EUDR undermined: Reduced checks for top deforesters

The world’s top three deforesters, Brazil, Indonesia, and the DRC, are not seen as high-risk exporters under the EU anti-deforestation legislation. "Unbelievable," says Rainforest Foundation Norway’s executive director.

DEFORESTED: Cattle grazing on deforested land in the Brazilian Amazon. Photo: Victor Moriyama/RFN

By Rainforest Foundation Norway.

UN and EU sanctions, not scientific evidence of deforestation, are informing the benchmarking system agreed by member states late last night. Only four countries are classified as high-risk in the soon-to-be-implemented anti-deforestation legislation: Belarus, North Korea, Myanmar, and Russia.

"The EUDR's potential to protect vast areas of tropical rainforest is now being reduced by a meaningless application of risk benchmarking. It is simply unbelievable that Brazil, Indonesia, and DR Congo, responsible for over 80% of net global deforestation, are not rated as high-risk," says Toerris Jaeger, executive director of Rainforest Foundation Norway.

Placing these in the standard category will reduce the annual checks of their exports by EU member states by at least two-thirds, creating incentives to evade controls as only 3% of importers to the EU will now be checked every year.

The ranking and methodology are expected to be revised in 2026.

“For the rainforest's survival, an uncompromising law is essential. We strongly urge the EU institutions to revise the benchmarking methodology already next year, to enable the EUDR to live up to its potential"

Toerris Jaeger, executive director of Rainforest Foundation Norway.

Breaking the intention of the legislation

According to Article 29(3) of the EUDR, the risk classification of countries shall be objective and transparent, building on the latest scientific evidence and internationally recognized sources. Furthermore, it shall be based primarily on rates of deforestation, forest degradation, expansion of agricultural land, and the production trends of relevant commodities. Limiting high-risk status to only countries facing international sanctions for geopolitical reasons does not follow the initial criteria for risk classification.

“Drafting the law, the EUDR spells out that deforestation and degradation rates are primary criteria for how exports should be scrutinized. This seems to have been forgotten,” says Toerris Jaeger.

The world’s top deforesters host nearly all tropical forests

In February this year, Rainforest Foundation Norway published detailed documentation explaining why six countries hosting the remaining large, contiguous tropical rainforests must be classified as high-risk. According to the FAO, Brazil, Indonesia, and the DR Congo are the three countries in the world that have lost the most forests since 1990, with Colombia and Peru also among the top 20.

Tropical rainforests are the most biodiverse forests in the world. According to FAO, the six countries that are home to 79% of the world's intact tropical rainforests also account for 86.6% of the world’s net deforestation in the period 1990-2020.

Risk categorization influences traders' and operators' obligations and, importantly, the annual checks carried out by competent authorities. While 9 % of operators and 9 % of goods from countries defined as high-risk will be controlled, this applies to only 3 % of operators for countries placed in the standard category.

Categorizing high-risk countries as standard or low-risk makes it easier to escape checks and, thereby, less risky to place commodities from recently deforested areas on the European market.

HIGH-RISK: Papua New Guinea is widely viewed as a high-risk country for deforestation, contradicting the EUDR risk classification that categorizes the country as low-risk. Photo: RFN

Papua New Guinea: High-risk country classified as low risk

One clear example of the misguided risk benchmarking is Papua New Guinea (PNG), home to the world’s third-largest rainforest and around 7% of global biodiversity. Its forests are threatened by illegal and unsustainable logging, weak governance, and industrial agriculture. Over 60% of PNG’s rainforest is now degraded, mainly due to logging. Much of the timber export is linked to corruption, illegal permits, and violations of landowner rights.

Despite this, PNG is classified as low-risk, a categorization that conflicts with assessments by international banks, civil society, and researchers, who widely view PNG as high-risk.

"The EUDR risk classification for Papua New Guinea ignores the reality there, creating large loopholes for European purchase of illegal and unsustainable logging products. This increases the risk of Europe contributing to the destruction of rainforests. Companies have a history of not meeting commitments in deforestation imports, and it’s naïve to believe that they will comply if the risk of being caught is insignificant. We strongly urge the EU to strengthen the control of companies to not contribute to rainforest destruction," says Toerris Jaeger, executive director of Rainforest Foundation Norway.

The three most important errors of the risk benchmarking methodology, according to RFN:

  1. Only countries facing EU/UN sanctions on relevant commodities/products are classified as high risk. This completely disregards the real deforestation risk as defined by scientific and objective criteria and limits high-risk classification to four countries, out of which two have increased forest cover in the period used to classify other countries.
  2. Forest degradation is not considered at all, in spite of EUDR stating clearly that this is one of the key criteria. Around half of the world’s remaining rainforests are already degraded, and this is often the precursor to deforestation. Reliable data on degradation is available from other sources than FAO, for example WRI/GFW.
  3. The qualitative criteria on nationally determined contribution to the UNFCCC, agreements with the EU and its member states, existence and enforcement of national laws to tackle deforestation, human rights protection and protection of indigenous peoples and local communities are only used to lower the risk rating from standard to low, while it should also have been used to increase from low to standard, and/or from standard to high risk.

The EU Deforestation Regulation and its risk benchmarking

The EU Deforestation Regulation (EUDR) stipulates that the seven commodities timber, cattle, soy, palm oil, coffee, cocoa, and rubber, and specific products derived from them, cannot be placed on the EU market or exported from the EU unless they are:

1) deforestation-free; 2) produced legally; and 3) accompanied by a due diligence statement.

The EUDR has legally entered into effect, but most obligations are due to take effect on 30 December 2025. By 30 June 2025 all countries of the world shall be classified as either high, medium or low risk of deforestation connected to the production of commodities/products covered by EUDR.

On 22 May 2025 the Commission published the methodology and the list of country classifications. The majority of the countries in the world were classified as low risk, and only four as high risk. On several points the risk benchmarking methodology deviates from the text of EUDR’s Article 29 which defines the framework of the methodology.

The EUDR Risk benchmarking versus deforestation statistics

  • Of the 30 countries with the highest absolute forest loss from 2015 to 2020 (FAO data), 28 are rated as standard risk, one as low risk (USA) and one as high risk (Myanmar)
  • Of the 30 countries with the highest relative forest loss from 2015 to 2020 (FAO data), 23 are rated as standard risk, six as low risk, and one as high risk (Myanmar).
  • Brazil, DR Congo and Indonesia record 63% of global net deforestation from 2015 to 2020 (FAO data). From 1990 to 2020, their share is 82%. From 2002-2023, they were responsible for 62% of the global loss of tropical rainforest. Yet, none of them are rated high risk.
  • The 10 standard risk countries with highest absolute forest loss (Brazil, DRC, Indonesia, Angola, Tanzania, Paraguay, Mozambique, Bolivia & Colombia) have together 103% of global net deforestation. This means that if you take all other countries together, forest cover has increased from 2015 to 2020 (FAO data).
  • At current (2023) rates, DRC will lose all its rainforests in less than 200 years and Brazil and Indonesia in less than 300 years (WRI/GFW data). Yet, they are all classified as standard risk.
  • Forest degradation is the precursor to deforestation, and in 2020, 67% and 63% of the tropical rainforests in Indonesia and Papua New Guinea (PNG) were in a degraded state, respectively (WRI/GFW data). Yet, PNG is rated as low risk, and Indonesia as standard risk.
  • Tropical primary forest loss increased 80% from 2023 to 2024 (WRI/GFW data). In 2024, 42% of this occurred in Brazil, 22% in Bolivia, and 9% in DR Congo. The 10 countries with the highest loss add up to 87% of tropical primary forest loss. They are all rated standard risk, except Laos which is rated low risk.

Contact:

Kristin Rødland Buick

Senior Adviser, International Communications
(+44) 776 858 2930
kristin@rainforest.no