From farm geometry to a submission-ready EUDR record
An EUDR connector should do more than collect GPS pins. It must validate every production plot, preserve the link from plot to batch to commercial lot, assemble the Article 9 evidence file, and exchange the right record with the EU Information System for the operator's legal role.
The deadline moved. The origin-data problem did not.
Regulation (EU) 2025/2650 postponed the main application date and simplified who submits. The binding EUDR obligations now apply from 30 December 2026 for large and medium operators and from 30 June 2027 for most micro and small operators. Micro or small operators handling former EU Timber Regulation products remain on the December 2026 date. See the consolidated regulation and 2025 amendment.
| Business role | Binding responsibility | Software implication |
|---|---|---|
| First operator placing or exporting | Conduct due diligence and submit the due diligence statement before placing the product or exporting it | Build the evidence package and Information System submission workflow |
| Micro or small primary operator in scope of Article 4a | Submit a one-time simplified declaration unless equivalent data are supplied through a qualifying public database | Maintain the declaration identifier and a controlled update flow |
| First downstream operator or trader | Keep supplier and customer details and, when supplied directly by the operator, its statement reference or declaration identifier; non-SMEs also register | Match the upstream identifier to receipts and preserve the chain of custody |
| Further downstream actor | Keep required supplier and customer information and respond to non-compliance information | Make the product and party records searchable for the five-year retention period |
Role assignment is transaction-specific. A company can be a downstream trader for one flow and the first EU operator for another. Treat the table as an implementation map, not legal advice; confirm the role logic with qualified counsel.
Article 9 is a data contract, not a map screenshot
Geolocation is one required field group inside a larger due diligence record. The connector must make the whole record reproducible for the exact product and quantity being placed or exported. The Commission's due diligence explanation sets out the complete collection step. A qualifying micro or small primary operator has the narrower Article 4a option to provide a clearly corresponding postal address in place of plot or establishment geolocation.
Product identity
Trade name and type, relevant commodity or product, and the applicable CN/HS code; wood records also need common and full scientific species names.
Quantity
Net mass and, where applicable, the supplementary unit required for the customs classification; otherwise mass, volume or item count as allowed.
Production origin
Country of production and, where relevant, the specific part of that country.
Plots and production
Every production plot, its compliant point or polygon geometry, and the production date or time range.
Supply-chain parties
The names, postal addresses and email addresses of suppliers and downstream recipients required by Article 9.
Deforestation-free evidence
Conclusive and verifiable evidence addressing the 31 December 2020 cut-off and, for wood, forest degradation.
Legality evidence
Evidence that production complied with relevant law in the country of production, including land-use rights where applicable.
Decision record
Risk assessment, mitigation where necessary, approver, statement payload, response, reference number and later corrections.
Reject bad geometry before it becomes compliance evidence
The law defines geolocation as latitude and longitude using at least six decimal digits. For a non-cattle production plot over four hectares, the perimeter must be a polygon. The EU Information System accepts bulk geometry in GeoJSON, but a file being syntactically valid does not make its origin claim true. The postal-address exception for qualifying micro or small primary operators does not extend to other operators.
Point
Permitted for a plot at or below four hectares. Store the coordinate as the plot's origin geometry, not as a facility, village or cooperative centroid.
Polygon
Required when a non-cattle plot exceeds four hectares. Check ring closure, self-intersection, latitude/longitude order, plausible area and containment in the declared country.
Cattle establishments
Record every establishment where the animals were kept, including temporary locations. This is a movement history, not the crop-plot point-versus-polygon rule.
Validation should produce explainable errors
Geometry
Type, coordinate range, precision, topology and plot-area threshold
Geography
Declared country, administrative area and impossible land or ocean positions
Identity
Stable supplier plot ID, duplicate detection and version lineage
Completeness
Production timing, commodity, source party and linked lot coverage
The chain must survive aggregation and splitting
A shipment may combine output from hundreds of plots, while one production batch may be divided across many invoices. The data model must preserve both directions without pretending that ERP lot numbers and farm plots are the same object.
Supplier and production unit
Identify the supplier, producer and stable plot or cattle-establishment records; retain the evidence source and collection method.
Production event
Connect commodity, plot or establishment, harvest or production time range, quantity and country-of-production evidence.
Source batch
Represent the physical batch received from a producer or aggregator, including all contributing production events rather than one convenient coordinate.
Transformation and mass balance
Record splits, combinations, processing yields and waste so quantities remain explainable through manufacturing and storage.
ERP lot and product
Map source batches to purchasing receipts, SAP or ERP lots, product codes, CN codes, sales orders and export or placement events.
Due diligence record
Freeze the plots, evidence, assessment and product quantities used for a specific decision; retain links to later corrections without rewriting history.
Mixing is a data event, not a reason to lose origin
When a product contains relevant commodity from several plots, all plots must be included. If any identified plot has deforestation or forest degradation that disqualifies the commodity, Article 9 does not allow the software to average that risk away. Quarantine affected lots and keep compliant and unknown-origin material physically and digitally separable.
A controlled path from supplier portal to EU reference number
The Commission supports manual entry, GeoJSON upload and a machine-to-machine interface. The production and acceptance environments are separate, and the API specifications can change. Keep EU transport logic outside the traceability core and version it explicitly.
Collect
Give suppliers a controlled upload or API path for geometry, production timing, commodity, legality evidence and stable identifiers.
Validate
Run geometry, country, field-completeness and duplicate checks immediately; return a precise correction request to the source.
Resolve scope and role
Use product classification and transaction context to determine whether EUDR applies and which party must submit or retain a reference.
Assess risk
Combine country benchmarking, supply-chain complexity, source credibility, deforestation evidence and legality evidence; document mitigation where needed.
Approve and freeze
Require an authorised reviewer to approve the exact record version, product quantity and evidence set that will support the transaction.
Submit and reconcile
Send the appropriate statement or declaration, capture the EU response and identifiers, link them back to ERP documents, and handle rejections idempotently.
What the ERP owns
Product and CN classification, purchase receipts, suppliers, physical lots, production transformations, quantities, deliveries, customs events and release blocks.
What the compliance layer owns
Plot versions, evidence provenance, risk decisions, approvals, EU payload versions, submission state, references, audit history and corrective actions.
Controls that prevent a clean API from carrying bad evidence
Country classification changes the depth of due diligence and enforcement intensity; it does not certify a shipment. Use the live Commission classification list as versioned reference data and retain the classification applied to each decision.
Supplier identity
Prevent a supplier from overwriting another producer's plots; require ownership, tenancy or authorised-use evidence where relevant.
Geometry versioning
Never silently replace a submitted boundary. Create a new version with source, timestamp, reviewer and affected lots.
Lot coverage
Block approval when the quantity or any contributing batch lacks a complete route back to production plots or cattle establishments.
Evidence provenance
Store original documents, satellite-analysis inputs, provider, capture time, checksums and the rule version that produced each result.
Risk escalation
Low-risk simplified due diligence must switch to full assessment when contrary information or a substantiated concern appears.
Segregation and release
Quarantine unknown, incomplete or non-compliant material in warehouse and ERP workflows before placement or export.
Submission idempotency
Retries must not create duplicate statements. Correlate each attempt, preserve responses and reconcile uncertain outcomes.
Access and approval
Separate supplier input, analyst review and authorised submission permissions; log every approval and administrative change.
Retention and retrieval
Keep due diligence statements and downstream Article 5 records for at least five years, and make a product, lot, plot or EU reference searchable during a request.
What software can verify — and what it cannot
This boundary matters in procurement. A connector can make evidence consistent, testable and reviewable. It cannot turn a supplier assertion or satellite signal into certainty.
Automate with confidence
- Geometry syntax, precision, topology and area checks
- Required-field and lot-to-plot completeness
- Duplicate, quantity and classification controls
- Evidence versioning, approvals and audit history
- Submission, response and reference reconciliation
Keep human judgement
- Whether source documents are authentic and sufficient
- Whether land-use and production were legally authorised
- Whether remote-sensing ambiguity needs field evidence
- Whether assessed risk is negligible after mitigation
- How substantiated concerns affect product release
Deliver the risky data path first
A useful first release proves one real commodity flow from supplier evidence to ERP release and an acceptance-system submission. Dashboards follow a trustworthy chain, not the other way around.
Scope one transaction
Choose one commodity, CN code, operator role, supplier route and ERP placement or export event; document exceptions before designing screens.
Map source data
Profile supplier geometry, production records, ERP lots, transformations and evidence. Measure missingness instead of assuming an API can fill it.
Define the canonical model
Specify plot and establishment versions, production events, batches, lots, evidence, decisions and external submission identifiers.
Build supplier validation
Implement controlled intake with correction feedback, duplicate detection, geometry tests and an accountable review queue.
Integrate ERP gates
Synchronise lots and quantities, calculate coverage, and block release when compliance evidence is incomplete or rejected.
Prove EU exchange
Use the Commission acceptance environment, exercise success, rejection, timeout, correction and duplicate-retry paths, then document production cutover.
Acceptance criteria for the connector
Complete
Every placed or exported quantity in the pilot can be traced to all contributing plots or cattle establishments and required evidence.
Explainable
Every rejection names the field, rule and corrective action; every risk decision exposes its inputs and approval.
Role-aware
The system chooses statement, simplified declaration, reference collection or information retention from the actual transaction role.
Recoverable
EU API timeouts, duplicates, rejections and corrections are tested without losing or duplicating the compliance decision.
Auditable
A reviewer can retrieve the frozen evidence, geometry version, country-risk version, payload, response and ERP documents for any reference.
Operable
Business owners have queues, permissions, escalation rules, monitoring and a manual contingency path before production launch.
EUDR geolocation API FAQ
What geolocation does EUDR require?
As the general rule for commodities other than cattle, Article 9 requires every plot where the relevant commodity was produced, plus the production date or time range. The legal definition requires latitude and longitude with at least six decimal digits. A plot over four hectares must be represented by a polygon; a point can represent a plot at or below four hectares. Cattle traceability refers to every establishment where the animals were kept. There is a narrow exception: a qualifying micro or small primary operator may replace geolocation with a postal address that clearly identifies every plot or establishment.
Can we submit one coordinate for a shipment assembled from many farms?
No. If a relevant product contains a commodity produced on different plots, Article 9 requires the geolocation of all those plots. The system therefore needs a many-to-many link between plots, production batches and commercial lots. Averaging coordinates, using a cooperative centroid or recording only the warehouse location destroys the required origin trail.
Does low-risk country status remove the geolocation requirement?
Not by itself. For an ordinary operator, low-risk sourcing can allow simplified due diligence, meaning the full Article 10 risk assessment and Article 11 mitigation steps may be omitted when the legal conditions are met, but Article 9 information collection still applies. Separately, the narrower category of qualifying micro or small primary operator may replace geolocation with a clearly corresponding postal address under Article 4a(5). Relevant contrary information or a substantiated concern requires escalation to full due diligence.
Is a satellite deforestation check enough to prove compliance?
No. Earth-observation analysis can support the deforestation-risk assessment, but EUDR also requires traceability, product and quantity data, supplier and customer information, production timing, and adequately conclusive and verifiable evidence of legality in the country of production. A green map result is evidence in a due diligence file, not an EU compliance certificate.
Who must submit a due diligence statement after the 2025 changes?
The revised model places the due diligence and statement obligation on the operator first placing a relevant product on the EU market or exporting it. Downstream operators and traders no longer submit a new statement for every downstream transaction. They keep required supplier and customer information; when their direct supplier is the operator, they also collect that operator's statement reference or declaration identifier. Non-SME downstream actors must also register in the Information System. A qualifying micro or small primary operator generally uses a one-time simplified declaration, unless equivalent public-database data are made available under Article 4a(4).
When does EUDR apply?
The operative obligations apply from 30 December 2026 for large and medium operators and for micro or small operators handling products already covered by the former EU Timber Regulation. Most other micro and small operators receive until 30 June 2027. These dates come from the amended binding regulation, not the older 2024 or 2025 dates still present in superseded guidance and articles.
Can the connector submit directly to the EU Information System?
Yes, for accounts and roles authorised by the Information System. The Commission provides production and acceptance environments and a machine-to-machine interface for bulk management of due diligence statements and simplified declarations. The connector should isolate that external adapter, track the exact Commission specification version, preserve request and response evidence, and support a controlled manual fallback for outages or rejected submissions.
Primary sources and status
Reviewed 2 September 2026. The regulation and implementing regulations listed here are binding EU law. The Commission implementation, due diligence and country-classification pages are official operational guidance and reference data, not substitutes for the legal text. Older guidance can show superseded application dates or pre-amendment downstream workflows. Yarify's data model, controls and delivery sequence are implementation recommendations, not legal advice.
- Consolidated Regulation (EU) 2023/1115 — EUDRBinding legal text as amended through 26 December 2025: scope, deforestation-free rule, geolocation definition, Article 9 information, due diligence and application dates
- Regulation (EU) 2025/2650 — 2025 EUDR amendmentBinding amendment that moved application to the end of 2026, simplified downstream obligations and introduced simplified declarations for qualifying primary operators
- Implementing Regulation (EU) 2024/3084 — EUDR Information SystemBinding rules for registration, submissions, reference numbers, risk profiling, amendments, withdrawals and data access in the EU Information System
- Implementing Regulation (EU) 2026/1565 — Information System updateBinding 2026 update covering simplified declarations, grouping, contingency arrangements and revised Information System operation
- European Commission — Understand EUDR due diligenceOfficial implementation explanation of Article 9 data, the three-step due diligence process, low-risk sourcing and substantiated-concern escalation
- European Commission — EUDR roles and responsibilitiesOfficial current explanation of operator, downstream and trader duties after the December 2025 simplifications, including the revised dates
- European Commission — EUDR Information SystemOfficial production and acceptance environments, GeoJSON bulk upload, statement lifecycle and machine-to-machine API documentation links
- European Commission — EUDR country classification listOfficial current classification of producing countries as low, standard or high risk under the Article 29 benchmarking system
