Compliance Checker Methodology

AidEnvironment identified an initial longlist of non-EU commodity supplying countries with potential deforestation risk to include in the Compliance Checker, based on a range of criteria, including the presence of intact (primary) forests, net forest loss, and relevant commodity production. The criteria are a combination of the FAO definitions of forest, and a selection of risk assessment criteria under Article 10 of the EUDR:

• Country has presence of ‘forests’ in its territory and produce relevant commodity or product, with ‘forests’ as defined by the FAO and the EUDR. The forest definition will also include parts of the Cerrado and Chaco biomes in Latin America, as well as wooded savannas and woodlands in Africa, based on FAO’s definition of ‘open forests’. Moreover, priority is given to countries with ‘primary forests’, which are a fundamental priority for conservation under FAO definitions and the EUDR. Finally, countries with ‘secondary forests’ (often degraded) are also included, which are ‘forests’ (by definition), and can also still contain high canopy cover (>10%) and biodiversity.
• The prevalence of deforestation or forest degradation in the country, region, and area of production of the relevant commodity or product.

AidEnvironment has used the FAO’s Global Forest Resources Assessment (FRA) 2025 to prepare a long list of countries that would fall under these definitions. The report included 236 countries and territories in the FRA 2025, based on the list used by the United Nations Statistics Division. For each country, forest area (2025) and forest loss (2015–2025) were assessed. Based on the criteria ‘presence of forests’ and ‘prevalence of deforestation’, 83 countries were selected in the long list. To assess relevant commodity production in this long list of countries, we have used FAOSTAT production data. This would guarantee that we only include a country for commodity-linked deforestation if the commodity is also actually produced in that country. Moreover, we have used European trade statistics (Eurostat) for assessing trading links between the producing country and the EU. The evaluation of actual commodity production and existing trading linkages with the EU27 countries, reduced the longlist of 83 countries to 62 countries with deforestation risk linked to relevant commodity production. As a threshold for forest cover, we have set (an arbitrary) 200,000 hectares, resulting in excluding two more countries (Singapore and Israel), leaving us with 60 remaining countries.

Still, some challenges remain in the identification of high-risk countries based on the aforementioned criteria. Countries such as Australia, Ghana, Philippines, Viet Nam, and India would not be included based on the criteria since the country self-reports no net forest loss. Instead, these countries report an increase in forest area. However, based on more detailed deforestation-risk analysis, AidEnvironment is aware of commodity-linked forest loss in Australia, e.g., for beef. Ghana is historically linked to high deforestation-risk linked to cocoa expansion. Agricultural expansion as well as logging have had a significant impact on the deforestation in Philippines from 1980 – 2020. Rubber and coffee are attributed to the forest loss in Viet Nam, as well as recent palm oil expansion in India. Apart from their link to deforestation, these five countries export large amounts of these commodities to the EU, a reason to include them in the list of countries. While the same reasoning may apply to other countries, AidEnvironment did not do a full risk assessment for each country to understand the drivers of deforestation.