Geolocation and traceability

Geolocation requirements under the EUDR

Geolocation is the single most transformative requirement of the EUDR. Unlike previous regulations that relied on country-level or concession-level traceability, the EUDR demands plot-level identification of every piece of land where covered commodities were produced.

Article 9(1)(d) requires operators to collect and provide:

• Geolocation coordinates of all plots of land where the relevant commodity was produced
• The coordinates must be sufficiently precise to allow competent authorities to verify deforestation-free status using satellite imagery

This requirement applies regardless of the commodity, the country of production, or the risk classification. It is the backbone of the regulation's enforcement mechanism.

Plot size thresholds

The regulation distinguishes between two scenarios based on plot size:

Article 9(1)(d) specifies that the polygon must be sufficient to identify the plot unambiguously. In practice, this means:

• Minimum of 3 coordinate pairs for a polygon (typically 4+ for agricultural plots)
• Coordinates in WGS84 geodetic reference system (the standard used by GPS)
• Precision of at least 5 decimal places (approximately 1.1 metres at the equator)

What constitutes a "plot of land"?

Article 2(28) defines a "plot of land" as a contiguous area within a single real-estate property used for the production of a relevant commodity. Key implications:

• A single farm with multiple non-contiguous fields requires separate geolocation for each field
• A plantation with a single contiguous boundary requires one polygon
• Cattle that graze on multiple pastures require geolocation for each pasture used during the production period
• For tree crops (cocoa, coffee, rubber, palm oil), the geolocation covers the plantation area
• For cattle, it covers all land used for grazing and feed production attributable to the animals

The cut-off date: 31 December 2020

Article 2(27) establishes the cut-off date as 31 December 2020. This means:

• The relevant commodity must have been produced on land that was not subject to deforestation after 31 December 2020
• For wood: the forest must not have been subject to forest degradation after 31 December 2020
• The reference state of the land on 31 December 2020 is the baseline against which compliance is assessed

How to verify the cut-off date

Operators must demonstrate that the land identified by geolocation was forested, agricultural, or otherwise classified as of 31 December 2020, and has not been deforested since. The primary verification method is satellite imagery analysis:

1. Obtain satellite imagery of the plot as of December 2020 (baseline)
2. Compare with current imagery to detect any forest cover change
3. Document the analysis methodology, data sources, and conclusions

Available satellite data sources:

Global Forest Watch (WRI) provides free, publicly accessible deforestation alert data (GLAD alerts) at approximately 30 m resolution with near-real-time updates. This is a widely used baseline tool.

Forest definition under the EUDR

Article 2(4) defines "forest" using the FAO definition:

• Land spanning more than 0.5 hectares
• With trees higher than 5 metres (or able to reach that height in situ)
• With a canopy cover of more than 10%
• Excluding land predominantly under agricultural or urban use

"Deforestation" (Article 2(3)) means the conversion of forest to agricultural use, whether human-induced or not. "Forest degradation" (Article 2(6)) -- applicable to wood products only -- means structural changes reducing canopy cover below the 10% threshold without conversion to agricultural use.

Satellite monitoring tools and platforms

EU-level tools

The European Commission is developing monitoring tools to support EUDR implementation:

EU Observatory on Deforestation (Global Forest Watch Pro partnership):

• Global deforestation monitoring at 10-30 m resolution
• Integration with Copernicus Earth Observation data
• Near-real-time alerts for forest cover change
• Planned integration with the EUDR information system

Copernicus Land Monitoring Service (CLMS):

• High-resolution land cover maps (pan-European and global)
• Forest type and tree cover density layers
• Change detection services
• Free and open access

Commercial solutions

Several commercial platforms offer EUDR-specific geolocation and monitoring services:

Open-source and free tools

• Global Forest Watch (globalforestwatch.org): the most widely used free platform for deforestation monitoring
• OpenForis (FAO): plot-level data collection tools designed for forest inventories
• SEPAL (FAO): cloud-based satellite imagery analysis platform
• Google Earth Engine: programmatic access to decades of satellite imagery for custom analysis

Operational challenges by commodity

Smallholder supply chains (cocoa, coffee, rubber)

The geolocation requirement is most challenging for commodities produced by millions of smallholders with plots under 4 hectares:

• Cocoa: approximately 5-6 million farmers, average plot size 2-3 ha in West Africa
• Coffee: approximately 12.5 million producers globally, many with fragmented holdings
• Rubber: millions of smallholders in Southeast Asia with average holdings of 1-3 ha

Practical challenges:

• Many smallholders lack smartphones or GPS devices
• Land boundaries are often informal and undocumented
• Cooperative aggregation blends product from hundreds of farms
• GPS accuracy under dense canopy can be limited (5-15 m error typical)
• Cost of mapping millions of individual plots is substantial

Solutions emerging:

• Mobile-based GPS collection apps (e.g., Meridia, Farmforce)
• Pre-competitive industry initiatives (e.g., CocoaAction, Global Coffee Platform)
• Government-supported land registration programmes
• AI-assisted plot delineation from satellite imagery

Cattle supply chains

Cattle present a unique traceability challenge because animals move between properties during their lifecycle:

• Birth farm -- typically small, often unregistered
• Rearing/fattening operations -- may involve multiple pastures
• Feedlots -- concentrate animals from diverse origins
• Slaughterhouses -- aggregate animals from multiple suppliers

The EUDR requires geolocation for all plots of land used during the relevant production period. For beef, this potentially means tracking every pasture an animal grazed on, plus the land where its feed (soy, maize) was produced.

Brazilian context: Brazil's cattle traceability system (GTA -- Guia de Transito Animal) tracks direct suppliers to slaughterhouses but does not systematically cover indirect suppliers (birth farms, intermediate rearing). This "indirect supplier" gap is a major compliance challenge.

Palm oil and blending

Palm oil passes through several processing stages where blending occurs:

1. Plantation -- fresh fruit bunches (FFBs) harvested
2. Mill -- FFBs from multiple plantations processed into crude palm oil (CPO)
3. Refinery -- CPO from multiple mills refined and fractionated
4. End-user -- refined oil blended into final products

At each stage, product from different sources may be mixed, making plot-level traceability difficult without physical segregation or robust mass balance systems.

Segregation vs. mass balance

The EUDR requires operators to demonstrate that specific products originate from specific plots. Two main approaches exist:

Physical segregation (identity preserved)

• Compliant and non-compliant product are kept physically separate throughout the supply chain
• Each batch can be traced to specific plots of land
• Highest level of assurance but most expensive and logistically demanding
• The EUDR standard: this is what the regulation fundamentally requires

Mass balance

• Compliant and non-compliant product may be mixed, but the volumes are tracked
• Credits are issued for compliant volumes entering the system
• The output is allocated proportionally between compliant and non-compliant
• Not explicitly accepted by the EUDR: the regulation requires that the specific product placed on the market is deforestation-free, not merely that an equivalent volume was sourced deforestation-free

Practical implications

For many supply chains (especially palm oil and cocoa), full physical segregation is not currently feasible at every stage. Operators and industry groups are actively engaging with the Commission to clarify:

• Whether certified mass balance systems can satisfy the regulation's requirements in the processing stages
• How to handle unavoidable commingling at shared infrastructure (mills, refineries, ports)
• What level of "book and claim" traceability, if any, is acceptable

The Commission's guidance documents (expected in 2026) should provide clarity on this critical implementation question. Until then, operators should work towards the highest feasible level of traceability in their supply chains.