What EUDR actually requires
The EU Deforestation Regulation applies to seven commodities — cattle, cocoa, coffee, oil palm, rubber, soya and wood — and the products derived from them. To place any of them on the EU market you need three things: plot-level geolocation for the land where the commodity was produced, evidence that the land was not deforested after 31 December 2020, and evidence that production complied with the laws of the producing country.
Geolocation is the part that stalls programmes
The regulation asks for polygons for plots above four hectares and points for anything smaller. That sounds simple until the data arrives. In our own processing, over 75% of supplier GeoJSON files contain problems, and roughly 15% carry errors the EU Information System rejects outright — self-intersecting geometry, coordinates in the wrong reference system, duplicate vertices, plots declared in the wrong hemisphere.
Legality is a separate test
A plot can be entirely deforestation-free and still fail. The legality limb asks whether production complied with land use rights, environmental protections, labour law, human rights, and the principle of free, prior and informed consent in the country of production. That is a different evidence base from satellite analysis, and it is usually the one teams start late.
What good preparation looks like
- Collect plot geometry early — it depends on other companies responding, so it has a floor on how fast it can move
- Validate on arrival rather than at submission, so errors surface while there is still time to go back to the supplier
- Keep the deforestation assessment and the legality assessment as separate, separately evidenced workstreams
- Retain documentation for five years; the obligation outlives the shipment
Teams that are comfortable at the deadline are the ones collecting and validating now, not the ones planning to.
