EUDR geolocation and due diligence statements: what the paperwork actually asks for

The cut-off date and what counts as deforestation

The reference date is 31 December 2020: land used to produce a covered commodity must not have been deforested, or the forest degraded, after that date. 'Forest' has a specific technical definition (land over 0.5 hectares, trees taller than 5 metres, canopy cover over 10%), and deforestation means converting that forest to agricultural use. Land cleared before the cut-off date is not a problem under EUDR, however recently it was cleared, since the regulation is not retroactive beyond that point.

Geolocation: points vs polygons, and the cattle exception

Geolocation coordinates need at least six decimal digits of precision. For plots over 4 hectares, you need the full polygon boundary, not just a centre point, for every commodity except one: cattle. For cattle specifically, the requirement is geolocation of the establishments where the animals were kept, and a single point is sufficient regardless of the area involved, because tracking grazing-land polygons for livestock doesn't map the same way it does for a fixed plantation plot.

This distinction matters operationally: a coffee or cocoa smallholding just over 4 hectares needs boundary mapping, which is a meaningfully bigger data-collection task than a single GPS pin, while a cattle operation of any size does not.

A real simplification: only the first operator usually files now

A December 2025 amendment changed who actually submits a DDS, and it's a genuine simplification worth knowing about if your last EUDR briefing predates it. Previously, due diligence obligations cascaded down the chain. Now, only the first operator placing the product on the EU market, or exporting it, files the due diligence statement itself. Downstream operators and traders no longer file their own DDS or re-verify the upstream diligence; they register in the EU's Information System and simply hold the reference number that was already generated further up the chain.

If you sell through an EU-based distributor rather than placing goods on the market yourself, this changes what that distributor actually needs from you: a valid upstream reference number they can point to, not a fresh due-diligence exercise on their end. It's worth confirming explicitly with your buyer which role they consider themselves to hold in the chain, since the paperwork flow depends on it.

An extra simplification, gated on country risk

Micro and small primary producers get a further simplification, but only if their country is classified low-risk under the EU's country benchmarking list: a one-time simplified declaration instead of a full DDS, and a postal address or cadastral reference can substitute for precise geolocation coordinates.

This gate is sharper than it first appears for Latin American producers specifically. Costa Rica, Chile and Uruguay are classified low-risk and qualify. Brazil, Colombia, Peru, Ecuador, Honduras, Mexico, Argentina and Paraguay are classified standard-risk, and a micro or small producer in any of those countries does not get this simplified route, regardless of how small the operation is. Country classification, not operator size alone, decides who gets the lighter-touch option.

Risk assessment, mitigation, and what low-risk actually exempts

Being in a low-risk country exempts you from two specific obligations, risk assessment and risk mitigation, but geolocation and the due diligence statement itself still apply in full regardless of risk classification. Being low-risk makes the paperwork lighter, it does not make it disappear.

Records have to be kept for five years across the chain: the geolocation data, the risk assessment where one was required, and the DDS itself.

Getting the underlying data ready

The exporters for whom this is cheapest already know exactly which plot, farm or herd each shipment came from, because that link is the geolocation record a DDS asks for. If that link lives in a paper docket or a grower's memory, the gap shows up the first time a shipment needs geolocation data attached on short notice.

This guide summarises the mechanics for orientation and is not legal advice. Country risk classifications, the Information System's technical requirements, and simplification rules for smaller operators can all change; confirm your product's current status against the European Commission's EUDR pages before relying on any of this for a live shipment.