EUDR country risk benchmarking 2026 review: what benchmark updates mean for Uganda due diligence
By Sandra Nansbuga
EUDR country risk benchmarking 2026 review: what benchmark updates mean for Uganda due diligence
The European Commission's first scheduled review of EUDR country risk benchmarks, set for 2026 under Article 29 of Regulation (EU) 2023/1115, can move any producing country between low, standard and high risk. Uganda currently sits at standard risk under Commission Implementing Regulation (EU) 2025/1093, so it already runs the full due diligence procedure on shipments to the EU. For Ugandan green coffee importers, the meaningful exposure in the 2026 review is a move up to high risk, which triples authority check rates, rather than a sConShiConConConimplification that most exporting countries should not assume.
What the 2026 benchmark review changes
The country benchmarking system operates under Article 29, which classifies producer countries as low, standard or high risk of producing in-scope commodities that are not deforestation-free. The current list was set out in Implementing Regulation (EU) 2025/1093, adopted on 22 May 2025, and covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Around 140 countries are designated low risk (including all EU member states), while EUDR.live notes the high-risk category covers Russia, Belarus, Myanmar and North Korea, with major tropical producers such as Brazil and Indonesia classed as standard. Any country on neither list, including Uganda, defaults to standard risk.
The first review is scheduled for 2026 and draws on the updated FAO Global Forest Resources Assessment published in October 2025. The Commission assesses countries against the quantitative criteria in Article 29(3): deforestation and forest degradation rates, expansion of agricultural land for relevant commodities, and production trends, complemented by qualitative factors such as enforcement of forest laws. The review lands in the same year operators first become subject to the rules. On 18 December 2025 the Council signed off the targeted revision postponing application to 30 December 2026 for large and medium operators (and micro and small operators already covered by the EU Timber Regulation), and to 30 June 2027 for other micro and small operators.
How risk tier drives due diligence under Articles 10 and 13
Tier assignment decides whether an operator runs the full due diligence procedure or the simplified regime. Low-risk origins carry simplified due diligence under Article 13: the operator still collects geolocation coordinates, legality documentation and supplier attestations, but does not have to run the Article 10 risk assessment or the Article 11 mitigation steps. Standard and high-risk origins pull the operator into the full Article 10 procedure, meaning a documented risk assessment and, where risk is more than negligible, Article 11 mitigation before a due diligence statement can be submitted. Uganda, being standard risk, already sits under this full regime under Implementing Regulation (EU) 2025/1093.
Enforcement intensity scales with tier as well. Member State competent authorities must check at least 1% of operators sourcing from low-risk countries, 3% for standard-risk and 9% for high-risk countries annually. A standard-to-high reclassification therefore triples the probability that an operator sourcing Ugandan green coffee is picked for an authority check.
What this means for buyers
Buyers of Ugandan green coffee should treat the 2026 review as a benchmark-risk management task, not a compliance note. Because Uganda is already standard risk, the realistic downside is a move to high risk, which keeps the same Article 10 and 11 workload but raises the authority check rate from 3% to 9% and adds enhanced scrutiny. The tier that applies to a shipment is the tier in force when the product is placed on the EU market, not when the supply contract was signed, so a contract spanning the 2026 review can begin under one regime and end under another.
Build due diligence workflows to the standard-risk baseline, since that is the regime already applying to Uganda and the one it keeps if the tier holds. Collect plot-level geolocation, legality documentation and supplier attestations on every origin now, because a low-risk reclassification would still require this information even though the assessment work drops. Add contractual clauses that let you request additional traceability data or switch suppliers if a country's tier changes mid-contract, and factor a plausible upward move into total-cost planning. Diversifying across more than one producing country also absorbs a reclassification more smoothly, since only part of the volume shifts regime.
FAQ
Q: Is Uganda currently low, standard or high risk under the EUDR?
A: Uganda is standard risk. It is not named in the low-risk or high-risk annexes to Implementing Regulation (EU) 2025/1093, in force since adoption on 22 May 2025, and countries on neither list default to standard, which means full due diligence under Article 10 already applies.
Q: How would a 2026 reclassification change Uganda due diligence?
A: If Uganda moves to high risk, the authority check rate would rise from the standard-risk 3% to 9% with enhanced scrutiny, while the Article 10 assessment and Article 11 mitigation workload stays the same. A move to low risk would simplify obligations to Article 13 information collection, but such an upgrade should not be assumed.
Q: When is the 2026 benchmark review and what does it use?
A: The Commission has scheduled the first review of the country benchmarks for 2026, drawing on the updated FAO Global Forest Resources Assessment published in October 2025, under the quantitative criteria in Article 29(3) of Regulation (EU) 2023/1115.
Sources: Coolset Academy | EUR-Lex Implementing Regulation (EU) 2025/1093 | Council of the EU | EUDR.live | TraceX Tech