The EU Deforestation Regulation (Regulation (EU) 2023/1115, commonly referred to as EUDR) came into force in June 2023, with an original compliance deadline for large operators that has since been extended. The core obligation it creates is straightforward to state and difficult to meet: operators placing in-scope commodities on the EU market must exercise due diligence to ensure those products were not produced on land that was deforested after December 31, 2020.
The commodities in scope are cattle, cocoa, coffee, palm oil, soya, wood, rubber, and products derived from these — including leather, chocolate, furniture, and printed paper. The geographic scope is global: if a soy shipment originating in Brazil was grown on land cleared after the cutoff date, it cannot legally enter the EU market under a compliant due diligence statement.
The mechanism that makes this regulation distinct from prior corporate sustainability commitments is the geolocation requirement. Operators must collect and maintain geolocation data for the plots of land where each commodity was produced. This is not optional, and it's not satisfied by country-of-origin certificates or trader-level attestations. The regulation requires plot-level coordinates.
What Due Diligence Actually Requires
Article 8 of EUDR describes the due diligence system that operators must establish. The three components are: information collection, risk assessment, and risk mitigation. The information collection requirement includes:
- Geolocation of the plots of land where the commodity was produced, with polygons for plots larger than 4 hectares and coordinates (with ±10 meter precision specified in implementing guidance) for smaller plots
- Date or time range of production
- Sufficient quantity and quality information to confirm that no deforestation or forest degradation has occurred on the production plot after December 31, 2020
The regulation does not specify which remote sensing methodology must be used to verify the no-deforestation claim. It requires that operators collect sufficient evidence — which means the burden is on the operator to demonstrate, with documentation that can withstand competent authority inspection, that the parcels in their supply chain were not deforested after the cutoff date.
Satellite change detection evidence is widely understood by practitioners to be the most scalable and auditable method for meeting this evidentiary standard. A timestamped analysis showing that the specific parcel polygon was covered by intact forest on December 31, 2020, and remained covered through the date of the due diligence statement, is the kind of documentation that makes an auditor's work tractable.
The December 31, 2020 Baseline Problem
The cutoff date creates a specific technical challenge: operators need to establish the forest status of their supply chain parcels as of a date that is now several years in the past. This is not a prospective monitoring problem — it requires historical archive analysis.
The Sentinel-2 archive, which begins in late 2015, provides coverage back well before the cutoff date. For most tropical regions, it's possible to construct a forest/non-forest classification of specific parcels as of December 31, 2020, from the Sentinel-2 archive — provided cloud-free or cloud-corrected imagery exists at sufficient temporal density around that date.
The main complication is cloud cover. In equatorial regions, a single scene from exactly December 31, 2020 may not exist. The evidentiary approach we use is to build a cloud-free composite from Sentinel-2 scenes within ±60 days of the cutoff date, apply change detection relative to earlier baseline periods to confirm forest persistence, and document the full methodology and imagery provenance in the deliverable. This approach is consistent with the EUDR's implementing regulation guidance on acceptable evidence, which acknowledges the need to use best-available data within a reasonable temporal window.
For regions where optical cloud cover makes the 2020 period difficult to assess from Sentinel-2 alone, Sentinel-1 SAR is a useful complement — as discussed in our earlier wetland SAR-optical fusion piece, C-band SAR provides some forest/non-forest discrimination capability even under cloud, particularly for detecting the double-bounce absence that characterizes cleared land versus standing forest.
Country Risk Classification and the Proportionality Principle
EUDR introduces a country benchmarking system under which supplying countries will be classified as low, standard, or high risk based on deforestation rates and governance quality. The classification has implications for the depth of due diligence required: for low-risk country classifications, operators can rely on simplified due diligence with less extensive documentation. For standard and high-risk countries, full due diligence including geolocation and change detection evidence is expected.
As of mid-2026, the country benchmarking system is still being finalized by the European Commission. The absence of the country list creates uncertainty for operators: they need to build the infrastructure for full due diligence regardless, because they can't yet rely on simplified procedures even where they might eventually qualify. The pragmatic approach is to build parcel-level geolocation and change detection capability now, which satisfies both the current uncertain environment and any future standard-risk designation.
We're not saying that every commodity sourcing relationship requires real-time monitoring at 48-hour cadence for EUDR purposes. The regulation is about whether deforestation happened after the cutoff date — it's not a continuous environmental monitoring obligation (though it does require operators to update their due diligence regularly when new information becomes available). The technical requirement is historical baseline verification plus periodic update, not operational alert monitoring. Those are different services, and conflating them leads to either over-engineering the compliance infrastructure or under-reading the ongoing monitoring requirement.
What "Negligible Risk" Means in Practice
For operators in standard-risk country supply chains, EUDR's due diligence conclusion must establish "negligible risk" of deforestation non-compliance — meaning the operator has gathered and assessed information, found no indications of non-compliance, and documents that assessment. This isn't a guarantee of zero deforestation across the entire source country; it's a documented, good-faith, evidence-based conclusion about the specific parcels in scope.
For a coffee roaster sourcing from smallholder cooperatives in Ethiopia or Honduras, "negligible risk" requires polygon-level geolocation of member farms, a historical forest cover analysis for each polygon against the 2020 baseline, and documentation of that analysis in the due diligence statement. The size of the cooperatives — often hundreds of smallholders each cultivating 1-2 hectares — means the polygon collection task is substantial, but there's no regulatory exemption for complexity of the supply chain.
This is where the combination of geolocation technology (mobile data collection from cooperative field agents), satellite change detection analysis on those polygons, and documented due diligence statements creates an end-to-end compliance workflow. The satellite analysis step is only as good as the polygon data feeding it. A due diligence system that has accurate polygons and change-detection methodology is demonstrably more robust than one relying on trader attestations — which is ultimately what competent authorities assessing compliance will be evaluating.
What Happens at the Border
EUDR creates obligations both for EU-established operators (who bear the primary due diligence responsibility) and for traders — who have lighter obligations if their supplier has already completed full due diligence, but bear full operator-level obligations if their supplier has not. At EU borders, customs authorities and competent national authorities will assess due diligence statements against a risk-based inspection protocol. Shipments flagged for inspection must be accompanied by documentation substantiating the due diligence claim.
For high-risk shipments, that documentation may include the underlying geolocation data and change detection evidence — not just the summary due diligence statement. Operators whose compliance approach relies on trader-level attestations with no supporting parcel data are exposed at the inspection stage. An auditor who asks "show me the polygon coordinates for these soy fields and the imagery confirming no clearing since 2020" cannot be satisfied with a certificate of origin.
Building the evidentiary layer — parcel polygons, dated satellite analysis, documented methodology — is the actual compliance work. The due diligence statement is the output of that work, not a substitute for it. The operators who are in the strongest position when inspections begin are those who treated the regulation as an evidence management problem, not a paperwork problem.
Getting the geolocation data right, and building the satellite analysis infrastructure to assess it at scale, is where the compliance work lives. Everything else follows from that.