This Commission Implementing Regulation (EU) 2025/1093 establishes a list of countries that present either a low or high risk of producing commodities associated with deforestation, specifically concerning whether products comply with the deforestation-free requirements outlined in Article 3(a) of Regulation (EU) 2023/1115. It aims to facilitate the implementation of Regulation (EU) 2023/1115 by categorizing countries based on their risk levels, which in turn affects the due diligence obligations of operators and traders placing relevant commodities on the EU market or exporting them from the EU. The regulation assigns a risk level to countries based on deforestation-related criteria.
The structure of the act is straightforward. It consists of two articles and one annex. Article 1 specifies that the countries presenting low or high risks are those listed in the Annex, while a standard risk level applies to all countries not listed. Article 2 states the regulation’s entry into force. The Annex provides the list of countries classified as either low risk or high risk. This regulation is a direct implementation of Article 29(2) of Regulation (EU) 2023/1115, which mandates the Commission to assess and classify countries based on their risk of producing commodities linked to deforestation. It does not repeal any previous legislation but rather builds upon and specifies the implementation of Regulation (EU) 2023/1115.
The most important provision is the Annex, which lists countries classified as low or high risk. This classification directly impacts the due diligence obligations of operators and traders under Regulation (EU) 2023/1115. Those sourcing from low-risk countries are subject to simplified due diligence, while those dealing with countries not listed (and thus considered standard risk) or high-risk countries must adhere to more stringent due diligence requirements.
**** Ukraine is listed as low risk country.
