EUDR geolocation data requirements for plots, products, and supplier evidence

The geolocation record should begin with the relevant commodity and the derived relevant product, not with an isolated coordinate file. Article 3 ties market access to products that are deforestation-free, produced in accordance with relevant legislation in the country of production, and covered by the required due diligence statement or simplified declaration.

For each SKU, shipment, batch, lot, or purchase order in scope, keep the commercial product identifier, Annex I product mapping used by the business, relevant commodity, country of production, supplier, and production plot or establishment reference together. If a product combines inputs from several farms, mills, plantations, forests, or other establishments, the record should preserve every contributing origin rather than reducing the file to a single country-level label.

Article 9 information collection requires operators to collect and keep information and evidence, including geolocation for the plots of land or establishments connected to the relevant commodities or products. The practical control is to make geolocation a required origin field before sourcing approval, not an after-the-fact sustainability attachment.

Suppliers should provide plot or establishment identifiers, the country of production, location evidence, and documents showing the product is deforestation-free and legally produced. As an internal control, the receiving team should preserve the original coordinate or polygon file, the normalized dataset used internally, the date collected, and the product lots it supports; the Regulation does not prescribe an internal file format or mapping vendor.

Geolocation evidence should feed the Article 10 risk assessment. The reviewer needs to determine whether the production locations, supplier chain, and supporting documents leave no or only negligible risk of non-compliance before the product is placed on the market or exported.

A location file that merely exists is not enough. The evidence should be checked against country of production, supplier chain complexity, possible mixing or circumvention, deforestation-free evidence, and legal-production documentation. Where the risk assessment does not reach no or negligible risk, Article 11 mitigation must happen before market placement or export.

Supplier evidence should make the origin claim auditable. For upstream suppliers, keep the contract or onboarding record, supplier contact details, commodity and product description, production location evidence, legal-production documents, and the supplier declaration or questionnaire response that explains how the origin data was collected.

For downstream operators and traders, Article 5 information matters. The record should include supplier details and, when the supplier is an operator, the due diligence statement reference number or simplified declaration identifier. Downstream records also need recipient information so the business can pass reference numbers and respond if new information indicates a risk of non-compliance.

The due diligence statement should be the final output of a traceable evidence chain, not the first place where geolocation data is assembled. Operators submit the statement only after due diligence concludes that the relevant product complies with Article 3 and the risk is no or negligible.

The DDS package should identify the product, commodity, country of production, origin evidence, risk assessment result, mitigation record if needed, responsible operator, and the reference number or declaration identifier used for downstream communication. The Article 33 information system context means teams should preserve both the submitted statement record and the non-public evidence version that supported it.

A defensible geolocation workflow should fail fast when origin data is incomplete, contradictory, or detached from the product record. These checks are practical controls for sourcing, sustainability, trade compliance, and data teams before the evidence package is used in a DDS.

The goal is not to perfect mapping data in isolation. The goal is to prove that the relevant product, supplier chain, production location, legal-production evidence, risk conclusion, and statement record are consistent with each other.