EU Deforestation Regulation Geolocation plots and polygons FAQ

For each in-scope relevant product, collect plot-level geolocation evidence for the land where the relevant commodities in that product were produced, then keep it tied to the due diligence file. The record should show the relevant commodity or product, supplier, production country or area, production date or time range, plot evidence, supporting documentation for deforestation-free and legal production, and the due diligence statement or simplified declaration reference when one exists.

A polygon is not a complete compliance record. The geolocation evidence must remain connected to the product lot, shipment, batch, or consignment that will be placed on the market, made available, or exported. If the same supplier ships mixed material from multiple production plots, the evidence file needs to preserve which plots support which product movement.

Geolocation also has a legal consequence. Article 9 says deforestation or forest degradation on a listed plot automatically disqualifies the relevant commodities and products from that plot. For all commodities, deforestation-free status uses the 31 December 2020 cut-off; wood also must have been harvested without inducing forest degradation after that date.

Supplier evidence should let the operator or downstream reviewer trace the product back to the production plots or establishments and evaluate whether the EUDR conditions are met. A supplier name alone is not enough if it cannot be connected to the land where the commodity was produced and to the specific product movement being reviewed.

For upstream operators, this usually means collecting and retaining the geolocation information and documentation demonstrating deforestation-free and legal production. For downstream operators and traders, the record should also preserve the supplier details and, where the supplier is an operator, the due diligence statement reference number or simplified declaration identifier communicated through the supply chain.

Build the link in both directions. From a product or consignment, a reviewer should be able to identify the supplier evidence and production plots or establishments that support it. From a plot record, a reviewer should be able to see which product lots, consignments, due diligence statements, or simplified declaration identifiers used that evidence.

EUDR due diligence is performed before placing relevant products on the market or exporting them. Operators submit or make available the due diligence statement through the Article 33 information system when due diligence concludes compliance. Downstream operators and traders then rely on supply-chain information, including reference numbers or declaration identifiers where relevant, rather than a disconnected map archive.

Geolocation evidence is one input into the Article 10 risk assessment. The operator uses the collected information and evidence to assess non-compliance risk before placing on the market or exporting. If the risk assessment does not show no or only negligible risk, the operator must not proceed without risk mitigation.

The review should check whether the plot evidence is complete for the product movement, whether supplier evidence supports deforestation-free and legal production, whether the coordinates overlap land deforested after 31 December 2020, whether wood harvesting caused forest degradation after that date, and whether supply-chain complexity or mixing breaks traceability.

Coordinate precision and polygon thresholds come from the Regulation. Portal file formats, upload limits, and validation messages come from the information-system rules and current technical instructions. Record which technical specification was used instead of treating a portal convention as part of Article 2.

The Article 2 definition requires latitude and longitude coordinates with at least six decimal digits. One point can describe a plot of four hectares or less. A non-cattle production plot larger than four hectares requires a polygon with enough points to describe its perimeter. Article 9 requires all production plots when multiple plots contributed to the product.

A plot of land is land within one real-estate property under the law of the production country, with sufficiently homogeneous conditions to evaluate aggregate deforestation and forest-degradation risk. The four-hectare rule applies to each such plot, not to a supplier's total farm area or a shipment's combined sourcing area.

For cattle and products made from or fed with cattle, Article 9 refers to all establishments where the cattle were kept. Eligible micro or small primary operators may replace Article 9(1)(d) geolocation with the postal address of all plots or the establishment. That substitution does not extend to other operators.