Posted on June, 23 2025

Background
The EU Deforestation Regulation (EUDR) entered into force in 2023 and is set to apply from the end of 2025. A key component of the EUDR is the country benchmarking system, designed to categorise countries as low, standard, or high risk—guiding the level of scrutiny and reporting obligations for products entering the EU but also determining, how many checks and controls EU Member States need to carry out on companies and products (between 1-9% depending on the risk category).

In May 2025, the European Commission published the first country risk classification (‘benchmarking’) list after it had been agreed with EU Member States -  the final piece that made the framework for the EUDR implementation complete.

In the benchmarking, only Russia, Belarus, Myanmar, and North Korea are flagged as “high risk”.  A majority of countries can be found in the low risk category, including all EU Member States. Nevertheless, it’s important to point out that the EUDR has no “green lanes”, with benchmarking meant to guide, not to grant exemptions. Companies remain fully responsible for ensuring the products they want to place on the EU market are free from deforestation, no matter the risk category of the country they source from.

What’s happening?
On 26 May Agriculture ministers of Austria and Luxembourg presented proposals to weaken the EUDR, advocating for another delay of the application of the EUDR and the introduction of a “insignificant” category or reducing due‑diligence obligations, despite the fact that the country benchmarking had already been formally adopted. This would largely exclude European producers and foresters from the scope of the law. The proposals were backed by a large number of Member States. 

These proposals would lead to exemptions from the traceability of products, transparency along the supply chain and from checks and controls. If adopted, they would turn the EUDR into a law that encourages exemptions more than enforcement. 

In parallel, Austrian MEP Alexander Bernhuber (EPP) and French MEP Mathilde Androuët (PfE) also submitted a motion for the EP ENVI Committee to reject the Commission’s risk classification list and to introduce a "negligible risk” category. The vote is scheduled to take place on Tuesday, 24 June 2025.

Why does it matter?
The introduction of a category of “insignificant or negligible risk” - absent from the legal text of the EUDR - would undermine the level playing field, introduce politically driven exemptions in a law that already entered into force, and run counter to the EUDR’s environmental and human rights objectives.

This push comes just months before the EUDR becomes applicable (after a delay of 12 months) in December 2025, and before the country risk benchmarking will be updated by the European Commission in 2026. It  puts into question the willingness of EU Member States and institutions to really act against deforestation. The proposals only focus on deforestation but do not address that the EUDR is as much about legality and forest degradation. The proposals could:

• Create loopholes by exempting entire sectors or regions, particularly in the EU, from deforestation checks - making it likely more costly for companies to comply with the law;
• Weaken enforcement by calling into question the objectivity of the benchmarking criteria and by adding complexity to carry out meaningful controls and checks;
• Require a reopening of the legislation, likely delaying the implementation, adding uncertainty for businesses preparing for compliance and eroding trust in the EU’s environmental policies.

What does WWF want?
With tropical primary forest loss increasing by 80% within a year in 2024, there is no more time to lose. If the EU wants to remain credible on the international commitments made, the EUDR needs to be applied as planned. Questioning the EUDR and reopening it before it even applies will dilute positive reforms and investments made by companies and governments, which deliver benefits for biodiversity, climate, producers and indigenous people far beyond the EU’s direct supply chains.

• The EUDR must enter into action. Only the application of the EUDR will show where the largest challenges with the legislation lie.
• Simplifications to the implementation of the EUDR have already been provided through the recent FAQs and guidance - these should be properly assessed and applied by companies and competent authorities.
• WWF urges Members of the ENVI Committee to reject MEP Bernhuber’s and MEP Androuët’s objection and uphold the Commission’s risk classification list. 
• The European Commission and the EU Member State should support the implementation and capacity-building, especially for SMEs and producer countries within the EU and beyond.

Last week, WWF and its partners had issued a statement to call on Member States and the Commission to stick to their commitments to implement the EUDR. 

Quote 
“With the benchmarking, the European Commission has delivered the missing link, and it must now keep calm and carry on with getting the EUDR to work, rather than allow for last-minute changes. Attempts to introduce an ‘insignificant risk’ category or to further delay the EUDR do nothing to stop deforestation and will lead to more complexity instead of simplification for companies. Creating exemptions now would gravely damage the EU’s credibility as a global environmental leader,” said Anke Schulmeister-Oldenhove, Manager, Forests at WWF European Policy Office. “We call on Members of the ENVI Committee to reject MEP Bernhuber’s and MEP Androuët’s objection and uphold the Commission’s risk classification list.”

Next steps & media availability
The ENVI Committee will vote on the objection on Tuesday, 24 June 2025. WWF experts will be available for comment and analysis following the vote.

Contact:
Angelika Pullen
Communications Director
WWF EU
apullen@wwf.eu
+32 473 947 966