EUDRGeolocation evidenceEU

EUDR geolocation evidence and Annex I commodity lookup

Structure the evidence that connects a relevant product to scope, supplier and trader records, production locations, risk assessment, and due diligence statement support.

Connect each scope decision to the product, production locations, supporting documents, release decision, and retained record.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

First confirm that the exact product description and Combined Nomenclature (CN) code appear in the current . Then connect every relevant commodity in that product to all production plots or, for cattle, all establishments used during production. The lookup must also connect those locations to the production period, supplier chain, risk decision, and reference or simplified-declaration identifier that supports the transaction. Complete this work before covered movements from 30 December 2026. The 30 June 2027 date applies only to operators that were established as natural persons or micro or small undertakings by 31 December 2024, and it does not apply to products covered by the EU Timber Regulation annex.

Section 1

Start with Annex I scope, not a generic commodity label

The lookup should first decide whether the item is a relevant commodity or relevant product listed in . The commodity families are cattle, cocoa, coffee, oil palm, rubber, soya, and wood; only the derived products listed under the relevant Combined Nomenclature (CN) entries are in scope.

Read together with Commission Delegated Regulation (EU) 2026/2102, in force from 18 September 2026. Its product removals, exclusions and revised descriptions affect the scope match. Specific added products, including frozen cattle tongues and coffee extracts, separately apply from 30 December 2027. Record the exact amended entry, Combined Nomenclature (CN) code, product description and applicable date for each scope decision.

  • Record the product identifier used by procurement, trade compliance, and inventory systems.
  • Record the commodity family and the specific Annex I product description used for the scope call.
  • Separate out-of-scope items from items that need due diligence support before market placement, availability, or export.
  • Keep the lookup versioned so later supplier, lot, or product-description changes do not silently reuse an old scope decision.
Section 3

Collect geolocation evidence as part of Article 9 information

Article 2 defines as latitude and longitude using at least six decimal digits. Article 9 requires all plots where the relevant commodities were produced and, for cattle, every establishment where the cattle were kept. For a plot larger than four hectares used for commodities other than cattle, provide a polygon with enough latitude and longitude points to describe its perimeter.

Capture the production date or time range as well as the coordinates. If any relevant commodity was produced on multiple plots, every plot must be included; if the product cannot be linked to all required locations, Article 9 does not allow the operator to place it on the market or export it. A qualifying micro or small primary operator may instead provide a postal address that clearly corresponds to the geographic location under Article 4a.

  • Validate coordinate precision, geometry type, coordinate order, and coverage of every plot or cattle establishment before risk assessment.
  • Attach each point or polygon to the supplier, product record, and production date or time range it supports.
  • Keep documentation used to demonstrate deforestation-free status and legal production with the same product evidence file.
  • Flag gaps where a product lot cannot be tied back to the relevant production-location evidence.
  • Use the Article 4a postal-address option only after documenting micro or small primary-operator status, including low-risk-country establishment and own production.
Recommended next step

Connect EUDR products to their evidence

Connect Annex I scope, supplier records, geolocation evidence, risk assessment, and due diligence statement support before teams release covered products.

Section 4

Use the lookup in risk assessment and mitigation

The lookup is not complete when coordinates or supplier documents are collected. On the standard route, EUDR due diligence includes information collection, risk assessment, and risk mitigation where needed. Article 13 permits qualifying low-risk production to omit Articles 10 and 11 after the required checks. Operators should use the linked product, supplier, country or part-of-country risk context, evidence, and legality documentation to decide whether there is no or only negligible risk before placing on the market or exporting.

If risk is not negligible, mitigate it before placement or export. Keep the mitigation action, reviewer, outcome, and product or transaction identifiers together.

  • Treat missing scope support, missing supplier details, missing location evidence, or broken product-lot linkage as risk-assessment inputs.
  • Where low-risk production is relied on, keep documentation showing supply-chain complexity and risks of circumvention or mixing were assessed.
  • Do not use country-risk status as a reason to discard Article 9 information that must still be collected and kept.
  • Do not release a product record for EUDR-covered activity when the linked assessment still shows more than negligible risk.
Section 5

Support the due diligence statement and information-system record

Operators exercise due diligence before placing relevant products on the market or exporting them. Unless the separate Article 4a regime applies, they submit a due diligence statement through the Article 33 information system after the evidence supports compliance and no or negligible risk.

The commodity lookup should therefore be able to reconstruct the path from product and supplier records to evidence, risk assessment, mitigation if any, and due diligence statement reference numbers. Downstream operators and traders also need the relevant supply-chain information and reference numbers or identifiers so the evidence can travel further down the supply chain.

  • Keep the due diligence statement record or simplified-declaration identifier with the product and transaction record.
  • Retain the evidence used to support the no-or-negligible-risk conclusion.
  • Retain operator due diligence documentation for at least five years, statement records for five years from submission, and Article 5 information for at least five years from placing, making available, or export.
  • Make the evidence retrievable by product, supplier, recipient, lot, shipment, consignment, and due diligence statement reference number.
Primary sources

References and citations

eur-lex.europa.eu6 citations
Referenced sections
  • Official consolidated text, provided by EUR-Lex as a documentation tool, for current Annex I scope, geolocation definitions and coverage, Article 9 evidence, risk assessment, mitigation, and DDS support.
  • Article 1 and Annex I support the commodity-family and product-code scope test.
  • Articles 4 and 5 support supplier and recipient linkage, DDS reference or declaration-identifier handoff, retention, and action on new risk information.
Show 3 more
  • Articles 2, 4a, and 9 support six-decimal geolocation, all-plot or all-establishment coverage, the four-hectare polygon rule, production-time data, the no-geolocation stop rule, and the limited postal-address option.
  • Articles 8 to 13 support the evidence, assessment, mitigation, release, and low-risk simplified-due-diligence sequence.
  • Articles 4, 5, 9, and 33 support DDS linkage, product-location evidence, supply-chain information, and retention.
eur-lex.europa.eu2 citations
Referenced sections
  • Current Information System amendment for DDS and simplified-declaration records.
  • Current amendment to the Information System rules for due diligence statements and simplified declarations.
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