EUDR compliance readiness: A short analysis of the update version of “Frequently Asked Questions Implementation of the EU Deforestation Regulation”.

The “Frequently Asked Questions Implementation of the EU Deforestation Regulation” updated on April 2026 answer the following questions on the traceability:

Why and how must operators collect coordinates? (UPDATED)

The Regulation requires operators placing covered products on the EU market or exporting them to collect geographic coordinates of the plots of land where the commodities were produced. This does not apply to downstream operators who place on the market or export such products . Traceability to the plot of land (i.e., the requirement to collect the geographic coordinates of the plots of land where the commodities were produced) is necessary to demonstrate that there has been no deforestation at the specific location of production. Geographic information linking products to the plot of land is already used by part of the industry and a number of certification organisations. Remotely sensed information (air photos, satellite images) or other information (e.g., photograph in the field with linked geotags and time stamps) may be used for verifying if the geolocation of declared commodities and products is linked to deforestation.

The geolocation coordinates need to be provided in the due diligence statements (hereinafter referred to as “due diligence statement” or “DDS”) or, where applicable, in the simplified declarations (hereinafter referred to as “simplified declaration” or “SD”) that operators are required to submit to the Information System ahead of the placing on the EU market or export from the EU of the products. It is therefore a core part of the Regulation, which prohibits the placing on the EU market, or the export, of any product covered by the Regulation’s scope whose geolocation coordinates have not yet been collected and submitted as part of a due diligence statement. The only exception is the SD of micro or small primary operators (MSPO), for whom the geolocation may be replaced by a postal address, provided that the postal address clearly corresponds to the geographic location of the plots of land or establishment concerned (see FAQ 3.28 for more details).

Collecting the geolocation coordinates of a plot of land can be done via mobile phones, handheld Global Navigation Satellite System (GNSS) devices and widespread and free-to-use digital applications (e.g. Geographic Information Systems (GIS)). These do not require mobile network coverage, only a solid GNSS signal, like those provided by Galileo.

For plots of land of more than 4 hectares used for the production of commodities other than cattle, the geolocation must be provided using polygons, meaning latitude and longitude points of six decimal digits to describe the perimeter of each plot of land. For plots of land under 4 hectares, operators can use a polygon or a single point of latitude and longitude of six decimal digits to provide geolocation. Establishments where cattle are kept can be described with a single point of geolocation coordinate.

Please note that the Regulation does not impose direct obligations on producers in third country (unless they are directly placing products on the EU market)

Should all commodities (imported, exported, traded) be traceable?

The traceability requirements apply to each batch of imported/exported/traded relevant commodities.

The Regulation requires that operators trace every relevant commodity back to its plot of land before making a relevant product available or placing it on the EU market, or before exporting it. Consequently, the submission of a due diligence statement which includes geolocation information (or, in the case of a micro or small primary operator, postal address information, provided that the postal address clearly corresponds to the geographic location of the plots of land or establishment concerned) is a requirement for the relevant products to be imported (customs procedure ‘release for free circulation’) to be exported (customs procedure ‘export’) and for transactions within the EU market. Downstream operators and traders ensure traceability by collecting information about their direct business partners (suppliers and commercial clients) and making such information available to Competent Authorities upon demand.

How does it work for bulk-traded or composite products? What about composite products containing different commodities?

For products traded in bulk, such as soy or palm oil for instance, this means that the operator needs to ensure that all plots of land involved in a shipment are identified and that the commodities are not mixed at any step of the process with commodities of unknown origin or from areas deforested or degraded after the cut-off date of 31 December 2020.

For relevant composite products, such as e.g. imported wooden furniture with different wood components, the operator needs to geolocate all the plots of land where the relevant commodity (wood, for example) used for the manufacturing process has been produced. The relevant commodities’ components may be neither of unknown origin nor from areas deforested or degraded after the cut-off date.

In the case of composite products containing multiple different relevant commodities or products (for example, a chocolate bar containing cocoa powder, cocoa butter and palm oil), the operator placing such a product on the EU market or exporting from it will need to conduct due diligence only on the main commodity and (derived) products deemed relevant under the EUDR, this being the commodity contained in the left column of Annex I. For example, for chocolate bars (Code 1806), the relevant commodity linked to it is cocoa. This means that the due diligence obligation and information requirements extend only to relevant products listed in the right column of Annex I under the relevant commodity which the chocolate bar contains or has been made using, which in this case is the cocoa powder and cocoa butter under the commodity cocoa.

Are mass balance chains of custody allowed?

The Regulation requires that the commodities used for all products falling under the scope be traceable to the plot of land. Mass balance chains of custody that allow for the mixing, at any step of the supply chain, of deforestation-free commodities with commodities of unknown origin or non-deforestation-free commodities are not allowed under the Regulation, because they do not guarantee that the commodities placed on the EU market, or exported, are deforestation-free. Therefore, the commodities placed on the EU market, or exported, need to be segregated from commodities of unknown origin or from non-deforestation-free commodities at every step of the supply chain. As mass balance is therefore to be ruled out, full identity preservation is not needed.