EU Compliance & Market Access
Country Risk Scoring Methodology
How sourcing country risk scores are assigned across nine dimensions, what each band means, and how scores are updated.
Dimension 1
Forced & Child Labour Risk
Measures the prevalence and severity of forced labour, state-sponsored labour coercion, and child labour in sectors relevant to EU-bound supply chains. Scored against the US DOL ILAB TVPRA List (2024 edition, published September 2024) covering 204 goods from 82 countries, and ILO Convention ratification data from NORMLEX.
- 1–3 (Low)
- No active ILAB listings in relevant sectors. No documented state-sponsored forced labour. Child labour prevalence below 5% in manufacturing. ILO C029 and C138 ratified and enforced.
- 4–6 (Moderate)
- Some ILAB listings in peripheral sectors. Isolated documented cases without systemic pattern. Child labour present in informal economy but not in formal export manufacturing.
- 7–9 (High)
- Active ILAB listings in key sourcing sectors. Documented systemic or state-sponsored forced labour. Child labour present in formal or semi-formal export supply chains.
Primary source: US DOL ILAB TVPRA List, 11th edition, September 2024. Supporting sources: ILO NORMLEX convention ratification database; Walk Free Global Slavery Index 2023; US State Department Trafficking in Persons Report 2024.
Dimension 2
Worker Rights & Freedom of Association
Measures the strength of labour rights frameworks, freedom of association, and collective bargaining rights in export manufacturing. The 2024 ILAB report introduced freedom of association assessments across all evaluated countries for the first time, flagging 29 countries where these rights face challenges — including Indonesia, India, Thailand, and Vietnam.
- 1–3 (Low)
- ILO core conventions ratified and enforced. Freedom of association protected. Strong SMETA/BSCI audit pass rates. Corrective action culture established.
- 4–6 (Moderate)
- Partial ILO ratification or inconsistent enforcement. Freedom of association restricted in some sectors. Mixed audit findings. Improving trajectory.
- 7–9 (High)
- Key ILO conventions not ratified or not enforced. Freedom of association suppressed. Systemic audit failures or audit access restrictions. High migrant worker recruitment fee exposure.
Primary source: US DOL ILAB Findings on the Worst Forms of Child Labor, 2024. Supporting sources: ILO NORMLEX core convention ratification status; ITUC Global Rights Index 2024; amfori BSCI country risk classifications.
Dimension 3
OHS & Audit Transparency
Measures occupational health and safety standards and the transparency of social audit outcomes in export manufacturing. Draws on LRQA EiQ data covering 75 million data points from 25,000 annual supplier audits, and the amfori ESG Risk Compass which monitors OHS fatal injury rates and audit transparency scores by country.
- 1–3 (Low)
- Strong OHS legislative framework with enforcement. Low fatal injury rates in manufacturing. High audit transparency scores. Corrective action culture established in export supply base.
- 4–6 (Moderate)
- Functional OHS framework with enforcement gaps. Moderate fatal injury rates. Mixed audit transparency — some decline in supplier disclosure noted. Improving trajectory.
- 7–9 (High)
- Weak OHS enforcement. High fatal injury rates in relevant sectors. Poor audit transparency scores. Significant under-reporting of violations. Audit access restrictions documented.
Primary sources: LRQA EiQ Supply Chain ESG Global Risk Outlook 2024 (75m+ data points, 25,000+ annual audits); amfori ESG Risk Compass social indicators (OHS fatal injuries, precarious employment, working hours). Supporting: Sedex data.
Dimension 4
Food & Product Safety Enforcement
Measures the capacity and consistency of national competent authorities to enforce food safety, feed safety, and product safety standards equivalent to EU requirements. Scored primarily against EU RASFF alert frequency in relevant product categories and DG SANTE audit mission outcomes.
- 1–3 (Low)
- Strong well-resourced competent authority. Low RASFF alert rate. Recognised equivalence with EU standards in key sectors. Regular EU audit missions with positive outcomes.
- 4–6 (Moderate)
- Functional competent authority with capacity gaps. Moderate RASFF alert rate in relevant categories. Some equivalence gaps. Improving following EU engagement.
- 7–9 (High)
- Weak or fragmented enforcement. Frequent RASFF alerts in relevant product categories. Significant equivalence gaps. Poor EU audit mission outcomes.
Primary sources: European Commission RASFF database (iRASFF); DG SANTE country audit reports (FVO mission outcomes). Supporting: Codex Alimentarius country participation data.
Dimension 5
Environmental & Regulatory Compliance
Measures compliance with EU-facing environmental trade regulations — specifically the EUDR country benchmarking classification (May 2025), EU IUU fishing card status, and CITES convention compliance. Scope is deliberately focused on regulations that create direct EU market access consequences rather than general environmental performance.
- 1–3 (Low)
- EUDR low-risk classification (simplified due diligence). No active IUU card history. Strong CITES compliance record. No active EU enhanced controls related to environmental violations.
- 4–6 (Moderate)
- EUDR standard-risk classification (full due diligence required). Past IUU card resolved, or no card but moderate fisheries governance gaps. Some CITES compliance issues. Improving trajectory.
- 7–9 (High)
- EUDR standard-risk with additional deforestation exposure in relevant commodities. Active EU IUU yellow or red card. Significant CITES violations documented. Active enhanced controls related to environmental non-compliance.
Primary sources: European Commission EUDR country benchmarking Implementing Act, published 22 May 2025 (first official classification — Low: 140 countries including US, UK, China, Thailand, Vietnam; Standard: ~50 countries including Indonesia, Malaysia, India; High: Belarus, Myanmar, North Korea, Russia). EU IUU fishing carding records — current active yellow card: Vietnam (issued 2017, under review). IUU cards lifted: Thailand, Philippines. Supporting: CITES trade database; FAO fisheries data.
Dimension 6
Governance & Anti-Corruption
Measures public sector corruption risk as a supply chain compliance factor — affecting the reliability of official certifications, customs declarations, and regulatory enforcement. Scored against Transparency International CPI 2024 (published February 2025), inverted so that lower CPI scores produce higher risk scores. CPI 2024 scores for covered countries: Thailand 35, Indonesia 37, India 38, Vietnam 40, China 42, Malaysia 50, US 65, UK 71.
- 1–3 (Low)
- CPI score 60 or above. Strong independent institutions. Reliable official certifications and customs declarations. Low risk of falsified compliance documentation.
- 4–6 (Moderate)
- CPI score 40–59. Functional institutions with documented corruption risks. Some exposure to falsified certifications or preferential enforcement. Improving or stable trajectory.
- 7–9 (High)
- CPI score below 40. Weak institutions and rule of law. Elevated risk of fraudulent compliance documentation, customs manipulation, and regulatory capture. Corruption documented in relevant sectors.
Primary source: Transparency International Corruption Perceptions Index 2024, published February 2025. Composite of 13 independent data sources. Scale 0 (highly corrupt) to 100 (very clean). Global average: 43. Score inverted for risk display — higher CPI = lower risk score.
Dimension 7
Tariff & Preferential Access to EU
Measures the cost and availability of preferential duty rates for goods exported to the EU market. A higher risk score indicates higher tariff exposure and more limited preferential access, increasing landed cost and reducing price competitiveness relative to countries with preferential arrangements. Vietnam benefits from the EU-Vietnam Free Trade Agreement (EVFTA, in force since 2020), the strongest preferential access of any country in this group.
- 1–3 (Easy)
- GSP+ or bilateral FTA in force covering relevant product categories. Significantly reduced or zero duty rates. Preferential origin rules achievable.
- 4–6 (Moderate)
- Standard GSP or moderate MFN rates apply. Some preferential access for specific categories. Origin rules achievable with standard documentation.
- 7–9 (Restricted)
- No preferential access for relevant categories. High MFN duty rates. Complex or unachievable origin rules.
Primary sources: EU TARIC database; European Commission DG TAXUD GSP beneficiary list (extended 2024–2027 by Regulation amending EU 978/2012); EU-Vietnam Free Trade Agreement (EVFTA); EU bilateral FTA register. China, UK, and US access EU market at MFN rates with no preferential scheme.
Dimension 8
Non-Tariff Barriers & Controls
Measures the complexity of non-tariff requirements for EU market access — enhanced import controls under Regulation 2019/1793, sanctions exposure, import licensing, and administrative border burden. China carries elevated NTB risk due to dual-use goods controls, technology transfer restrictions, and UFLPA-related scrutiny of goods produced in Xinjiang.
- 1–3 (Low)
- No enhanced import controls. No sanctions exposure. Simple import licensing. Low administrative burden at EU border.
- 4–6 (Moderate)
- Some products under enhanced controls per Regulation 2019/1793. No sanctions. Standard import licensing. Moderate border inspection rate.
- 7–9 (High)
- Multiple product categories under enhanced controls. Sanctions risk on some goods or entities. Complex import licensing. High border rejection rate.
Primary sources: Regulation (EU) 2019/1793 on enhanced controls (updated list of high-risk food and feed); EU Consolidated Sanctions List (updated continuously); EU border rejection database (TRACES NT). Supporting: WTO Trade Facilitation Agreement notification compliance data.
Dimension 9
Supply Chain Traceability
Measures the transparency and documentation maturity of multi-tier supply chains — how far beyond tier 1 a buyer can realistically see. Scored against EcoVadis sustainability rating density by country, audit data from LRQA EiQ, and the relative share of formal versus informal economy in export manufacturing.
- 1–3 (Low)
- High density of EcoVadis-rated or SMETA-audited suppliers. Formal economy dominates export manufacturing. Multi-tier documentation achievable. Strong digital traceability infrastructure in relevant sectors.
- 4–6 (Moderate)
- Growing supplier rating density. Mixed formal and informal economy in supply base. Tier 2 visibility achievable with effort. Moderate documentation gaps. Improving under regulatory pressure.
- 7–9 (High)
- Low supplier rating density. Highly fragmented informal supply chains. Limited visibility beyond tier 1. Weak documentation culture. Significant sub-contracting opacity.
Primary sources: EcoVadis Global Supply Chain Sustainability Risk & Performance Index 2025 (49,000 ratings in 2024, 89,000 companies across 150 countries); LRQA EiQ audit density data. Supporting: World Bank informal economy estimates; Transparency International CPI (as proxy for documentation reliability).
Reference
Data Sources & Attribution
- US DOL ILAB
- TVPRA List of Goods Produced by Child Labor or Forced Labor, 11th edition, September 2024. dol.gov/agencies/ilab
- ILO NORMLEX
- International Labour Standards ratification database. normlex.ilo.org
- Transparency International
- Corruption Perceptions Index 2024, published February 2025. transparency.org/en/cpi/2024
- European Commission RASFF
- Rapid Alert System for Food and Feed. ec.europa.eu/food/safety/rasff
- DG SANTE
- EU audit mission reports (FVO). food.ec.europa.eu
- EUDR Benchmarking
- European Commission Implementing Act, 22 May 2025. green-forum.ec.europa.eu
- EU IUU Carding
- European Commission third-country carding records. ec.europa.eu/fisheries
- LRQA EiQ
- Supply Chain ESG Global Risk Outlook 2024. lrqa.com
- amfori ESG Risk Compass
- Country ESG risk indicators. amfori.org
- EcoVadis
- Global Supply Chain Sustainability Index 2025. ecovadis.com
- EU TARIC
- EU customs tariff and trade measures database. ec.europa.eu/taxation_customs
- ITUC
- Global Rights Index 2024. globalrightsindex.org
- Walk Free
- Global Slavery Index 2023. walkfree.org
Maintenance
Update Cadence
- Review frequency
- Scores are reviewed quarterly.
- Triggers for change
- New ILAB TVPRA listings or annual Findings report; EUDR country benchmark reclassification; IUU card changes; TI CPI annual update (published February each year); RASFF alert pattern changes; GSP status changes; new DG SANTE audit findings.
- Documentation
- Each score update is documented with the triggering source.
Limitations
Important Caveats
- —Scores are indicative assessments for sourcing intelligence purposes.
- —They do not constitute legal advice or formal risk certification.
- —Country conditions change — always verify against current official sources before procurement decisions.
- —Sector-specific risk within a country may vary significantly from the country-level score.