EUDR country benchmarking and Liberia

By Moril Trading Enterprise Inc.. Last updated .

The EU sorts producing countries into low, standard and high risk under the EUDR. The first list, Implementing Regulation (EU) 2025/1093 of 22 May 2025, names the low and high risk countries. Every country not named is standard risk. Liberia is not on the low or high risk lists, so it is classed as standard risk. For importers that means full due diligence: information collection, risk assessment and risk mitigation.

This note explains what the classification changes and what it does not. For our own position, see our EUDR status.

How benchmarking works

The Commission assesses countries, or parts of countries, on:

  • The rate of deforestation and forest degradation
  • The rate at which agricultural land for the relevant commodities is expanding
  • Production trends for those commodities

It can also take into account national commitments, agreements with the EU and information from governments, companies and civil society. The list is reviewed regularly.

The 2025 list placed four countries in the high risk tier: Belarus, Myanmar, North Korea and Russia. A long list of countries was placed in the low risk tier. All others, including most tropical producing countries, are standard risk.

What each tier means for importers

ItemLow riskStandard riskHigh risk
Information collection, including geolocationRequiredRequiredRequired
Risk assessment and mitigationNot required unless there are signs of riskRequiredRequired, with enhanced scrutiny
Share of operators checked by authorities1%3%9%

The check rates are minimums for national authorities. They apply to operators placing products from that country on the market.

What standard risk means for Liberian palm oil and rubber

For a buyer of Liberian CPO or TSR20, standard risk means:

  1. No shortcuts on data. You need full geolocation and legality evidence, as for any origin.
  2. A real risk assessment. You must look at the supply chain, mixing risk, forest cover near the plots and legality concerns, and record your conclusions.
  3. Mitigation where needed. If your assessment finds risk, you must reduce it, for example through extra checks or excluding plots, before placing the product on the market.
  4. Ordinary inspection odds. Authorities target about 3% of operators for products from standard risk countries.

Standard risk is the normal position for most palm oil and rubber origins, including Côte d'Ivoire and much of Southeast Asia. It does not mean Liberian supply is a problem. It means the importer has to do the work, and the supplier has to provide the data to support it.

Low risk is not a free pass

Even for low risk countries, operators must collect information, including geolocation, and file a due diligence statement. Simplified due diligence only removes the risk assessment and mitigation steps, and only if nothing suggests a problem. A buyer who learns of a risk must still act on it.

Sub-national risk

The regulation allows the Commission to classify parts of a country differently. The 2025 list works at country level. If a later review classifies regions, the plots in your data package will matter even more, because their location would set the risk level.

What to do next

  • Check the current list on the Commission's EUDR pages before each new contract.
  • Build your risk assessment template for standard risk origins now.
  • Ask suppliers for the information your assessment needs, not only the coordinates. See EUDR due diligence for rubber.
  • Follow date changes in our EUDR timeline.

We update this note when the classification changes.

Frequently asked questions

Is Liberia high risk under the EUDR?

No. The high risk countries on the 2025 list are Belarus, Myanmar, North Korea and Russia. Liberia is not on the low or high risk lists, so it is standard risk.

What does standard risk mean for importers?

Full due diligence: collecting information including geolocation, assessing the risk and mitigating it before placing the product on the EU market.

Do low risk countries need geolocation?

Yes. Simplified due diligence removes the risk assessment and mitigation steps, not the need for information and a due diligence statement.

How often are operators checked?

National authorities check at least 1% of operators for low risk countries, 3% for standard risk and 9% for high risk.

Can the classification change?

Yes. The Commission reviews the list, and can classify parts of countries differently.

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