Under Article 9 of Regulation (EU) 2023/1115, every Due Diligence Statement (DDS) filed under the EU Deforestation Regulation (EUDR) must include the geolocation of all plots of land where the relevant commodity was produced. The technical bar is fixed by Article 2(28), covered below.

The obligation starts on 30 December 2026 for medium and large operators, and on 30 June 2027 for micro and small enterprises. The collection and validation work therefore sits inside 2026.

What counts as ‘compliant geolocation’ under Article 9

Compliant geolocation is a set of coordinates that identifies each production plot precisely enough to compare it against the JRC's 2020 forest cover map. Article 2 of the consolidated EUDR text defines geolocation as latitude and longitude in decimal degrees to at least six decimals. Plots above four hectares that produce commodities other than cattle must be submitted as polygons. Plots at or below four hectares can be submitted as points. For cattle, geolocation refers to all establishments where the animals were kept, and those are submitted as points.

Under Article 2, a plot of land means one continuous area within a single property, uniform enough to assess deforestation risk as one unit. The Commission's FAQ on EUDR implementation confirms this directly: a single polygon cannot cover several plots of land.

Article 9 then requires the DDS to include the geolocation of every plot where the relevant commodity was produced, together with the date or time range of production. The regulation also stipulates the consequences. Any deforestation or forest degradation on the identified plots disqualifies all relevant commodities from those plots from being placed on the EU market or exported. Missing coordinates or a plot that fails the deforestation test does not delay a shipment. It blocks it.

For feed used for livestock, the original OJ text makes clear that geolocation applies to where the cattle were raised, not to the feed itself. Operators sourcing multiple commodities inside one product need to know which coordinate set attaches to which input.

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Where polygon accuracy tends to break in the supply chain

Polygon accuracy tends to break at the plot boundary, where a small drift in coordinates can push the polygon into pixels that the JRC baseline reads as forest in 2020. The JRC EU Observatory on Deforestation and Forest Degradation, live since 8 December 2023, publishes a global forest cover 2020 spatial dataset at 10 meter resolution. That dataset is the reference layer against which submitted polygons are checked. A polygon that leaks beyond the real cultivation boundary can cross into a 10 meter pixel classified as forest at the cut-off date, and the shipment associated with it becomes a compliance problem.

The second failure mode is scope. The Commission's EUDR FAQ is explicit that a single polygon cannot cover several plots of land. Aggregators who submit a cooperative footprint or a concession outline as one polygon are not compliant, even when the geometry is technically well formed. Each production plot needs its own geometry, tied to its own commodity batch and production period.

The third failure mode sits at the DDS level. A DDS that references upstream reference numbers inherits the exposure of the polygons underneath. If an upstream operator's plot data is wrong, the downstream buyer that referenced that DDS carries the risk into its own filing. The Commission's traceability page is clear that products can only be placed on or exported from the EU if they are deforestation-free, legally produced and covered by a DDS. One flawed polygon breaks that chain for everyone above it.

Cattle chains face a distinct issue. Article 2 treats cattle geolocation as the establishments where animals were kept, so operators need to capture every establishment across the animal's life, not just the final farm.

How to collect polygon data at the plot level

Polygon data is collected by capturing coordinates at the boundary of each production plot with a GNSS-enabled device and storing them for upload to the Information System. The EUDR anticipates this by permitting operators to use space data and services delivered under the Union's Space programme, including EGNOS, Galileo and Copernicus. Those signals provide the positioning precision that a compliant polygon depends on.

Two anchors are non-negotiable in the field. First, six decimals of precision for every latitude and longitude value, as required by Article 2 of Regulation (EU) 2023/1115. Second, polygon geometry for every plot above four hectares that produces a commodity other than cattle, with enough vertices to describe the actual perimeter. Point data is only valid for smaller plots and for cattle establishments.

Each polygon then needs to travel with metadata. Article 9 of the regulation ties geolocation to the specific commodity and the date or time range of production. The workflow must record which plot produced which batch and when. Country of production and producer identifier belong on the same record. The Commission's traceability guidance confirms that non-EU producers may be asked to provide the exact locations where products were grown, harvested or raised, which puts the metadata burden on the operator sourcing from them.

Collection methodology itself is part of due diligence. The Commission's official Guidance Document for Regulation (EU) 2023/1115, developed with Member States, treats documentation of how data was captured as part of the operator's due diligence file. A record of the device, the surveyor, the date and the capture method for each polygon protects the operator when authorities ask how a coordinate was produced.

Validating polygons before you file the DDS

Polygon validation before filing runs in three layers: geometric integrity, positional plausibility and post-2020 deforestation risk. Each layer stops a different failure mode from reaching the Information System.

Geometric integrity means the polygon is a closed ring with no self-intersections, no duplicate vertices and a plausible vertex count. The Commission's FAQ addresses whether polygons should be provided by circumference, and reiterates that one polygon cannot cover several plots. Polygons that fail structurally are the easiest problems to fix at source.

Positional plausibility means the polygon sits inside the declared country, on land, and in a zone consistent with the declared commodity. This is the layer where projection and coordinate-order errors surface, and where the six decimal requirement in Article 2 becomes visible in practice.

Deforestation risk is the layer with the sharpest consequences. Every polygon should be checked against the JRC forest cover 2020 dataset at 10 meter resolution for any post-2020 tree cover loss inside the boundary. If the polygon covers any pixel that was forested at the EUDR cut-off, the shipment fails the deforestation-free test in Article 9. The fix is either to show that no deforestation occurred on the identified plot, or to redraw the polygon to reflect the real production area if the geometry was overdrawn.

The Commission's FAQ also confirms that operators must verify geolocation data before filing a DDS, and that a DDS can be amended within a limited window. Amendments are not a substitute for validation. They are a fallback when new information emerges after filing.

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How to get polygon data from suppliers who cannot produce it themselves

The practical route is to run a shared collection programme through the supply chain rather than expect every producer to submit polygons in the correct format. The Commission's FAQ confirms that an operator can use the producer's geolocation data, provided the operator verifies it. Trust plus verification, not delegation.

Non-EU producers have no direct EUDR obligation unless they place products on the EU market. They may still be asked to provide the locations where commodities were grown, harvested or raised, according to the Commission's traceability page. The verification burden therefore sits with the operator filing the DDS. Supplier engagement typically runs in tiers, with high-volume and high-risk origins first because they generate the largest DDS exposure at go-live. Secondary suppliers follow before the 30 June 2027 date that captures micro and small enterprises through the same chain.

Regulation (EU) 2025/2650 opens a small structural door for the smallest producers. Article 6(3) of the amended text, in the consolidated PDF, allows a micro or natural-person upstream operator to mandate the next downstream operator or trader as its authorized representative. That does not remove the geolocation requirement. It clarifies who can file on whose behalf when the smallest suppliers are involved.

Contractually, the useful move is to specify the format and metadata a supplier has to deliver, together with a right to reject shipments whose coordinates fail validation. Every clause has to trace back to the same underlying rule: six decimals, polygons above four hectares, one polygon per plot, commodity and production period attached.

Operators that need broader context on how obligations distribute through the chain can review what the downstream operator category means and the practical enforcement risks in EUDR penalties.

What to lock in before the 30 December 2026 application date

Before medium and large operators enter scope on 30 December 2026, the polygon dataset for every in-scope commodity, origin and production period has to be collected, validated and ready to upload to the Information System. Application dates are set out in Regulation (EU) 2025/2650: 30 December 2026 for medium and large operators and traders, and 30 June 2027 for natural persons and micro or small enterprises established by 31 December 2024. The Commission's Access2Markets update confirms the same calendar.

The Information System itself is functional. According to the Commission's Green Forum page, a PRODUCTION server exists for DDS and simplified declarations with legal value. An ACCEPTANCE server runs as a replica for training, familiarization and testing, and submissions there have no legal value. That test environment is the right place to expose format errors, deforestation alerts and overlapping polygons before a legally binding statement is filed.

Commission Implementing Regulation (EU) 2024/3084 of 4 December 2024 sets the rules for how the Information System works. It provides the legal basis for filing DDS and simplified declarations electronically, and covers data exchange with other systems. The Commission is updating the Information System User Guide to reflect the amended EUDR. Operators integrating through the API published on CIRCABC should track that guide.

Ownership matters as much as data quality. The geolocation dataset touches procurement, sustainability, legal and IT. Placing accountability with one team, usually procurement or sustainability rather than IT, prevents the polygon file from becoming everyone's problem and no one's decision. Teams comparing broader compliance approaches can review EUDR compliance requirements and solutions or the wider question of supply chain due diligence, and check the April 2026 simplification package for context on how the Commission has been adjusting the regime.

The most useful next step

Run a validation pilot on one high-volume commodity, using the polygons suppliers have already provided as the input. The gaps that surface in a single origin are the most reliable signal of what the wider polygon collection programme needs to fix before the EUDR application date.

Frequently asked questions

Do I need a polygon for every plot, or only for large ones?

Polygons are required for every plot above four hectares that produces a commodity other than cattle, under Article 2 of Regulation (EU) 2023/1115. Plots at or below four hectares can be submitted as points. Cattle establishments are always submitted as points.

Can one polygon cover several plots of land?

No. The Commission's EUDR FAQ confirms that a single polygon cannot cover several plots of land. Each plot needs its own geometry, tied to a single commodity batch and production period, so competent authorities can evaluate deforestation risk plot by plot.

When does the geolocation obligation apply?

According to Regulation (EU) 2025/2650, main EUDR obligations apply from 30 December 2026 for medium and large operators and traders, and from 30 June 2027 for natural persons and micro or small enterprises established by 31 December 2024.

Can I rely on the producer's geolocation data?

Operators can use the producer's data but must verify it, according to the Commission's EUDR FAQ. If the polygon is missing, wrong, or captures any post-2020 tree cover loss inside the plot boundary, the operator filing the DDS carries the compliance risk.

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