The Commission has published its long-awaited Implementing Regulation with the list of EUDR high-risk/low risk countries, originally expected for June. Surprisingly, only 4 countries made the high-risk list (Russia, Myanmar, North Korea, Belarus). Brazil and Indonesia, which were expected to be classified as high-risk, have been labelled as standard risk.

The risk level determines the level of due diligence obligations that need to be carried out by importers, with imports from high-risk countries facing stricter due diligence obligations and enhanced scrutiny by authorities. The full high-low risk country list Annex is available here. Countries not present in the Annex of the Implementing Regulation are classified as having a standard risk.

NEXT STEPS

This Implementing Regulation is already directly applicable in all member states. As a reminder, EUDR will start applying on 30 December 2025 for large companies and on 30 June 2026 for SMEs.

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