• If new information arises indicating non-compliance — even for low-risk sourcing — the operator must revert to full due diligence for those products
• The due diligence system must be reviewed at least annually
• All documentation must be retained for at least five years

What about downstream operators and traders?

Under Regulation (EU) 2025/2650, downstream operators and traders no longer submit their own DDS or perform due diligence. Their obligation is limited to collecting and retaining reference numbers passed on by their direct upstream supplier. Non-SME downstream operators must register in the EUDR Information System.

SME and non-SME traders who purchase from downstream operators or traders (rather than directly from an upstream operator) are not required to collect DDS reference numbers. Their obligation is limited to basic business partner information (name, address, email).

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June 2026 update: Risk list adopted and guidance clarified

The country risk classification was formally adopted via Commission Implementing Regulation (EU) 2025/1093 on 22 May 2025 and is now in force. The adopted classification results in 51% of importing operators qualifying for simplified due diligence under Article 13 — significantly above the 20% projected in the original EUDR impact assessment.

The Guidance Document (3rd edition, published 4 May 2026) provides important operational clarifications for operators sourcing from low-risk countries. For supply chains, production areas, and countries of production where an initial examination of available information indicates a negligible risk of non-compliance with Article 3(b) (legality), operators are not required to carry out in-depth data collection. Specifically, they should not be required to: systematically collect comprehensive legal documentation for each individual plot of land; obtain specific document types such as individual land titles; or compile an exhaustive list of all potentially relevant laws and legal documents.

Micro and small primary operators are, by definition under the EUDR, established in low-risk countries. They are therefore generally not required to carry out risk assessment or risk mitigation under Articles 10 and 11, unless they obtain or become aware of information indicating a non-negligible risk of non-compliance. Their due diligence system, in practice, consists primarily of information collection under Article 9, and they submit a one-off simplified declaration rather than a DDS per shipment.

FAQ — EUDR due diligence for low-risk countries

1. Do I still need to submit a DDS if I source from a low-risk country?

Yes. Simplified due diligence reduces your information collection and risk assessment obligations, but you still need to submit a Due Diligence Statement for each shipment. The DDS must include geolocation, production date, commodity details, and a compliance declaration.

2. Can I skip geolocation collection if my supplier is in a low-risk country?

No. Geolocation is a core information requirement under Article 9 and applies regardless of country risk classification. The simplification for low-risk sourcing is that you do not need to assess the risk or apply mitigation measures — but you still need to collect the full set of information.

3. What if I discover a risk of non-compliance while sourcing from a low-risk country?

If you become aware of information pointing to a risk of non-compliance — for example, evidence of deforestation near a supplier's plots — you must revert to full due diligence for that product. Simplified due diligence is conditional on the absence of new risk signals.

4. Does simplified due diligence apply to traders?

Traders do not conduct due diligence under the revised EUDR, regardless of country risk. Their obligations are limited to collecting and retaining reference numbers from their direct upstream supplier (if that supplier is an operator). Country risk classification is only relevant to operators performing due diligence.