EUDR Geolocation for Forestry and Cattle: What to Record Before 30 December 2026

From 30 December 2026, wood and cattle placed on the EU market must be traceable to the exact plot of land where they were produced. The EU Deforestation Regulation (EUDR) requires geolocation coordinates for every plot, collected before the product is sold. For forest owners, logging contractors and sawmills, including small ones, that date has not moved.

What is the EUDR?

The EUDR, Regulation (EU) 2023/1115, prohibits placing on the EU market, or exporting, products made from seven commodities unless they are deforestation-free, legally produced and covered by due diligence. The commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood. Deforestation-free means produced on land that was not deforested after 31 December 2020.

Two amending regulations, (EU) 2024/3234 and (EU) 2025/2650, postponed the start date and simplified the text. The 2025 amendment removed due diligence statements for downstream operators and created a one-off declaration for the smallest producers. In May 2026, the Commission’s review (COM(2026) 191) concluded that no further change to the basic text was appropriate.

A delegated regulation published on 17 September 2026, (EU) 2026/2102, then adjusted the product list. Cattle hides, skins and leather are out of scope, and a handful of products are added from 30 December 2027.

When does the EUDR apply to wood and cattle?

• 30 December 2026: large and medium operators and traders, for every product in scope.
• 30 December 2026: micro and small operators too, for wood products already covered by the EU Timber Regulation: logs, sawn wood, firewood and chips, panels and plywood, pulp and paper, wooden furniture.
• 30 June 2027: micro and small operators established by 31 December 2024, for products outside the old Timber Regulation, including live cattle and beef.
• 30 December 2027: products newly added by Delegated Regulation (EU) 2026/2102.

The second line is the one most summaries miss. Article 38(3) grants the June 2027 date “except as regards the products covered by the Annex to Regulation (EU) No 995/2010”, which is the EU Timber Regulation. A small sawmill or firewood business already doing timber due diligence keeps the 30 December 2026 date. The EUDR replaces the Timber Regulation, which is repealed from that same day. Check the Timber Regulation annex against your own HS codes.

Who is the operator in a timber or cattle supply chain?

The operator is the person or company that first places a product on the EU market, or exports it. Everyone after that is a downstream operator or a trader. In a domestic timber chain, the operator can be the forest owner selling harvested wood, the logging contractor or the sawmill, depending on who first places the wood on the market. The Commission’s EUDR FAQ works through specific cases.

Since the 2025 amendment, downstream operators and traders no longer submit due diligence statements. They must still keep the name, postal address, email and web address of their suppliers and customers, plus the reference numbers received from operators, for at least five years (Article 5).

What does geolocation mean under the EUDR?

Article 2(28) defines geolocation as the latitude and longitude of a plot of land, with at least one point and at least six decimal digits. Six decimals is a precision of about ten centimeters, so a location read off a paper map or typed from memory will not do.

• Plots of 4 hectares or less: a single point is enough.
• Plots of more than 4 hectares: a polygon with enough points to describe the perimeter, for every commodity except cattle.
• Cattle: single points for every establishment where the animals were kept. No polygons.

A “plot of land” is land within a single real-estate property, as recognized by the law of the country of production, with conditions homogeneous enough to assess deforestation risk as a whole (Article 2(27)).

In the EU Information System, GeoJSON is the only file format accepted for upload, in WGS-84 (EPSG:4326), with longitude before latitude. Polygons must be closed, have at least four coordinate pairs and must not cross themselves. Uploads count toward a 25 MB limit per statement. Coordinates can also be typed in by hand or drawn on a map inside the system.

Small producers: the one-off simplified declaration

The 2025 amendment added Article 4a for micro and small primary operators. These are natural persons or micro or small undertakings, established in a low-risk country, who place on the market products they grew, harvested or raised themselves on their own plots or establishments in that country. France and Spain are both classed as low risk (Implementing Regulation (EU) 2025/1093).

Instead of a due diligence statement for each shipment, they submit a one-time simplified declaration and receive a declaration identifier. It contains their name and address, the HS code and an estimated annual quantity, the country of production, and the geolocation of all plots or establishments. Article 4a(5) allows the geolocation to be replaced by the postal address of the plots, as long as it clearly corresponds to where they are. The Commission FAQ also accepts cadastral references. An administrative head-office address does not count.

Three caveats. The declaration replaces the statement, not the duty: the information in Article 9 must still be collected and kept. If that information already sits in a national database, no declaration is needed at all (Article 4a(4)), so ask your competent authority whether one applies. And a cooperative marketing its members’ wood or cattle does not qualify on their behalf, though it can act as their authorized representative.

What must be recorded for every batch?

Article 9(1) lists what operators must collect and keep for five years from placing on the market or export:

• Product description and trade name; for wood, the common and scientific name of the species
• Quantity, in net mass and, where applicable, a supplementary unit
• Country of production and, where relevant, the region
• Geolocation of all plots of land, plus the date or time range of production
• Name, postal address and email of the supplier and of the customer
• Conclusive, verifiable information that the product is deforestation-free
• Evidence that production complied with the laws of the country of production

In a low-risk country such as France or Spain, simplified due diligence (Article 13) removes the risk assessment and mitigation steps. It does not remove geolocation. The Commission FAQ states: “There is no exception for the traceability requirement via geolocation.” Operators must still check for a risk of circumvention, or of mixing with products of unknown origin.

How to capture plot geolocation in the field

The Commission FAQ notes that coordinates can be collected with mobile phones or handheld GNSS receivers, which “do not require mobile network coverage, only a solid GNSS signal”. That matters in forests and upland pastures, where there is often no signal to send data but the satellites are still overhead. Under dense canopy, accuracy drops: take the reading from a clearing, track or landing where you can, and note where it was taken.

1. Give every plot a stable ID that matches your cadastral or forest-management reference.
2. Record the coordinates on site with six decimals, and for plots over 4 hectares, the perimeter points you need to draw the polygon.
3. Attach the evidence at the same time: photos of the stand or pasture, date, operator, and the harvest or animal movement it relates to.
4. Link plots to lots. Each load, stack or batch of animals should carry the IDs of the plots it came from, so traceability holds when products are mixed.
5. Build and check the GeoJSON before submission: longitude first, closed polygons, and a quick look on a map.
6. Keep everything for five years, with its history: who recorded what, when and where.

FormRift covers steps 2 to 4 where there is no network. Your teams record each plot visit on mobile, with GPS coordinates, photos, timestamp and signature, even with no coverage, and the data syncs when the network returns. Every entry feeds a complete audit trail, and records export to CSV for your mapping tool. FormRift does not file declarations in the EU Information System: it keeps the field evidence those declarations rely on. See the features and how it applies to agriculture and forestry teams.

What are the penalties?

Member States set the penalties, within the limits of Article 25. For legal persons, the maximum fine must be at least 4% of total annual EU-wide turnover. Authorities can also confiscate the products and the revenue made from them, exclude the company from public procurement and public funding for up to 12 months, and, for serious or repeated breaches, temporarily ban it from placing products on the market.

In France, the competent authority is a joint one: the ministries in charge of ecological transition and of agriculture. In Spain, it is MITECO, alongside the authority each autonomous community has designated.

Checklist before 30 December 2026

1. Confirm your date. Wood in the old Timber Regulation scope: 30 December 2026, whatever your size.
2. Establish your role: operator, downstream operator or trader.
3. If you are a micro or small primary operator, prepare the one-off simplified declaration, with postal addresses or cadastral references for your plots.
4. Map your plots with IDs and six-decimal coordinates, and polygons above 4 hectares.
5. Set up field capture that links each plot to the lots it supplies.
6. Register in the EU Information System if you are an operator, or a downstream operator or trader that is not an SME.
7. Plan five-year retention that keeps the original timestamp and location of every record.

Frequently asked questions

When does the EUDR apply?

The EUDR applies from 30 December 2026 to large and medium operators and traders. Micro and small operators established by 31 December 2024 have until 30 June 2027, except for wood products already covered by the EU Timber Regulation, where 30 December 2026 applies to all sizes. Products added in 2026 follow from 30 December 2027.

Do small forest owners and sawmills get until June 2027?

Not for most wood. Article 38(3) excludes products covered by the old EU Timber Regulation from the June 2027 date: logs, sawn wood, firewood, panels, pulp, paper and wooden furniture. A small forest owner or sawmill placing those products on the market must comply from 30 December 2026, though it may use the one-off simplified declaration.

Is a postal address enough instead of GPS coordinates?

Only for micro and small primary operators filing the one-off simplified declaration under Article 4a. They may give the postal address of their plots or establishment if it clearly corresponds to the location, and the Commission FAQ also accepts cadastral references. Everyone else must provide coordinates with at least six decimals, and polygons for plots over four hectares.

Does low-risk status for France and Spain remove geolocation?

No. France and Spain are classed as low risk, which allows simplified due diligence under Article 13, with no risk assessment or mitigation. Geolocation stays: the Commission FAQ is explicit that there is no exception for the traceability requirement via geolocation. Operators must also still check for a risk of circumvention or mixing with products of unknown origin.

What file format does the EU Information System accept?

GeoJSON is the only file format accepted for upload, using WGS-84 coordinates (EPSG:4326) with longitude before latitude. Polygons must be closed and contain at least four coordinate pairs. Uploaded files count toward a 25 MB limit per statement. Coordinates can also be typed in by hand or drawn as a plot on a map in the system.

Is leather still covered by the EUDR?

No. Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, removed cattle hides, skins and leather from the EUDR annex. Live cattle, beef, offal and prepared meat remain in scope. The same act limits live cattle to the genus Bos and adds frozen cattle tongues from 30 December 2027.

Can plot coordinates be collected offline?

Yes. Satellite positioning does not need mobile coverage: the Commission FAQ notes that phones and handheld GNSS receivers need only a solid GNSS signal. What needs care is the rest of the record, meaning the photos, timestamp, plot ID and lot, which should be captured together on site and synced later rather than retyped from notes.

How long must EUDR records be kept?

At least five years. Operators keep the Article 9 information and their due diligence documentation for five years from placing on the market or export. Downstream operators and traders keep supplier and customer records for the same period under Article 5(4). Plan storage that preserves the original timestamp and location of each record, not only a summary.

The bottom line

The EUDR asks one question of every load of wood and every animal: where exactly did it come from? From 30 December 2026, the answer has to be a coordinate, recorded before the sale and kept for five years. Capture it where the work happens, attach the evidence, and link it to the lot. If you also keep plant-protection records, the same logic applies to the EU 2027 digital pesticide record.

Inspections, audits and reports then rest on records that hold up, built on simplicity, an audit trail and security.