Regulation explainerAgriculture

EUDR traceability: the geolocation and evidence data you need to hold

EUDR traceability means holding, for every relevant product, the geolocation of each plot where the commodity was produced, evidence that the land was not deforested after 31 December 2020 and evidence of legal production, then filing a due diligence statement before placing the product on the EU market1. This page sets out those requirements from the data side.

Reviewed 8 min read

On this page
  1. Where the rules stand at this page's review date
  2. The instruments that define EUDR data obligations
  3. Who files a due diligence statement, and who only keeps records
  4. Plot geolocation rules in plain terms
  5. From plot registry to a filed due diligence statement
  6. Reference architecture for EUDR traceability data
  7. What satellite checks can prove, and what they cannot
  8. Chain of custody through cooperatives, collectors and exporters
  9. A hypothetical coffee exporter consolidating smallholder lots
  10. Questions and answers
  11. Sources

Where the rules stand at this page's review date

The instruments that define EUDR data obligations

Regulation (EU) 2023/1115 on deforestation-free products (EUDR), as amended by Regulations (EU) 2024/3234 and (EU) 2025/2650 and Delegated Regulation (EU) 2026/2102

European Union

Applies whenAnnex I products containing or made with cattle, cocoa, coffee, oil palm, rubber, soya or wood are placed on, made available on or exported from the EU market1.

  • Products must be deforestation-free, legally produced under the law of the country of production, and covered by a due diligence statement or simplified declaration1.
  • Operators collect information including the geolocation of all plots of production and keep it for five years1.
  • Operators assess risk and mitigate it to a negligible level before placing products on the market1.

Commission Delegated Regulation (EU) 2026/2102 (list of relevant commodities and products)

European Union

Applies whenFrom its entry into force in September 2026, with several new product entries deferred to 30 December 20276.

  • Replaces parts of Annex I, so check every customs code you handle against the amended list rather than the original one6.
  • Narrows commodities by species, for example rubber to Hevea brasiliensis and oil palm to Elaeis, and excludes bamboo and rattan from wood6.

Commission Implementing Regulation (EU) 2025/1093 (country benchmarking list)

European Union

Applies whenAlways, because it sets the risk category of each producing country3.

  • Lists countries classified as low or high risk; every other country stays at standard risk, and sourcing only from low-risk countries permits simplified due diligence3.

Who files a due diligence statement, and who only keeps records

The amended text concentrates filing on whoever places a product on the EU market first; most downstream duties become record keeping4.

RoleWho it isStatement or declarationRecords and registration
Operator placing firstFirst to place a relevant product on the EU market, or to export itFiles a due diligence statement in the EU Information System before placing or exporting1Keeps Article 9 information for five years and passes reference numbers on1
Micro or small primary operatorA natural person, micro or small undertaking established in a low-risk country1A one-time simplified declaration under Article 4a instead1Annex III information; a postal address can replace geolocation in defined cases1
Downstream operatorPlaces products made from inputs already covered by a statement or declaration1None of its own4Keeps supplier and customer details and reference numbers; non-SMEs register in the Information System1
TraderMakes products available on the EU market after another operator placed themNone of its own4Same record keeping as downstream operators; non-SMEs register1

A simplified summary; firms that both import and process should check the consolidated text for their exact position.

Plot geolocation rules in plain terms

Plot of land
Land within a single real-estate property, as recognized by the law of the country of production, with conditions homogeneous enough to assess as one unit1.
Geolocation
Latitude and longitude coordinates using at least six decimal digits; a single point can describe a smaller plot1.
Polygon requirement
Plots of more than four hectares need a polygon tracing the perimeter; for cattle, geolocation means the establishments where animals were kept1.
Deforestation-free
Produced on land not deforested after 31 December 2020, and for wood, harvested without inducing forest degradation after that date1.
Forest
Land of more than 0.5 hectares with trees higher than 5 meters and canopy cover above 10 percent, or able to reach those thresholds, excluding land mainly under agricultural or urban use1.

From plot registry to a filed due diligence statement

  1. Register every supplying plot

    Record each plot with its producer, a stable identifier, the commodity and production period; walk the boundary with a phone or GNSS receiver where a polygon is needed.

    Output
    Plot registry
    Owner
    Sourcing and field teams

  2. Validate the geometry

    Check coordinates carry at least six decimal digits1, use one coordinate reference system, close without self-intersecting, match declared areas and do not overlap other producers' plots.

    Output
    Validated geometries
    Owner
    Data team

  3. Screen against the cut-off date

    Compare forest cover on and around each plot before and after 31 December 2020 and route every detected loss to a reviewer1.

    Output
    Screening result per plot
    Owner
    Remote-sensing analyst

  4. Collect legality evidence in proportion to risk

    Gather land-use rights, permits and labor and tax evidence; the Commission's updated guidance says detail should scale with risk2.

    Output
    Legality file per supplier
    Owner
    Compliance team

  5. Link plots to lots

    At every aggregation point, record which plots fed each lot so the statement can list them all.

    Output
    Lot-to-plot links
    Owner
    Operations

  6. Assess, file and retain

    Assess and mitigate risk per shipment, file the statement, pass its reference number on and keep the evidence for five years1.

    Output
    Statement reference and archive
    Owner
    Compliance team

Reference architecture for EUDR traceability data

Statement assembly01Risk assessment workflow02Lot and custody records03Satellite screening04Append-only provenance log05Plot and supplier registry06
  1. Statement assembly

    Builds statements from approved lots and stores reference numbers.

  2. Risk assessment workflow

    Combines country risk, screening and supplier evidence into a documented decision.

  3. Lot and custody records

    Links plots to lots and blocks lots containing unverified supply.

  4. Satellite screening

    Flags forest loss after the cut-off date for human review.

  5. Append-only provenance log

    Anchors hashes of records, for example on Hedera Consensus Service, so later edits are detectable.

  6. Plot and supplier registry

    Producers, geometries and documents, captured offline.

Conceptual layered architecture of responsibilities, not a specific product; the provenance log supports due diligence and never replaces it.

What satellite checks can prove, and what they cannot

Satellite change detection is the practical way to screen thousands of plots against the cut-off date: combine optical time series, radar where cloud persists and published forest maps, and send every detected loss to a reviewer.

Its limits matter. The EUDR's forest definition uses area, tree-height and canopy thresholds and excludes land mainly under agricultural use1, so shade-grown coffee, cocoa agroforestry and rubber are hard to classify from imagery alone. Small clearings near a boundary fall within positional error, and cloud can hide the decisive dates.

Satellites say nothing about legality, which comes from documents and local knowledge. ColdAI uses Hedera Consensus Service as a verifiable backbone for compliance evidence and supply-chain provenance5; such a log proves when evidence existed and that it has not changed, which supports, but never replaces, the operator's judgment.

Chain of custody through cooperatives, collectors and exporters

Most smallholder commodities pass through collectors, cooperatives, mills or exporters before an EU operator sees them, and each step mixes volumes. Because the operator must hold the geolocation of all plots behind a product1, every aggregation point has to record which plots fed which lot; mass-balance claims used in some voluntary schemes do not meet that test.

Two designs work. Segregation keeps verified supply physically apart from farm gate to export. Plot-list tracing allows mixing only among plots that are all registered, screened and linked to the lot. Either way, one unverified delivery spoils the lot, so intake controls at the collection point matter most.

A hypothetical coffee exporter consolidating smallholder lots

Questions and answers

How does EUDR country benchmarking change the due diligence required?

The Commission classifies producing countries as low, standard or high risk; countries not listed as low or high stay at standard3. Sourcing only from low-risk countries allows simplified due diligence, meaning information collection without the full risk assessment and mitigation steps, unless you learn of a specific risk1. Plot geolocation is still needed in every category, apart from the postal-address option for qualifying micro and small primary operators.

How can smallholders without GPS devices provide plot geolocation?

Most programs use field officers or cooperative staff with phones or low-cost GNSS receivers. Apps should work offline, timestamp each capture, record what the farmer agreed to share and sync later. Some producer governments also run national farm registries. Either way, validate the geometry and confirm the plot with the farmer before it enters a statement.

What should we do with plots that cannot be verified?

Keep them out of EU-bound lots until the gap is closed. Typical causes are missing or implausible geometry, overlap with another producer's plot, a satellite alert after the cut-off date or missing legality documents. Record the reason, give the supplier a route to fix it, such as re-mapping or documents, and screen again. Supply that stays unverified can go to markets outside the scope but must never be mixed back into compliant lots.

Are wood, pulp and paper products covered by the EUDR?

Yes. Wood is one of the seven commodities, and the amended Annex I covers products such as logs, sawn wood, furniture, wood pulp and paper and paperboard1. Used and second-hand products, recovered paper and products made from it, and bamboo or rattan items are excluded6, as is single-use packing material used only to support, protect or carry another product1. The December 2025 amendment removed printed products from scope4. Timber produced before 29 June 2023 stays under the EU Timber Regulation until 31 December 20291.

Sources

  1. Regulation (EU) 2023/1115, consolidated text of 18 September 2026 — EUR-Lex · checked 10 October 2026
  2. COM(2026) 191 final: Simplification review on Regulation (EU) 2023/1115 — European Commission · checked 10 October 2026
  3. Commission Implementing Regulation (EU) 2025/1093: list of low-risk and high-risk countries — EUR-Lex · checked 10 October 2026
  4. The amended EUDR: what has changed and what has remained — Stibbe · checked 10 October 2026
  5. Hedera Consensus Service: verifiable ordering for provenance and compliance evidence — ColdAI
  6. Commission Delegated Regulation (EU) 2026/2102 amending Regulation (EU) 2023/1115 as regards the list of relevant commodities and relevant products — EUR-Lex · checked 10 October 2026

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