Which plots need a point, which need a polygon, how cattle establishments are treated, and how the data is checked before it goes into a due diligence statement.
Summary
Article 9 of the EUDR requires the due diligence statement to contain the geolocation of every plot of land where the commodity was produced, given as latitude and longitude with at least six decimal digits. Without this data the product cannot be linked to a place of production and the statement is incomplete.
The form of the data depends on the plot size and on the commodity. A plot of up to four hectares can be given as a single point, a larger plot needs a polygon. Cattle follow a separate rule: the geolocation covers the establishments where the animals were kept, not the grazing land.
After the rules, this page describes the checks we run in the Pixel & Proof platform: one coordinate system (WGS-84, EPSG:4326), six decimals, topological validity of every polygon in PostGIS and a satellite screening. These checks are our practice and the Regulation does not name them.
Plots under 4 ha (point) versus 4 ha and above (polygon)
A plot of up to four hectares can be described by one point placed inside the plot. A larger plot must be described by a polygon with enough points to trace its boundary. The threshold applies to each plot separately: a farm made of several small plots gives a list of points, and one large plot gives one polygon.
Borderline plots cause most rejections. A plot of 3.9 hectares drawn as a polygon is acceptable, but a plot of 4.2 hectares sent as a point is not. Compute the area from the drawn polygon, not from the cadastral register, because the two often differ.
Area also matters for overlap checks. Two plots of different suppliers that overlap on the map point to a data error or to the same land being counted twice, which breaks the link between a product and its plot.
WGS-84 (EPSG:4326) and accuracy to six decimals
The Regulation asks for latitude and longitude with at least six decimal digits. Six decimals correspond to roughly ten centimetres on the ground, so rounding to fewer digits is a defect and not a simplification. We store every coordinate in WGS-84 (EPSG:4326) and refuse other reference systems at import.
Typical errors are swapped latitude and longitude, coordinates in a national grid such as HTRS96/TM or Gauss-Krüger passed off as degrees, and a decimal comma instead of a point. Each of them produces a plot in the wrong country or in the sea.
Need to verify your EUDR compliance?
We check your tariff codes, plot geolocation and batch traceability against the EUDR obligations, and prepare the due diligence statement for you. Send us your product and supplier list and we will tell you where the gaps are.
PostGIS topological check (ST_IsValid)
A polygon can look well formed in a file and still be invalid as geometry: a self-intersecting ring, a ring that does not close, duplicate vertices or a hole outside the shell. In our database every plot must pass ST_IsValid before it is stored, and invalid shapes are returned with the reason so that the supplier can correct them.
Validity does not prove correctness. A valid polygon can still be drawn around the wrong land. For that reason the validation status of a plot is kept apart from its deforestation risk score, and a consultant can record a manual review with a written note.
Sentinel-2 / GEOS-EUDR satellite screening for deforestation
The operator must assess the risk that the plot was deforested after 31 December 2020. The Regulation prescribes no method. Screening with Sentinel-2 imagery is a practical way to compare land cover around the cut-off date and to flag plots for review.
A flag is not a finding. A cleared patch can be a permitted conversion or a forest management activity. A flagged plot goes to review and is not rejected automatically.
The cattle exception (HS 0201)
For cattle and for products made from them, such as HS 0201 bovine meat, the statement gives the geolocation of the establishments where the animals were kept. A farm is therefore recorded by its location and an establishment identifier, not by the polygons of its pastures. Check in the official text which establishments must be listed, for example birth, rearing and fattening sites.
Geolocation rules at a glance
| Article | Rule | Applies to | Date rule |
|---|---|---|---|
| 9, 2 | Latitude and longitude with at least six decimal digits for every plot. | All operators submitting a statement | Same date as the Regulation. |
| 9 | Plots of up to four hectares: one point. Larger plots: polygon with sufficient points. | Commodities other than cattle | Same date as the Regulation. |
| 9(1)(d) | Geolocation of every establishment where the cattle were kept. | Cattle and products made from cattle | Same date as the Regulation. |
| 9 | Each product is tied to the exact plots of production; our platform does not accept mass-balance bookkeeping in its place. | All operators | Same date as the Regulation. |
HS/CN codes and the geolocation unit
| Commodity | HS/CN heading | Geolocation unit | Rule |
|---|---|---|---|
| Wood | HS 44 | Plot | Point up to 4 ha, polygon above 4 ha |
| Paper and paperboard | HS 48, including 4819 | Plot of the fibre source | Point up to 4 ha, polygon above 4 ha |
| Coffee | HS 0901 | Plot | Point up to 4 ha, polygon above 4 ha |
| Cocoa | HS 1801 | Plot | Point up to 4 ha, polygon above 4 ha |
| Natural rubber | HS 4001 | Plot | Point up to 4 ha, polygon above 4 ha |
| Bovine meat | HS 0201 | Establishment | Location and identifier of the establishment; the polygon rule does not apply |
Exemptions and simplifications
The geolocation duty has few exemptions. One simplification is reported for the smallest primary operators.
- Micro or small primary operators submit a one-time simplified declaration, and under Article 4a(5) the geolocation may be replaced by the postal address of all plots or of the establishment of production.
Frequently asked questions
When is a point enough and when do I need a polygon?
For plots of up to four hectares a single point with at least six decimals is accepted; larger plots need a polygon. Cattle are the exception: the establishments are geolocated instead.
How is cattle geolocated under the EUDR?
The statement gives the geolocation of all establishments where the animals were kept, not grazing polygons (Article 9(1)(d)).
Book a 15-minute EUDR audit
We look at your product list, tariff codes and plot data and tell you where the gaps are. Write to us through the contact page; a booking slot is offered here when it is available.
Sources
- Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on deforestation-free products (EUDR), OJ L 150, 9.6.2023. Read in the Official Journal text on 10 November 2026.
- Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115 (application dates, downstream operators, simplified declaration, scope). Read in the Official Journal text on 10 November 2026.
Facts last checked against the Official Journal text on 10 November 2026.
This page is general information, not legal advice. It reflects the Official Journal text of Regulation (EU) 2023/1115 as amended and Commission guidance as read on 10 November 2026; items marked as expected are not confirmed. Obligations depend on your role, product and Member State. Check the current official text on EUR-Lex.