What geolocation means under the EUDR
Article 2(28) of Regulation (EU) 2023/1115 defines "geolocation" as the geographical location of a plot of land described by coordinates using latitude and longitude with sufficient accuracy to identify the individual parcel or area. Article 9(1)(d) requires operators to collect this geolocation for all plots of land where the relevant commodities were produced.
The practical implication is that you need spatial data for the actual production land, not simply the country of origin or a region name. For a commodity like cocoa sourced from Côte d'Ivoire, you need GPS coordinates or polygon boundary data for each farm that contributed to the shipment. For palm oil from Malaysia, you need plot-level data for every plantation in the supply chain. For coffee from Colombia, every farm that supplied beans for a lot you are placing on the EU market.
Polygon versus point data
The regulation accepts two geolocation formats. A polygon is a defined boundary of the land area, typically provided as a series of GPS coordinates that trace the perimeter of the plot. A point is a single GPS coordinate representing a location within the plot. Both are compliant with the regulation's minimum requirements.
The Commission's guidance documents express a preference for polygon data, because a polygon can be cross-referenced against satellite deforestation monitoring data with greater precision than a point coordinate. A point placed in the center of a 50-hectare farm says nothing about whether the plot boundary extends into a forest area. A polygon covering the same farm can be overlaid directly on land cover maps and forest monitoring data to confirm that the land was not forest after 31 December 2020.
For operators building a compliance system for the long term, investing in polygon data collection from suppliers is the more robust position. Point coordinates are acceptable where polygon data cannot be obtained, but they increase the uncertainty in the risk assessment step.
Aggregated supply chains
Many commodity supply chains involve aggregation: a processor or trader in the producing country collects from hundreds of smallholder farmers and sells a consolidated lot to the EU operator. In these cases, the geolocation requirement applies to every individual farm in the aggregated lot, not just the aggregator's premises.
This is the single most challenging aspect of EUDR traceability for many supply chains. A cocoa trader in Côte d'Ivoire sourcing from 500 smallholder farmers must have GPS data for each farm and must be able to link each farm's contribution to the specific lot being exported. This requires data systems and field-level collection capacity in the producing country that many supply chains did not have before the EUDR.
Under the regulation's due-diligence framework, operators can rely on due diligence carried out by their direct supplier, provided the supplier is also subject to EUDR obligations and the operator has verified the quality of the supplier's due diligence. This means operators sourcing from large processors or traders in producing countries can potentially use that counterpart's geolocation dataset, rather than collecting data independently, if the supplier can demonstrate robust data quality.
Special considerations for wood products
For timber and wood-derived products, geolocation refers to the harvesting area rather than agricultural plots. The regulation requires coordinates for the concessions, forests, or land areas where the timber was harvested. For plantation timber, this is similar to the agricultural plot requirement. For natural forest harvesting, the harvesting area is the concession boundary.
Wood supply chains are often multi-tier: logging concession, sawmill, secondary processor, furniture manufacturer, and then the EU importer. Each step can transform the product. The relevant geolocation is always the original harvesting location, not the processing facility. Operators importing furniture, paper, or other processed wood products must trace back to the forest or plantation, not just the last supplier in the chain.
When suppliers cannot or will not provide data
If a supplier cannot provide geolocation data, the operator cannot complete the information collection step of due diligence. Without completing information collection, no risk assessment can be conducted, and no DDS can be submitted. The result is that the goods cannot be placed on the EU market.
This creates leverage that many EU importers have used in supplier negotiations. EUDR compliance is now a precondition for selling to the EU market. Suppliers who cannot provide geolocation data lose access to EU customers. In practice, this has driven investment in data collection capacity in producing countries, particularly in West Africa for cocoa and in Southeast Asia for palm oil and rubber.
For operators who are transitioning suppliers or managing a temporary data gap, the options are limited: the goods cannot be placed on the EU market until the data is available. There is no grace period or "partial compliance" path once the regulation is in force. For context on how the country risk system affects the intensity of data requirements, see our article on EUDR country risk classifications. For the full compliance overview, see our guide on EUDR compliance for EU importers.