Will the EUDR risk classification of countries change this year?
Country risk classification is not fixed. The regulation provides for the European Commission to classify countries (or parts thereof) into a risk class: low, standard, or high. This classification can be reviewed over time. If the country of origin of your coffee, cocoa, wood, or beef changes class, what must be included in your due diligence file also changes.
Important to know: a change in risk classification does not change your role in the supply chain or the implementation date that applies to you. These two things are fixed based on your position as a market operator or trader and based on the product. What does change is the depth of the risk assessment that corresponds to a lower or higher class.
Why the classification can change
Risk classification is intended as a dynamic instrument. The Commission assesses countries against criteria set out in the regulation, such as deforestation figures and the extent to which a country has its own legislation and enforcement in order. If the situation in a country changes, the class can move. This can go both ways: a country that is currently classified as standard can move to low risk, or vice versa.
For SMEs sourcing from a limited number of countries, this is usually not a daily concern. For companies that source from multiple countries of origin, or from countries close to a classification threshold, it is something to keep an eye on, precisely because it has a direct impact on the records you must maintain.
What a different class means for your file
For a low-risk class, the regulation provides for a simplified declaration: less extensive information requirements, and no mandatory risk assessment and risk mitigation. For standard and high risk, the full due diligence obligation applies, with a risk assessment and, where necessary, measures to mitigate an identified risk.
If a country of origin changes class, therefore, not only does a label in a system change, but also what you must provide and substantiate. A file that sufficed last year with basic data may this year require more extensive substantiation, or vice versa. This is one reason why maintaining a file per product stream, with supplier, country of origin, and plots kept separately, is more practical than a single consolidated document: a change in the classification of one country then affects only that part of your records.
How to track changes without it becoming a full-time job
Most SMEs have no need to monitor Commission publications daily. It is more practical to check the classification of your own countries of origin a few times a year, and certainly when you add a new supplier or a new country to your sourcing. For each product stream, document which country the goods come from and which class applied at that time, so that you can later demonstrate on the basis of what information you acted.
Those who prefer not to maintain this manually can consult the risk indication and the source in the official text per country via the overview of countries and risk classes in the knowledge base. This way you can see directly for each country of origin where the classification comes from, without having to search through Commission publications yourself.
What is not yet fixed this year
Whether, when, and for which countries the classification will change this year is not predetermined and is not something we make predictions about. Such decisions are published by the European Commission itself. Avoid assuming that a classification from last year still applies, and check the current status before submitting a declaration if in doubt.
If you are uncertain which class applies to your country of origin, or what that means in concrete terms for your file, that is a question for a legal adviser or for the competent supervisory authority in your Member State. We structure and validate the data you provide, but we do not express an opinion on the correct risk assessment in your specific case.
Do you first want to know where you stand, independent of country classification? With the free role check you will see in a few questions which role and obligation apply to you. If you are unsure between submitting yourself and receiving guidance, then review how the guidance for building a file works, or read the shortest answers to frequently asked questions via the overview of frequently asked questions on the Deforestation Regulation.