FAQs Explained: EUDR Traceability & Geolocation (3rd ed.)
Understanding the requirements right
The European Union’s Deforestation-Free Regulation (EUDR) continues to evolve, bringing new clarifications and adjustments to ensure compliance with strict sustainability and traceability requirements.
In the latest update of the third edition of the Frequently Asked Questions (FAQs) document, published in October 2024, the EU has provided answers to or integrated 56 additional questions, refining the framework for businesses operating within its jurisdiction.
Among the key topics addressed, traceability and geolocation remain critical components, requiring precise tracking of commodities back to their source to prevent deforestation-related risks.
This article delves into the updated guidance on traceability, shedding light on how bulk-traded and composite products are handled, the requirements for geolocation data submission, and interesting exceptions to the general rules.From geospatial data formats to due diligence obligations, these FAQs provide helpful insights for operators, traders, and stakeholders navigating the EUDR’s evolving landscape.
Whether you’re a business working to align with these stringent regulations or simply looking to stay informed, this breakdown will help you understand the latest expectations and best practices for traceability and geolocation under the EUDR. We quote the original questions as they appear in the FAQ document to ensure you can easily recognise them. So fasten your seat belts because we are ready to dig in!
Understanding EUDR: Traceability & Geolocation
1.3. How does it work for bulk-traded or composite products? (Partially NEW)
EUDR mandates that operators and non-SME traders must collect geolocation data, i.e. coordinates, for the plots of land where commodities were produced. The next two sections have not been updated since the 2nd edition of the FAQs.
What happens if the products are traded in bulk?
Operators and non-SME traders must identify all plots of land associated with any products in the shipment and ensure these commodities haven’t mixed with non-compliant commodities during the supply chain processes.
What happens in the case of composite products?
There’s no way around it: for every commodity in the shipment, companies must submit the geographic coordinates of each plot where these commodities were produced. However, the new FAQs introduce a sort of simplification for handling composite products.
For products containing a combination of relevant commodities and products, operators and non-SME traders must conduct due diligence over the main commodity and derived products of that commodity.
But what does this mean? Let’s use the example from the FAQs, which is a chocolate bar containing both cocoa and palm oil. Here, the HS code of the final product is “1806 – Chocolate and other food preparations containing cocoa.” This means cocoa is the main commodity (as indicated in Annex I), so the company is only required to conduct due diligence on the cocoa.
To summarise, the steps are:
- Identify the HS code of the product.
- Identify the main commodity.
- Conduct due diligence on the main commodity only.
1.7. What is the size of the area (hectares) that can be covered by a polygon? (NEW)
The regulation itself doesn’t specify a maximum plot size, but the FAQ document does set out certain conditions. First, the plot needs to represent a specific area, meaning it should pinpoint the exact production site, not a broader area like a province or region.
Second, these polygons should be consistent enough to allow for accurate risk assessment regarding deforestation and forest degradation.
We also advise creating multiple GeoJSON files for each of the land plots so that the evaluation can be more precise – and you might be able to avoid repetitive analyses.
While there’s no restriction on the size of polygons you can upload to the Information System, keep in mind that the DDS file size cannot exceed 25 MB. How to get a feeling that the dimension is good? Consider that 25 MB is the maximum size of files that you can send via Gmail or Outlook.
1.8. Does geolocation need to be provided by means of polygons in all cases? (NEW)
The short answer would be “No.” However, there are some exceptions; for instance, if the land plot size is lower than 4 ha, then the polygon is not necessary, and the coordinates can be shared with one latitude and longitude point only.
The second exception would be cattle. As cattle is the only “live” relevant commodity under EUDR requirements, it must be treated slightly differently. In this case, polygons are unnecessary, and suppliers can provide one latitude and longitude point for all locations where the cattle have been kept.
Focus Point: Geolocation for Cattle
Operators and large traders can submit single geolocation points in the case of live cattle (HS Code 0102 21, 0102 29), e.g., cows that are sold to slaughterhouses. In particular, operators must submit geolocation data for each location where the cattle were held before being placed on the EU market; while large traders must add to the due diligence statement each location where the cattle were held after the first placing on the EU market (Article 9, para. 1d).
On the other side, SME traders are not required to provide additional geolocation data points or issue new DDSs, but they still need to keep the collected information and the due diligence statement for at least 5 years.
If the cattle was born before 29 June 2023, i.e. the enforcement date of EUDR, then the Regulation does not apply.
1.9. How should polygons in digital format be declared? (NEW)
The formats currently supported by the Information System are GeoJSON file format and WGS-84, with EPSG-4326 projection. In future, it might be possible that the system, building on the user feedback, would develop further and eventually accept other common geolocation file standards.
The EU will adopt an implementing act to define in detail the rules for the functioning of the Information System, and the various stakeholders will be notified about these developments via the Multi-Stakeholder Platform on Protecting and Restoring the World’s Forests, a platform existing to inform the public about EUDR updates and related impact assessment.
1.15. What if a relevant commodity is produced on a plot of land within a single estate property, including also other plots of land? (NEW)
Let’s take the FAQ document example as a starting point to define the right approach.
Imagine that the supplier is producing soy, a relevant commodity, in area B. How do you know which geolocation should be provided?
For EUDR, what is relevant is the plot of land where the relevant commodity is produced. The best practice imposes to conduct one risk assessment per commodity, per shipment and per land plot. This means that, in this case, the operator must provide only geolocation data for area B. If soy is produced in areas B and C, then the operator will have to request the supplier to provide separate GeoJSON files of area B and of area C.
What if deforestation in area C is legal and after the cut-off date?
Remember that EUDR only applies to relevant commodities and requires a strong correspondence between the relevant commodities and products placed in the EU market and the related land plots. Adopting this perspective, we will answer the question considering different scenarios:
| SCENARIO | APPROACH |
| No relevant commodity is produced in area C. | The production of soy in area B is compliant with EUDR. |
| Another relevant commodity (e.g. cattle) is produced in area C. | The production of soy in area B is still compliant with EUDR, but the production of beef will result non-compliant with EUDR requirements. |
| Soy is produced in areas B and C. | If the final output consists of a mix of the soy produced in areas B and C, then the product does not comply with EUDR. To be compliant, the operator will have to implement specific risk mitigation measures, eventually sourcing soy only from area B and ensuring it does not mix with soy produced in area C (Article 10, para. 2j). If the final output only uses soy produced in area B, then its production is compliant with EUDR. |
What if the legal status of the real estate property A is affected by illegality within the meaning of the Regulation (for instance, if there is illegal deforestation in area C)? Is the soy produced in area B affected?
The EUDR mandates that relevant products must be deforestation-free, must be covered by a due diligence statement based on a due diligence system, and must have been produced according to the law of the country of production. Based on this last condition, if the legal status of the land plot shifts to being ‘illegal’, then the production activities in that area will automatically become illegal. In our example, the soy produced in area B will not be compliant with EUDR.
1.17. How should the place of production of mixed goods be declared? (NEW)
Mixed goods must be treated as a combination of the relevant commodities, each requiring a risk assessment over their supply chain. In particular, the operator must clarify where each component has been produced.
It all gets more complicated when compliant goods from multiple production sites are gathered together into the same containers – e.g. silo, stack, pile, tank, etc. – and then packed and placed on the EU market.
What to do in such cases?
- The operator must ensure traceability by identifying the origin of all goods collected in the same container since it was last emptied, as these goods could potentially be included in the shipment.
- In the case that silos are not emptied on a regular basis, the operator must determine and disclose the production sites of all goods that entered the silo over a period of time. The timeframe must be sufficiently long to ensure that relevant components with an unknown origin are not mixed in. For example, when removing a portion of the goods stored in the silo, this can be done safely by providing the geolocation of all previously stored goods amounting to at least 200% of the silo’s capacity, assuming the silo operates on a first-in, first-out basis. This method is also applicable to other types of storage and continuous processing systems, such as stacked goods, tanks, and similar facilities.
- Forget the shortcuts! Under the Regulation, it is not permitted to declare the production location of a quantity of goods equivalent to the amount being placed on the EU market, because it is easily deducible that those goods entered the silo at an earlier time. Doing so would violate the Regulation’s prohibition against placing products of unknown origin on the Union market.
1.18. Under which circumstances can operators declare more plots of land in a due diligence statement than those actually concerned by the production of the specific commodity placed on the market? What are the implications of a “declaration in excess”? (NEW)
We have already discussed how EUDR applies strict traceability criteria, requiring the tracking of the land plots for each and every relevant component of the final product.
In special cases, the operator can provide geolocation data for more land plots than those where the commodities were produced. This is referred to as declaring “in excess” and it is only applicable when it is possible to entirely trace a bulk commodity to the land plot, and this has not been mixed with other untraceable or non-compliant commodities.
In case the bulk commodity is mixed, for instance, if it was gathered with other relevant commodities in containers along the value chain, the land plot can be declared in excess if only a part of the whole land plot produce is placed on the market. However, the approach is strongly discouraged, as it would make it difficult, if not impossible, to comply with EUDR both for operators and competent authorities due to the extreme level of complexity.
In particular, you should be aware that this practice carries several risks, explained below.
- Increased Compliance Liability: By listing extra land plots in a due diligence statement, the operator takes on full responsibility for ensuring that every declared plot meets compliance standards. Even if only a portion of these plots is actually used in production, the operator remains liable for all of them.
- Higher Risk of Non-Compliance: If any single plot within the declared geolocation data is found to be non-compliant, the entire set is classified the same way. the risk of non-compliance, requiring the operator to guarantee that every declared plot meets regulatory requirements.
- Expanded Due Diligence Obligations: operators must conduct due diligence on all declared land plots, including those declared “in excess”, multiplying the efforts. This involves collecting the necessary information as explained in Article 9, “Information requirements”, conducting a risk assessment as reported in Article 10, “Risk assessment”, and coming up with risk mitigation measures as required in Article 11, “Risk mitigation”.
Moreover, the operator must also consider how difficult it would be to maintain control over the due diligence process in such situations. There would be a high probability that the relevant products cannot be easily traced back to the declared land plots, and that the risk of circumvention of EUDR and of mixing with relevant products that are untraceable and non-compliant is extremely high.
1.21. What type of checks may EU Member States Competent Authorities carry out in third countries in case a product is deemed potentially non-compliant with the EUDR? (NEW)
Competent authorities cannot carry out checks in third countries unless they agree to collaborate beforehand. The authorities can determine the need to carry out field audits in third countries as dictated in Article 18, para. 2e, but the EUDR does not mandate these aspects and does not explicitly demand that competent authorities directly consult third countries in their activities, not even when a product results to be ‘non-compliant’ or ‘potentially non-compliant’.
1.25. What is the ‘date or time range of production’? (Partially NEW)
Previously, this was question number 1.22 in the FAQ second edition.
Article 9, related to the information requirements, instructs operators and large traders to share the date and time range during which the commodity has been produced. This point in time is the driver to determine whether deforestation occurred because it allows a before-and-after land plot analysis. That is why EUDR applies both to the relevant raw materials directly placed in the EU market and to the goods produced with those relevant raw materials.
But how do you identify the correct time range?
Except for cattle, the ‘date of production’ corresponds to the harvest date, while the ‘time range of production’ corresponds to the duration of the production activities.
For instance, in the case of timber, the ‘time range of production’ would be the period during which all harvesting activities have been carried out. Of course, the timings should refer to the exact land plots where the commodities have been produced. In some cases where precise data are missing, operators can also share the crop year and/or harvesting season.
In the case of cattle and beef, the ‘time range of production’ corresponds to the lifetime of the animal, from the date of birth to the date of death. To know how to manage the information gathering with such commodity, please refer to the “Focus Point: Geolocation for Cattle” you can find above.
1.31. How can producers share the geolocation data when certain governments prohibit the sharing of such data? (NEW)
According to EUDR, operators and large traders must provide geolocation data related to the land plot used for the production of the relevant commodities. Without them, no deforestation analysis can be carried out, making the whole regulation pointless.
That is why geolocation data is simply uncompromisable. The FAQ documentation advises not to rely on governmental prohibitions to be excluded from compliance. In addition, there are multiple free tools which suppliers can use to collect this information, which is public and widely accessible.
If, for any reason, geolocation data points cannot be collected and submitted in the due diligence statement, the relevant commodities and products are deemed non-compliant and, therefore, cannot be placed in the EU market according to EUDR requirements.
Conclusions
The third edition of the EUDR FAQs reinforces the EU’s commitment to strengthening environmental due diligence and ensuring that commodities placed on the market are fully traceable to deforestation-free sources. With new clarifications on geolocation requirements, polygon data submissions, and risk assessment procedures, businesses must adapt to increasingly precise compliance measures.
The regulation leaves little room for ambiguity—whether dealing with composite products, mixed goods, or government-imposed data restrictions, operators must prioritise transparency to maintain market access. As companies refine their traceability strategies, the emphasis on compliance grows even stronger. Implementing robust geolocation tracking, risk mitigation measures, and due diligence practices will be essential for navigating this regulatory landscape.
While challenges remain, these guidelines provide a clear roadmap for businesses to align with EUDR requirements. Staying informed and proactive will be key to ensuring smooth operations in an increasingly regulated global supply chain.
RADIX Tree as EUDR Solution
RADIX Tree is an end-to-end solution that enables you to reach supply chain compliance from start to finish without the need for further integrations, partners or contracts.
The platform enables the automated collection and reporting of data. It also provides templates and instructions on which documents are required in each situation, thus reducing the effort and costs for the operator.
Above all, RADIX Tree is the smart tool that minimises the financial impact of supply chain compliance because it offers service packages to suit the size of your business – individually expandable and customisable.
