The European Commission categorizes countries by risk levels, likely deeming the US low risk. However, due diligence remains essential, requiring a Due Diligence Statement with geodata for imports.
The European Commission (EC) will categorize countries or parts thereof in three categories - high, standard and low risk - according to the local level of risk of producing commodities that are not deforestation-free. For the US, the risk benchmark will most likely result in a low risk. Based on this category, operators as well as EU Member States (MS) shall adapt their level of due diligence, meaning e.g. the MS authorities auditing activities will place a lower focus on low risk countries (/ a lower sample rate).
But this does NOT mean, operators/ importers do not have to apply a due diligence process or file a Due Diligence Statement. As any other relevant goods passing EU borders, imports from the US (or other countries with a presumed low risk status) must be accompanied by a Due Diligence Statement that includes Geodata of the forest or agricultural source.
According to trade representatives such as the American Hardwood Export Council (AHEC), US exporters are very reluctant to provide geodata on the forest sources.
Due to the large amount of small forest owners in the US - especially in the hardwood sector - providing such data will be very difficult or rather elaborate for US producers. And therefore EU importers/ operators will likely face a lot of resistance on behalf of their trading partners providing such information.
To date the EC has not published any country benchmarks. As of 29 June 2023, all countries were assigned a standard level of risk until further notice.
