Hi Jada, thanks for raising this important and timely topic.

The idea of introducing a “zero-risk category” – as proposed by the German Bundesrat – aims to reduce administrative burden by exempting certain low-risk regions or products from full due diligence obligations under the EUDR.

Potential Benefits:

• Efficiency: Companies sourcing from well-governed, low-deforestation regions could focus resources on higher-risk supply chains.

• Proportionality: Risk-based approaches are standard in other EU regulations (e.g. CSDDD, LkSG), so applying this principle could increase acceptance and practicality.

• Relief for SMEs: Smaller players with limited compliance capacity could benefit disproportionately from such simplification.

 But: Significant Concerns

• Greenwashing risk: A blanket exemption could lead to less scrutiny in regions where risks still exist (e.g. illegal logging in “low-risk” zones).

• Undermining EUDR credibility: If exceptions are too broad, the regulation risks losing effectiveness and public trust.

• Fair competition: Companies committed to full traceability might be disadvantaged compared to those sourcing from “exempt” regions.

Alternative approach: “Smart risk-based due diligence”

Rather than introducing a hard exemption, a tiered due diligence model (e.g. simplified DDS with reduced documentation for pre-verified low-risk areas) could strike a better balance — aligning with the EUDR’s objectives while addressing operational burdens.

Conclusion:
A “zero-risk” category might seem attractive at first glance, but it risks opening doors to abuse and inconsistent enforcement. A better path might be differentiated due diligence, not complete exemption.