EUDR Country Benchmarking and Risk Categories

Updated 2026-11-02 · 3 min read · By the akar.earth specialist team

EUDR country benchmarking explained: how the Commission's low, standard and high risk categories change due diligence and checks for Indonesian supply chains.

EUDR country benchmarking is the European Commission’s system for classifying producer countries as low, standard or high risk of supplying commodities linked to deforestation. The Commission has published these risk categories; check Indonesia’s current category on the Commission site rather than relying on secondary sources, because the list can be reviewed.

How benchmarking works

The Regulation gives the Commission the task of assessing countries, or parts of countries, against criteria such as the rate of deforestation and forest degradation, the rate of expansion of agricultural land for the covered commodities, and production trends. Other factors include whether the country has climate commitments, agreements with the EU on deforestation and forest governance, and laws that are enforced.

The result is three categories:

The Regulation sets minimum check rates for competent authorities that rise with the category. The exact percentages can be confirmed in the Regulation text on EUR-Lex.

What benchmarking does not change

Every category still needs the basics. For a product made from Indonesian palm oil, coffee, cocoa, rubber or wood:

• The operator must collect geolocation for every plot of production.
• The product must be deforestation-free since the cut-off date and legal under Indonesian law.
• A due diligence statement must be filed before the product is placed on the market or exported.

Simplified due diligence is a relief on the analysis, not on the data. An Indonesian supplier still has to deliver plot coordinates or polygons, whatever the category.

Why it matters for Indonesian exporters

The category affects how EU buyers treat your supply chain. Under full due diligence, the buyer must assess risk for each supply and show how it was reduced to negligible. That pushes buyers to ask for more than geolocation: satellite screening results, land legality documents, supplier mapping and sometimes field audits.

Within Indonesia, risk is not uniform. A plot in a long-established smallholder coffee area on Java has a different profile from a recent oil palm plot near remaining forest in Central Kalimantan or Papua. Good risk assessment looks at the plot and the sourcing area, not just the national label. Our commodity guides cover this for palm oil, coffee and the other chains.

Note that the Regulation allows benchmarking of parts of countries. Check the Commission’s published list for whether any sub-national area is treated differently.

Using the category in your own risk assessment

The country category is one input to a buyer’s risk assessment, alongside:

• Supply chain complexity. How many intermediaries sit between the plot and the exporter? Collectors (pengepul), traders and mills add mixing risk.
• Proximity to forest. Plots near primary forest, peat or protected areas need closer review. See drivers of deforestation in Indonesia.
• Legality concerns. Overlap with the forest estate (kawasan hutan) or contested customary land.
• Indigenous peoples and local communities. Presence of customary claims, and whether free, prior and informed consent was respected.
• Reliability of documents. How easily land documents can be checked.

A low-risk country does not excuse ignoring a known problem. If the operator has information pointing to a risk, it must deal with it.

Practical advice

1. Confirm Indonesia’s current category on the Commission page before you write any buyer-facing material.
2. Do not market your supply as “low risk” on the basis of the national category alone. Buyers will ask for plot evidence anyway.
3. Build your data so it works under full due diligence. If the category is relaxed later, you lose nothing.
4. Keep an eye on reviews of the list. The Commission can update it.

Benchmarking and import origins

Indonesian processors using imported inputs, such as cocoa beans, soy or timber, should also check the category of each import origin. The operator’s due diligence for an EU-bound product follows the category of the country where each input was produced.

Next steps

For the overall framework, see the EUDR hub and the glossary entry on country benchmarking. Use our EUDR readiness check for a quick view of your gaps, or contact us on WhatsApp about plot mapping and screening for your supply base through our EUDR compliance services.