EUDR country benchmarking

EUDR country benchmarking is Article 29. The risk list is an implementing act, not this page

Direct answer. In the consolidated text of Regulation (EU) 2023/1115, CELEX 02023R1115-20260918 (EN, 18.09.2026), Article 29 is titled “Assessment of countries.” It establishes a three-tier system: high risk, low risk, and standard risk for countries or parts thereof that are neither. Article 29(2) says that on 29 June 2023 all countries shall be assigned a standard level of risk, and that the list of countries or parts thereof that present a low or high risk shall be published by means of implementing acts, adopted under the examination procedure in Article 36(2), no later than 30 June 2025. That list, as EUR-Lex states it, is Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025. Its Article 1 says the countries that present a low or high risk shall be those listed in the Annex, and that a standard level shall be maintained for all countries not listed in the Annex. This page does not paste that annex. For low-risk sourcing, Article 13 is simplified due diligence, and only in the words that article uses. Application dates are the scope guide. This page is not legal advice.

EUDR Records Manager (Shopify App Store · Write a review) keeps a supplier and commodity-lot registry with DDS reference numbers per product, flags missing supplier, country, or DDS fields, and keeps an audit trail of supplier, lot, document, and export changes. The listing does not say the app classifies a country’s risk or submits a due diligence statement. Who files the statement is operator versus trader.

Related: CRALedger Duty Records — CRA duty records before an Article 14 incident. Does not file ENISA notifications.

Free check first: EUDR product scope check runs in your browser and sends nothing. Type a product or HS code and see which EUDR Annex I lines it may touch.

Checklist before you treat a source country as low risk

What Article 29 calls the three categories

Article 29(1) says Member States and third countries, or parts thereof, shall be classified into one of the following risk categories. High risk refers to countries or parts thereof for which the assessment in paragraph 3 results in the identification of a high risk of producing in such countries or in parts thereof relevant commodities for which the relevant products do not comply with Article 3, point (a). Low risk refers to countries or parts thereof for which that assessment concludes that there is sufficient assurance that instances of producing relevant commodities for which the relevant products do not comply with Article 3, point (a), are exceptional. Standard risk refers to countries or parts thereof which do not fall in either the category high risk or the category low risk.

Article 29(2), as replaced in that consolidation, says the list of the countries or parts thereof that present a low or high risk shall be published by means of implementing acts, no later than 30 June 2025, and that the list shall be reviewed, and updated if appropriate, as often as necessary in light of new evidence. The act EUR-Lex publishes for that list is Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025, laying down rules for the application of Regulation (EU) 2023/1115 as regards a list of countries that present a low or high risk of producing relevant commodities for which the relevant products do not comply with Article 3, point (a). It cites Article 29(2) as its legal basis. Open the Annex on EUR-Lex for the names. This page does not copy them.

What Article 13 says changes for low-risk sourcing

Article 13 is titled “Simplified due diligence.” Article 13(1) says that, when placing relevant products on the market or exporting them, operators shall not be required to fulfil the obligations under Articles 10 and 11 where, after having assessed the complexity of the relevant supply chain and the risk of circumvention of this Regulation or the risk of mixing with products of unknown origin or origin in high-risk or standard-risk countries or parts thereof, they have ascertained that all relevant commodities and relevant products have been produced in countries or parts thereof that were classified as low risk in accordance with Article 29. In such cases, the operator shall make available to the competent authority upon request relevant documentation demonstrating that there is a negligible risk of circumvention of this Regulation or of mixing with products of unknown origin or origin in high-risk or standard-risk countries or parts thereof.

Article 13(2) says that, if the operator obtains or is made aware of relevant information, including as a result of the assessment in paragraph 1 and including substantiated concerns submitted under Article 31, that would point to a risk that the relevant products do not comply with the Regulation or that the Regulation is circumvented, the operator shall fulfil all of the obligations under Articles 10 and 11 and shall immediately communicate any relevant information to the competent authority. Article 13(3) is the competent-authority sentence on circumvention, including where commodities or products produced in a standard-risk or high-risk country or part thereof are subsequently processed in a low-risk country or part thereof. This page does not add a step Article 13 does not state. The statement fields themselves are the due diligence statement example.

What this page is not

Related pages

Not legal advice. Confirm Article 29 and Article 13 on the live consolidated text, and the Annex to Implementing Regulation (EU) 2025/1093, before you treat a source country as low risk. The app stores records you enter. It does not classify country risk.