The European Union Deforestation Regulation (EUDR), in force since January 1, 2024, mandates that “relevant commodities” linked to deforestation — including cattle, cocoa, coffee, oil palm, rubber, soya, and wood — must not enter the European Union (EU) market unless documented as deforestation-free. A central pillar of the EUDR is its Country Classification List, placing nations into low-risk, standard-risk, or high-risk categories based on governance quality, deforestation rates, and, critically, data transparency and reliability.

As of 2024, the United States enjoys low-risk status, due to open data systems (e.g., Global Forest Watch, the U.S. Forest Service (USFS), the National Aeronautics and Space Administration (NASA)) and transparency in emissions and forest-loss reporting. Exporters benefit from streamlined due diligence protocols. But that status could change. It is important for stakeholders to stay on top of any changes that occur under the EUDR, whether to Annex I, the seven commodities, reporting obligations, simplifications, or the country designation as low-, standard-, or high-risk.

Initially, every country was given standard-risk designations before the European Commission (EC) could begin their country’s benchmarking process. Article 29 of the EUDR unpacks the specific criteria for how countries gain low-, standard-, and high-risk designation under the EUDR for their assessed risks to contribute to global deforestation. When first introduced, the report invited pushback when it only designated four, somewhat surprising, countries as high-risk: Belarus, Myanmar, North Korea, and Russia. Many countries otherwise thought of as major contributors to deforestation, like Brazil, received standard-risk designations.

Why did the EC single out just four countries that seemingly do not contribute to global deforestation? Some speculate that the designations were motivated by factors other than data. The EC designations mandate that the EC consider certain criteria as it assesses risk designations, including “agreements and other instruments between the country concerned and the Union and/or its Member States that address deforestation, and forest degradation.” Additionally the EC may consider “whether the country concerned has national or subnational laws in place, including in accordance with Article 5 of the Paris Agreement, and takes effective enforcement measures to tackle deforestation and forest degradation.” The most important factor may be 4(d) of Article 29, which allows the EC to consider “whether the country concerned makes relevant data available transparently.” Some of these relevant factors include things like whether the country is currently subject to United Nations (UN) or EU sanctions on the import or export of goods covered under the EUDR — all of the countries labeled high-risk face some kind of sanction under either the UN or EU.

The EC’s designation process weighs heavily whether a country provides credible, accessible, and scientifically audited data on deforestation and land-use. Countries lacking robust data systems, or withholding information, are downgraded — even if deforestation rates are not dramatically higher.

Sweeping cuts to federal budgets to diminish the federal footprint raise many questions. Notably, the fiscal year (FY) 2026 NASA budget proposal includes termination of two Orbiting Carbon Observatory satellites (OCO-2 and OCO-3) — missions that map global carbon dioxide (CO₂) concentrations with unmatched precision — with one mission (OCO-2) being intentionally destroyed in a fiery atmospheric re-entry even though it is still operational. These satellites are among the few U.S. platforms that monitor CO₂ at the global scale, and their loss would eliminate critical data from federal monitoring systems used by both scientists and industries. David Crisp, a retired NASA scientist who led the development of the satellites, clarified that “the observations provided by these satellites . . . (are) critical for managing growing climate change impacts around the planet, including in the U.S.”

Other proposed federal U.S. agency action adds to these concerns. The proposed dismantling of the National Oceanic and Atmospheric Administration’s (NOAA) climate research programs would cut NOAA’s budget by nearly 27 percent, shuttering its research office and terminating satellite observation initiatives. Meanwhile, the U.S. Environmental Protection Agency (EPA) is seeking to rescind the “endangerment finding” that underlies nearly all greenhouse gas regulation under the Clean Air Act (CAA). EPA has regulated greenhouse gases under the CAA since the finding was made in 2009, after the Supreme Court ruled in the landmark 2007 Massachusetts v. EPA case that the gases fell into the scope of the CAA. EPA’s proposal for this action questions the connection between carbon emissions, climate change, and public health. Such a conclusion directly contradicts the data that the EC draws in points 1-86 demonstrating how deforestation and climate change are inherently connected.

Reducing climate data collection and reporting may disadvantage industries in ways not fully considered. While curtailing some data collecting initiatives may initially benefit industry, greater reduction could hamper the efforts of entities looking to achieve specific Environmental Social Governance (ESG) goals. Additionally, many global regulatory initiatives rely on global climate data to ensure that each country hits stated benchmarks, whether it is in the EUDR, the Paris Agreement, or the EU Nature Restoration Regulation. 

Implications of Losing “Low-Risk” Status

If the United States were downgraded:

• Export disruptions: Commodities like soy, cattle, and timber would require enhanced third-party audits, slowing shipment and adding costs.
• Trade disadvantage: Delays and added red tape could shift market share to exporters in stable or improving risk-rated countries.
• Reputational damage: Among trading partners, the United States’ credibility as a reliable provider of environmental data could be undermined.

At the same time, downgrades signal political concern. If the EU sidelines Russia and North Korea, it may feel compelled to reassess the United States as well — especially if data transparency erodes.

Managing the Risk: Safeguards and Mitigation

To prevent downgrade, stakeholders — government, academia, non-governmental organizations (NGO), and industry — should consider:

• Legal protections for federal environmental data integrity, akin to scientific-integrity policies. This standard also appears to be in line with the President’s Restoring Gold Standard Science Executive Order, although it is currently unclear to what extent that order is being considered or enforced. 
• Academic and NGO partnerships to co-host data continuity if institutional funding shifts.
• Multilateral reporting engagements — like the Global Forest Observations Initiative or the Forest Data Partnership — to ensure consistent international data submission regardless of political changes.

For companies and policymakers, the message is clear: “low-risk” is not guaranteed. It reflects active, transparent infrastructure — now at potential risk due to policy changes that may not be thoughtfully considered with regard to EUDR implications. The EUDR’s framework rests on a straightforward principle: transparency is as critical as performance. In this light, environmental monitoring programs are more than scientific exercises — they are trade infrastructure.

Deregulation can serve important economic and administrative goals, but in areas where credible, verifiable data confer a measurable trade advantage, overcorrection can have the opposite effect. Maintaining “gold standard science” is not only about environmental stewardship — it is about safeguarding U.S. competitiveness, keeping compliance costs low, and ensuring continued access to high-value export markets.