Sourcing from Low-Risk Countries — Simplified EUDR Due Diligence

EUDR Sourcing from Low-Risk Countries — A Practical Guide

The EUDR classifies producer countries (or parts of them) into three deforestation-risk tiers: low, standard and high. Sourcing exclusively from low-risk countries unlocks a simplified due diligence pathway that materially reduces the workload — provided you handle the procedure correctly. This page is the practical, operational version. For the legal basis see the country benchmarking page on eudr.live.

What "low-risk" actually means

"Low risk" is a Commission classification under Article 29 EUDR, applied at country (or sub-country) level on the basis of independent and verifiable information. The classification has three legal effects:

• The level of checks performed by competent authorities on operators sourcing from that country is reduced.
• The due diligence obligation is simplified: less information, narrower legality verification, no new mandatory mitigation steps when no risk indicators trigger.
• The new small and micro primary operator regime (created by the December 2025 revision) only applies to non-timber products sourced from low-risk countries.

"Low risk" is not the same as "exempt". Operators still place products on the EU market, still submit a due diligence statement, and still bear liability if they have actual knowledge or grounds to suspect that a specific shipment is non-compliant.

The simplified due diligence procedure, step by step

Below is the workflow once a country (or region within it) is on the low-risk list and your sourcing falls within it. Use this as your internal procedure template.

1. Verify the classification. The country benchmarking is published in an Annex to a Commission implementing act and updated periodically. Check the version in force on the date you place the product on the EU market, not the date of contract. If the country was reclassified to standard or high during your supply window, the simplified procedure does not apply to that batch.
2. Confirm sourcing exclusivity. The simplified pathway only applies if the entire production lot for the consignment originates in low-risk territory. Mixed sourcing (low + standard) reverts to standard due diligence. Document this exclusivity with supplier-level evidence (purchase orders, contracts, weight/volume records).
3. Collect the reduced information set. You still need: HS code, product description, quantity, country of production, supplier identity, and geolocation of the production plots. The geolocation requirement does not disappear — the EUDR does not waive it for low-risk imports. What changes is the depth of legality verification and the volume of documentary evidence on associated risks.
4. Run a narrowed legality check. Verify that the product complies with the laws of the country of production that are relevant to EUDR: forestry/agricultural land use, environmental permits, indigenous and local community rights, and anti-corruption rules touching the supply chain. You do not need to verify open-ended host-country legal compliance (taxation, employment, etc.) under EUDR.
5. Assess risk indicators. Even within a low-risk country, certain risk indicators — presence of armed conflict, sanctions, complex supply chains routed through transformation countries, evidence of mixing with non-low-risk material — trigger an obligation to escalate to standard due diligence. List these triggers in your internal SOP.
6. Submit the due diligence statement. Through the EUDR Information System (accessed via EU SWE-C). Tag the statement as relying on the simplified procedure and reference the country benchmarking version.
7. Retain documents for 5 years. The retention period is the same as standard due diligence. Authorities can request these documents during the period.

Information that you still need to collect

Data category	Standard due diligence	Simplified (low-risk)
HS code, description, quantity	Required	Required
Country of production	Required	Required
Supplier identity	Required	Required
Geolocation (GPS) of plots	Required	Required (no exemption)
Open-ended legality verification	Required	Narrowed to EUDR-relevant law
Full documentary evidence on each risk factor	Required	Reduced — evidence proportionate to risk
Mandatory mitigation measures	Required if non-negligible risk	Only if a risk indicator triggers

Common pitfalls

• Assuming geolocation is waived. It is not. The geolocation requirement is a Article 9 EUDR obligation that applies regardless of risk classification.
• Relying on outdated benchmarking. The Commission updates the country list. The version that matters is the one in force on the date of placing on the market.
• Mixed sourcing. A single batch with even a small fraction of standard-risk-country material falls out of the simplified pathway.
• Risk indicators ignored. Sanctions, armed conflict in producer regions, or evidence of supply-chain mixing escalate you back to full due diligence even if the country is on the low-risk list.
• Treating low-risk as exempt internally. Train staff, retain documents, and submit statements. "Low risk" is not "no obligation".

What the April 2026 simplification package may change

The April 2026 simplification package is expected to include updated FAQs and an implementing act on the EUDR Information System that further refine the low-risk procedure. Watch in particular for:

• Whether geolocation for low-risk imports moves toward farm-management-unit references rather than per-plot GPS (this is one of Germany's BMLEH proposals from 30 March 2026, but no commitment yet).
• Whether the legality narrowing is codified in a delegated act or remains in guidance.
• Whether the small/micro primary operator regime gets practical detail on collective regional reporting.

Related guides

• Due Diligence System — the full standard procedure, for comparison.
• Risk Assessment — how to identify the risk indicators that may escalate you out of the simplified pathway.
• Geolocation Requirements — the GPS data you need regardless of country risk.
• SME Guide — for small and micro operator-specific obligations.
• Country Benchmarking (legal background) on eudr.live.