Geolocation and traceability for EUDR: Getting supplier data right

Why traceability has become a regulatory requirement 

Supply-chain transparency has long been recognised as an important part of responsible sourcing. Even so, many organisations have traditionally leant on supplier declarations, certifications or contractual commitments without maintaining detailed visibility into where their raw materials actually came from. 

The EUDR changes that. Rather than relying on supplier assurances alone, organisations are expected to demonstrate that commodities covered by the regulation come from land that has not been deforested or degraded after 31 December 2020, the regulation's fixed cut-off date. It does not matter whether the land clearance was legal under local law at the time. If it happened after that date, the product is out of scope for compliant sourcing. 

Meeting that standard means tracing commodities right back to their place of production and holding onto evidence of that origin for any product placed on, or exported from, the EU market. For many FMCG and retail companies, this is one of the most operationally demanding parts of EUDR compliance, and one worth getting ahead of well before the current deadlines of 30 December 2026 for large and medium operators, and 30 June 2027 for micro and small enterprises. 

Understanding geolocation under the EUDR 

Geolocation is one of the defining, and most technically specific, requirements of the EUDR. It refers to the precise geographic location where a relevant commodity was produced, and the regulation sets out exactly how precise that needs to be. 

For plots of land up to 4 hectares, a single point coordinate is sufficient. For anything larger than 4 hectares, the regulation requires a full polygon, a closed shape defined by a series of latitude and longitude points, rather than a single point. Either way, coordinates need to be recorded in decimal degrees to at least six decimal places, precise enough to identify a specific plot rather than a general area. 

This geolocation data is then checked against a forest-cover baseline for the year 2020, maintained by the European Commission's Joint Research Centre, to establish whether the land in question has been deforested or degraded since the cut-off date. Depending on the production system, the specific information required might include: 

This is a considerably higher bar than a country-of-origin declaration. Rather than a general regional risk judgement, geolocation lets organisations and regulators assess environmental risk at the level of an individual plot. For commodities sourced from many farms or production sites, which is common for cocoa, coffee and palm oil in particular, collecting accurate geolocation data at this level of precision becomes considerably more complex the further you get from a handful of large estates. 

Why traceability extends beyond Tier 1 suppliers 

Most organisations have reasonably strong visibility over their direct suppliers. The trouble is that commodities usually pass through several intermediaries before they ever reach a manufacturer or retailer. 

A chocolate manufacturer, for instance, might buy cocoa from a processor, who sources beans from exporters, who in turn aggregate production from multiple cooperatives and individual farms. Timber, coffee, palm oil and rubber often move through a similarly long chain of processing stages before they end up in a finished consumer product. 

Under the EUDR, organisations need visibility further upstream than most supplier management programmes have historically reached, right back to the original production location. That means moving beyond traditional supplier management towards genuine transparency across multiple tiers of the supply chain, not just the tier you buy from directly. 

Building effective supply-chain traceability 

Traceability is the ability to track products and commodities through the supply chain, from point of origin to finished product. A traceability system that actually works should let an organisation understand where commodities originated, which suppliers handled the materials, how products moved through the chain, and whether the sourcing information stays consistent across each stage of production. 

Getting to this level of visibility usually means improving both governance and data management at the same time, not just adding a new data collection step onto an existing process. Traceability is increasingly becoming a genuine business capability in its own right, rather than something that exists purely to satisfy a regulator. 

Collecting supplier data 

Supplier engagement sits at the centre of EUDR compliance. Organisations are increasingly asking suppliers for detailed information covering: 

The quality of this supplier data directly shapes how meaningful your due diligence, and how compliant your documentation, can actually be. Many businesses are reviewing supplier onboarding, contractual requirements and information-sharing arrangements specifically to improve data availability, rather than trying to bolt geolocation requests onto an unchanged process. 

Worth checking early: where your sourcing is concentrated in countries classified as low risk under the EU's country risk benchmarking system, a simplified due diligence route is available, and the depth of supplier data collection required can be considerably lighter than for standard or high-risk sourcing. It is worth confirming the risk classification of your sourcing countries before assuming the full data collection burden applies everywhere. 

Validating supplier information 

Collecting supplier data is only half the job. Organisations also need a process for checking whether the information they have received is complete, accurate and reliable. Validation activities commonly include: 

One resource worth knowing about here is the EU Forest Observatory, a public tool run by the European Commission's Joint Research Centre. It has been live since December 2023 and provides global forest change maps built on the same 2020 forest-cover baseline used to assess EUDR compliance, giving organisations (and regulators) a consistent reference point for checking whether a given plot has seen forest loss since the cut-off date. 

How much validation is genuinely needed tends to vary with commodity risk, sourcing region and supplier maturity, so it is worth calibrating the depth of validation to the actual risk profile of each part of your supply chain rather than applying one standard everywhere. 

The role of technology in traceability 

Many organisations are turning to digital tools to support EUDR implementation. Technology can help with supply-chain mapping, supplier data collection, geospatial analysis, document management, risk screening, satellite monitoring, workflow management and data integration. 

Technology does not replace supplier engagement, but it does let organisations manage far larger volumes of information more efficiently, while improving consistency and making the whole process considerably easier to audit. For organisations with extensive global sourcing networks, digital traceability systems are becoming an increasingly important part of maintaining compliance over time, rather than a nice-to-have. 

Common challenges in supplier data collection 

The EUDR sets out clear expectations, but organisations still run into a handful of recurring practical challenges. 

Fragmented supply chains. Many commodities come from thousands of individual producers, which makes data collection genuinely resource-intensive. Smallholder farming systems in particular often involve several intermediaries before commodities reach a processor or exporter, and keeping visibility across networks like this is difficult by nature, not just by neglect. 

Data quality. Supplier information can be incomplete, inconsistent, outdated, recorded in different formats, or simply hard to verify. Standardised data collection templates and validation procedures make a real difference to consistency here. 

Supplier capability. Not every supplier currently has the systems or expertise to provide detailed geolocation information. Some will need training, technical support, better record-keeping processes, new technology, or simply time and ongoing collaboration to get there. Building supplier capability is becoming a genuine part of EUDR readiness, not a side issue. 

Integrating multiple data sources. Many organisations already manage supplier information across separate procurement, quality, sustainability and compliance systems. Folding geolocation data into these existing systems can create real operational complexity where information sits in disconnected databases, which makes data governance and interoperability an important priority in its own right. 

Integrating traceability into due diligence 

Traceability works best when it is not treated as an isolated compliance activity. Organisations increasingly fold supplier information into broader due diligence processes covering risk assessment, supplier monitoring, procurement decisions, environmental reporting, supply-chain governance and regulatory compliance more widely.