Geolocation Data Requirements Under EUDR

EUDR is often described as a deforestation law and is, operationally, a geolocation law. Almost everything difficult about complying with it reduces to obtaining coordinates for every plot that contributed to a consignment.

That sounds mechanical and is not, because the commodities in scope are frequently aggregated many times before they reach an EU importer, and aggregation is precisely what destroys plot identity.

What exactly is required?

Six decimal places is roughly a tenth of a metre, which is more precision than the underlying survey usually has. The requirement is about unambiguous identification of a plot rather than about survey-grade accuracy.

Which commodities are in scope?

Cattle, cocoa, coffee, oil palm, rubber, soya and wood, plus products derived from them as listed in the regulation’s annex. The derived product list is what pulls in manufacturers who do not think of themselves as commodity traders.

Furniture containing wood, tyres containing rubber, chocolate containing cocoa and leather from cattle are all captured. A furniture manufacturer therefore needs plot coordinates for the forests behind their panels, which is covered in EUDR for furniture manufacturers.

Who can actually produce coordinates?

• Large plantations and managed forests: usually yes, often already mapped.
• Cooperatives with mapping programmes: increasingly yes, at varying quality.
• Independent smallholders: frequently not, without a collection programme.
• Traders and aggregators: only if they collected it at the point of purchase.
• Processors several steps downstream: almost never, without chain investment.

The third row is the substance of the problem. Cocoa and coffee in particular reach the EU through millions of smallholdings, and mapping them is a field exercise rather than a data request.

How the data is submitted

Through a due diligence statement lodged in the EU Information System before placing the product on the market. The statement carries the geolocation data, information on the operator and a declaration that due diligence was exercised.

Submission generates a reference number that travels with the consignment and can be cited by downstream operators. That reference is what allows a manufacturer to rely on an upstream statement rather than repeating the entire exercise.

Geolocation is the input, not the answer

Coordinates alone do not establish compliance. They are used to assess whether the plot was deforested after 31 December 2020, which requires comparing the location against forest cover data for that date.

That assessment is the substantive obligation, and it is why the coordinates must identify the production plot rather than a convenient nearby point. A coordinate that names the wrong place produces a risk assessment about the wrong land.

The four ways collection fails

1. Coordinates for a facility rather than a plot: a mill, a warehouse or an office.
2. A single point supplied for a plot well above four hectares, where a polygon is required.
3. Aggregated lots where the contributing plots were never recorded.
4. Coordinates that cannot be attributed to a named supplier, so nothing can be verified.

The first is the most common and the easiest to miss, because the data looks complete. A spreadsheet of coordinates that all resolve to processing facilities passes a completeness check and fails the obligation entirely.

How to run the collection

Start at the point where aggregation happens, because that is the last place plot identity exists. For most chains that is the cooperative, the first buyer or the mill, and it is considerably further upstream than the supplier you contract with.

Then decide whether you are collecting or buying. Certification schemes and traceability platforms in these commodities increasingly supply coordinates as a service, which is faster and transfers the accuracy question to a third party rather than removing it.

What to hold against the product

The coordinates, the plot area, the supplier that asserted them, the date of assertion and the due diligence statement reference. Holding these against the consignment rather than in a compliance folder is what makes them retrievable when a downstream customer asks.

Downstream customers will ask. An operator relying on your statement needs its reference number, and a manufacturer whose records are organised by supplier rather than by consignment cannot produce it quickly.

What does the polygon threshold mean in practice?

Four hectares is roughly the size at which a smallholding becomes a plantation, and the threshold was set to avoid demanding survey work from farmers whose entire holding is smaller than the measurement error of a phone GPS.

The practical consequence is a split collection method. Smallholder programmes capture a point per farm, usually with a phone at the farm gate, while larger estates supply a polygon from existing land records or a mapping exercise.

Mixing the two in one dataset is normal and needs a field recording which is which, along with the plot area that justified the choice. A point supplied for a plot later found to be six hectares is a defect an authority can identify from the data alone.

How long does collection take?

For a chain with large, identified suppliers, weeks. For a smallholder chain without an existing mapping programme, a full season or more, because farms have to be visited and the visits follow agricultural cycles rather than compliance deadlines.

That asymmetry is why buyers in cocoa, coffee and rubber have moved toward sourcing through cooperatives and certified programmes that already hold the data. It is a sourcing decision driven by a data obligation, which is the recurring shape of these regulations.

What about confidentiality?

Plot coordinates reveal a supply base, which is commercially sensitive and in some regions a safety matter for the producers themselves. The regulation requires submission to authorities rather than publication, and that distinction should be preserved downstream.

This is a role-scoped access problem rather than a reason to avoid holding the data. A due diligence statement reference is shareable; the underlying coordinates generally are not, and a passport carrying both should treat them differently.