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, plot evidence, supporting documentation for deforestation-free and legal production, and the due diligence statement or simplified declaration reference when one exists.

Do not treat polygons as a standalone compliance artifact. The useful control is traceability: 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.

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.

This matters because 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 practical review should check whether the plot evidence is complete for the product movement, whether supplier evidence supports deforestation-free and legal production, whether there is supply-chain complexity or possible mixing that could break traceability, and whether any new information indicates a risk of non-compliance.

The available grounding supports one specific adjustment: for micro or small primary operators, Article 9(1)(d) geolocation may be replaced by the postal address of the plots of land or the establishment. That does not remove the need to keep the product, supplier, and due diligence evidence coherent.

The grounding reviewed for this FAQ does not support a public claim about a particular coordinate format, polygon file format, or plot-size threshold. If a workflow needs those details, treat them as blocked until the exact source text, implementing guidance, or system specification is available and cited.