On May 22, the European Commission (EC) released its long-awaited country benchmarking classifications under the EU Deforestation Regulation (EUDR). This system classifies 194 countries by deforestation risk across seven commodities—cattle, cocoa, coffee, oil palm, rubber, soy, and wood—marking a key milestone in the EC’s rollout of the EUDR. For many in the environmental and policy world though, the results were both underwhelming and deeply concerning.
After years of development, one might have expected a risk classification tool robust enough to help companies navigate the complex terrain of global sourcing. Instead, the rankings are poised to mislead businesses into thinking certain countries are “low risk” when the realities on the ground tell a very different story.
A Narrow Lens on Risk
At the heart of the problem is the methodology. The EUDR sets out dual requirements: products placed on or exported from the EU market must be both “deforestation-free” and “produced in compliance with the laws of the country of origin.”
However, the EC’s benchmarking appears to focus overwhelmingly on deforestation metrics and existing EU political sanctions—giving little attention to equally critical issues like governance, corruption, and law enforcement capacity. Findings from Forest Trends’ Illicit Harvest, Complicit Goods report further underscore the problem: illegal deforestation and associated commodity trade are widespread in many countries currently labeled as “low” or “standard” risk according to the EC scores. In fact, estimates suggest there is up to 50–90% illegal deforestation in some tropical countries—a level of illegality that cannot be ignored when assessing risk.
This is not a minor oversight. More than a decade of implementing laws like the EU Timber Regulation, US Lacey Act, and Australia’s Illegal Logging Prohibition Act has shown that corruption, weak governance, and limited enforcement capacity are some of the clearest signals of risk—and essential for directing enforcement efforts where they matter most.
Who’s High Risk? Only the Diplomatically Convenient
Surprisingly, only Russia, Belarus, Myanmar, and North Korea were classified as “high risk.” These are all countries already under EU Council sanctions for other reasons, making them politically safe choices with little chance of diplomatic blowback.
Meanwhile, countries with long-standing forest governance concerns—Congo, Central African Republic, Papua New Guinea, South Sudan, Solomon Islands—were all marked as low risk, grouped alongside the likes of Finland, Norway, and the United States. The result is not just misleading—it actively undermines the regulation’s credibility.
Re-Export Hubs and Laundering Loopholes
The inconsistencies continue when it comes to global trade hubs. The risk of laundering and obfuscating origin is real and well documented. Major re-export centers like China, India, and Singapore also receive low-risk labels, despite their documented roles in transshipment processing, and/or re-exporting high-risk materials in ways that obscure original country of harvest. Even more striking is that Turkey and Kazakhstan, which the EC itself has flagged for laundering banned Russian-origin plywood, remain listed as low risk—a troubling disconnect. Without stronger safeguards, the current country classifications could further incentivize this kind of circumvention.
A Better Lens: Forest Trends’ IDAT Risk Scores
To help importers and enforcement agencies, Forest Trends developed the Illegal Deforestation and Associated Trade (IDAT) Risk scores in 2017, which offer a more comprehensive view of risk by incorporating indicators of governance quality, corruption, law enforcement capacity, and conflict from credible sources, such as the World Bank, UN agencies, the Economist Intelligence Unit, and other global governance and environmental data providers. Combined with commodity-specific legal risk data, this approach yields a clearer picture of where due diligence should be strongest. Despite their diverse origins, these indices show strong alignment in relative country rankings.
The 2025 IDAT Risk scores classify 104 countries as high risk, 54 as medium risk, and 53 as low risk. These classifications offer a sharper, more grounded assessment of supply chains.
Tales of Two Risk Scores: EC vs Forest Trends’ Scores
The Republic of the Congo is labeled “low risk” under the EC’s EUDR benchmarks, yet Forest Trends’ IDAT Risk scores assess it as high risk due to persistent governance weaknesses and its World Bank designation as a state with high fragility. Forest loss surged 150% in 2024, largely driven by illegal logging and unsustainable land use—closely tied to governance and institutional breakdowns. These are not the signs of a low-risk sourcing environment.
Transshipment hubs are overlooked by the EUDR benchmarks, despite the substantial role they play in today’s complex global supply chains. Re-export hubs like China and Vietnam, both classified as low risk, are in fact major importers and processors of raw materials from high-risk countries—often obscuring true origin and complicating verification efforts. Even more concerning, the EC itself has launched investigations into rising imports of banned Russian birch plywood entering through Turkey and Kazakhstan— also countries labeled low risk by the EUDR but higher risk by Forest Trends’ IDAT Risk scores. These gaps suggest that the current classifications will incentivize transshipment and laundering through countries deemed low risk.
The Bottom Line on the EC Scores: Handle with Caution
For a regulation meant to be a gold standard for global deforestation-free supply chains, this first round of benchmarking is a missed opportunity. Without a fuller picture that includes governance, legality, and institutional risk, companies would do well to treat these rankings with caution. Due diligence remains their responsibility—and in many cases, the risks run deeper than the EC’s classifications suggest.
Relying solely on EUDR benchmarks could weaken the very enforcement system they aim to support. To be effective, enforcement and due diligence must be guided by a broader set of indicators—governance scores, conflict risk, corruption levels, and transshipment patterns.
Because even if a country is rated low risk on deforestation, it doesn’t mean it’s low risk on legality. Due diligence and enforcement targeting must be guided by a fuller picture.
Viewpoints showcases expert analysis and commentary from the Forest Trends team.
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