As the EU Deforestation Regulation (EUDR) moves closer to full implementation, businesses across the globe are preparing to meet its stringent due diligence requirements. A key component of this regulation is the country benchmarking system. This mechanism is designed to help companies assess the deforestation risk associated with sourcing key commodities from different countries. 
 
By classifying countries into low, standard, or high risk, the EU aims to create a more targeted and efficient compliance process. But while the system offers clarity at a high level, it also introduces new complexities – especially for companies with global, multi-tiered supply chains. Understanding how the EU benchmarking system works, and how it affects your sourcing and risk management strategies, is essential for staying compliant and competitive in a rapidly evolving regulatory landscape. 

What Is the EUDR Benchmarking System? 

The EUDR’s country benchmarking system is a classification tool developed by the European Commission to assess the deforestation risk associated with the production of key commodities in different countries. It applies to seven regulated commodities: cattle, cocoa, coffee, oil palm, rubber, soya, and wood – as well as certain products derived from them. 

Countries are assigned one of three risk levels: 

• Low risk: Simplified due diligence applies. No risk assessment or mitigation is required. 
• Standard risk: Full due diligence is required, including geolocation, risk assessment, and mitigation. 
• High risk: The same due diligence obligations as standard risk apply, but with increased scrutiny and likely higher expectations for mitigation. 

The classification is based on several factors, including: 

• Historical deforestation rates and trends
• National forest governance and enforcement capacity
• Transparency and availability of geolocation data
• Cooperation with the EU on sustainability and traceability

The benchmarking list is not static. It will be reviewed and updated regularly, meaning that companies must stay informed and be ready to adapt their sourcing strategies as classifications change. This dynamic nature is intended to incentivize producer countries to improve forest protection and governance to move toward a lower risk category.  

Why It Matters: Mixed Commodities Are Classified by the Highest Risk Level

One of the most operationally relevant rules of the EUDR benchmarking system is how it handles mixed-risk commodities. According to the regulation, if products from different risk categories are stored, transported, or processed together – such as in shared silos, warehouses, or containers – the entire batch is classified according to the highest risk level present. 

This means that if even a small portion of the mixture originates from a high-risk country, the entire volume must be treated as high risk. The same applies if standard-risk material is mixed with low-risk goods. The full batch is then considered standard risk. 

This rule is designed to prevent circumvention of the regulation through blending or aggregation. However, it also presents a significant challenge for companies that rely on bulk logistics or shared infrastructure, especially in sectors like cocoa, coffee, soy, or palm oil. 

For example: 

• A shipment of coffee beans from a low-risk country, when mixed with beans from a high-risk country in the same silo, must be treated as high risk.
• This triggers the need for full due diligence, including geolocation, risk assessment, and mitigation, regardless of the proportion of low-risk material. 

As a result, companies must rethink how they manage storage, transport, and traceability. Segregation strategies and digital tools that can track origin at batch level become essential for maintaining compliance and minimizing risk exposure.

Future-Proofing Your Supply Chain: Go Beyond Country-Level Risk 

While the benchmarking system provides a useful starting point, relying solely on country-level classifications can be misleading. Deforestation risk is not uniform across an entire country. It can vary significantly between regions, production areas, and even individual suppliers. That’s why it’s increasingly important to conduct risk assessments at the supplier level. 

This more granular approach allows companies to: 

• Identify low-risk suppliers operating in standard- or high-risk countries 
• Avoid blanket exclusions of entire regions that may contain sustainable producers 
• Build long-term relationships with transparent, traceable, and compliant partners 

Supplier-level risk assessment also helps companies to future-proof their supply chains. As the EU continues to refine and expand its sustainability regulations, more detailed traceability and risk data may become mandatory. Companies that already have supplier-level insights will be better positioned to adapt quickly and maintain market access. 

In short, going beyond the benchmarking list isn’t just about compliance – it’s about building a smarter, more resilient supply chain that can withstand regulatory, reputational, and environmental risks. 

How osapiens Helps: Automation for Complex Supply Chain Scenarios 

Real-world supply chains are rarely linear. Products are often stored in shared silos, transported in bulk, or manufactured using components from multiple suppliers, each potentially linked to a different risk category. These complexities make manual due diligence not only time-consuming, but also error-prone and difficult to scale. 

That’s where the osapiens HUB for EUDR comes in. The AI-powered solution automates the creation of Due Diligence Statements (DDS) by integrating benchmarking data, supplier-level risk profiles, and mitigation measures into a single, reliable process. 

Here’s how it works: 

• If commodities from different origins are mixed in storage, the system automatically applies the correct risk classification based on the highest risk level present. 
• When new products are created, such as a table assembled from wood sourced from multiple shipments, the osapiens solution ensures that the existing DDS for the multiple items is referenced automatically based on different aggregation methods (FIFO, rolling window or internal traceability) and a compliant DDS is generated automatically. It traces each component back to its origin, assesses the associated risk, and applies the necessary mitigation steps. 
• The platform continuously updates its logic based on the latest EU benchmarking list, so your compliance efforts are always aligned with current regulations. 

This level of automation not only ensures regulatory compliance, but also increases transparency, reduces administrative burden, and provides a clear audit trail for authorities and business partners alike.

Staying Ahead with Smart Compliance – Before it’s Too Late 

The EU’s benchmarking system is only one piece of the EUDR puzzle. Many companies still rely on static country lists – but that won’t be enough. EUDR compliance requires full traceability, geolocation data, ongoing risk assessments, and auditable due diligence. Companies that wait risk falling behind – or losing market access altogether. 

Smart compliance isn’t just a checkbox – it’s your competitive edge. With osapiens HUB, you put EUDR compliance on autopilot – reducing complexity, eliminating guesswork, and ensuring legal certainty. Act now and secure your supply chain.