EUDR Country Risk List Explained: India, Vietnam, Côte d'Ivoire and Indonesia

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By Prabir Mishra, Founder & CEO, TRST01 · 15 November 2026 · EUDR Guides

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The EUDR sorts every country into one of three risk categories. The category does not change whether a product needs geolocation and a Due Diligence Statement. It does change how much risk assessment an operator must do and how often authorities check. This guide explains the list and what it means for four origins that matter for rubber, coffee, cocoa, palm oil and soy.

How the benchmarking works

The Commission published the classification in Implementing Regulation (EU) 2025/1093 in May 2025. It uses three tiers:

• High risk: four countries, Belarus, Myanmar, North Korea and Russia.
• Low risk: a named list that includes the EU Member States and countries such as India, Vietnam, Sri Lanka, Ghana, the United States and China.
• Standard risk: every country not listed as high or low, including Brazil, Indonesia, Malaysia and Côte d'Ivoire.

As of November 2026 the list has not been revised. The Commission can update it, and will review it periodically, so check the current version before relying on it.

What the category changes

• Low risk: operators can use simplified due diligence (Article 13). They still collect all the information in Article 9, including plot geolocation, and still file a Due Diligence Statement, but they can skip the risk assessment (Article 10) and risk mitigation (Article 11). Micro and small primary operators in low-risk countries can submit a one-off simplified declaration.
• Standard risk: full due diligence. Collect information, assess the risk of deforestation and illegality, and mitigate it to negligible before placing goods on the market.
• High risk: full due diligence, plus enhanced scrutiny from authorities.
• Checks: competent authorities must check at least 1% of operators for low-risk origins, 3% for standard risk and 9% for high risk (9% of operators and 9% of the quantity of each product).

What it does not change

• Low risk is not exemption. Plot geolocation, legality evidence and a Due Diligence Statement are required for every origin.
• Simplified due diligence applies only if all inputs come from low-risk countries. If there is a risk of mixing with products from standard-risk origins, or of circumvention, full due diligence applies.
• If an operator learns of a risk, for example a credible report of deforestation in a supply area, it must do a full risk assessment for that supply and inform the authorities.

India: low risk

India's low-risk status covers its main EUDR exports: natural rubber from Kerala and the North East, coffee from Karnataka and Kerala, soybean meal and oil from Madhya Pradesh and Maharashtra, and wood products. EU buyers still need plot geolocation, which is the hard part for millions of smallholders. India's answer for rubber is the Rubber Board's national BSNR programme, built on TRST01Chain. Indian coffee and soy exporters are following the same pattern: see our coffee and soy pages.

Vietnam: low risk

Vietnam is the world's largest robusta exporter and a major rubber and wood producer. Low risk lightens the assessment burden for EU buyers, but Vietnamese coffee comes from very fragmented smallholdings through layers of collectors, so lot-to-plot traceability and point or polygon data for every farm remain the real work. Buyers will also watch for mixing with coffee or rubber from neighbouring standard-risk countries.

Côte d'Ivoire: standard risk

Côte d'Ivoire is the largest cocoa producer and Africa's largest rubber producer. As a standard-risk origin, every EU operator must carry out a full risk assessment, with particular attention to classified forests and protected areas, where much past cocoa expansion took place. Polygons and satellite deforestation checks are the core evidence. TRST01 mapped more than 31,000 plots for Golden Rubber across 85,000 hectares there.

Indonesia: standard risk

Indonesia supplies palm oil, rubber, coffee, cocoa and wood. Standard risk means full due diligence, and palm oil and rubber smallholders near forest frontiers will draw close scrutiny from EU buyers. Strong polygon data, deforestation screening and legality documents for land use are what make Indonesian supply chains straightforward to buy from.

What to do with this

• EU importers: tag every supply chain by origin risk and plan the depth of due diligence accordingly. Our 30 December checklist sets out the steps.
• Exporters in low-risk countries: do not mistake low risk for no work. Your buyers still need clean plot data, so start mapping.
• Exporters in standard-risk countries: expect detailed questions and audits. Deforestation screening per plot is the best defence. You can test your plot file on the free EUDR Polygon Validator.

This guide reflects the EUDR as amended by Regulation (EU) 2025/2650 and the Commission's 2026 implementing measures, as at 15 November 2026. It is general information, not legal advice. Check the official texts linked below before you act.

Official sources

• Implementing Regulation (EU) 2025/1093, country classification
• Regulation (EU) 2023/1115, Articles 13, 16 and 29
• European Commission EUDR implementation page