EUDR evidence, and what satellite data can actually prove

What the Regulation requires

Article 3 permits a relevant product to be placed on, made available on, or exported from the EU market only when all three of these hold at once:

• It is deforestation-free.
• It was produced in accordance with the relevant legislation of the country of production.
• It is covered by a due diligence statement, or by the simplified declaration available to a qualifying micro or small primary operator.

For an ordinary upstream operator, due diligence has three parts: collect the Article 9 information, assess risk under Article 10, and mitigate any non-negligible risk under Article 11. The operator may proceed only once its assessment establishes no or negligible risk. Sourcing entirely from a low-risk country can remove the routine Article 10 and 11 steps, but the operator still has to collect the Article 9 information, assess supply-chain complexity and mixing or circumvention risk, and return to full due diligence if relevant risk information appears.

Records have to be kept for five years and made available to a competent authority on request.

On dates. ATI’s September 2026 review of the consolidated text records 30 December 2026 for large and medium enterprises and for micro and small enterprises already covered by the EU Timber Regulation, and 30 June 2027 for most other micro and small enterprises. This timeline has been amended more than once. Treat those dates as a pointer and confirm them at source.

What you have to collect

Article 9 requires evidence relating to each relevant product, including:

• Product description, relevant commodity, and applicable CN/HS code.
• Quantity.
• Country of production and, where relevant, the part of the country.
• The geolocation of all production plots, and the production date or time range.
• Supplier and customer identity and contact details.
• Adequately conclusive and verifiable information that the product is deforestation-free.
• Adequately conclusive and verifiable information that the commodity was produced legally, including the right to use the production area where relevant.

The due diligence statement is the operator’s structured declaration in the EU Information System. A satellite report does not replace it. The sound arrangement is to retain the report in the evidence file supporting the statement, not to file the report as the statement.

Tree-cover loss is not deforestation under EUDR

This is the distinction most EUDR material skips, and it decides real cases in both directions.

The legal definition concerns conversion of forest to agricultural use. Global tree-cover change datasets record any tree change. A loss caused by fire, storm, road construction or renewable-energy infrastructure may not meet the legal definition at all. So a plot can show tree-cover loss and still be deforestation-free under the Regulation.

It fails in the other direction too. A forest baseline can be missed when a global land-cover product classifies an agroforestry landscape differently from the legal definition. In ATI’s own Ghana measurement, the JRC product returned a zero forest baseline on all fifteen reviewed cocoa polygons while other canopy evidence showed substantial tree cover. A zero baseline of that kind is uninformative by itself. It is not proof that the land was bare, and it is not proof that conversion happened safely before the cut-off.

The practical consequence: a screen that reports “tree-cover loss detected” as though it were “EUDR deforestation” will generate false alarms on ordinary cocoa farms and false comfort on genuinely converted land. Current Commission guidance describes land registers and cadastral material as complements to satellite data when establishing historical agricultural use.

What satellite evidence can and cannot answer

Commission guidance says spatial imagery can greatly assist due diligence and authority checks, but the Regulation does not prescribe a particular satellite tool or a minimum resolution. Certification and third-party verification are complementary evidence; they do not transfer the operator’s responsibility.

Well suited to

• Where is the submitted plot?
• What did a named forest-baseline dataset classify there at the EUDR cut-off?
• Did a named change dataset record tree-cover loss after 31 December 2020?
• What area and which years are associated with those observations?
• Do the datasets agree, or is the result limited by coverage, definitions, cloud, spatial resolution or classification?

Not answerable from imagery alone

• Whether the commodity in a shipment actually came from that plot.
• Whether every plot contributing to a mixed lot was disclosed.
• Whether an observed tree-cover change was conversion of forest to agricultural use.
• Whether production complied with land-tenure, environmental, labour, tax, trade or other relevant local law.
• Whether the operator considered every Article 10 factor.
• Whether mitigation reduced a product’s risk to negligible.
• Whether the operator should sign and submit the due diligence statement.

A provider claiming the second list is doing something other than remote sensing, and the operator remains accountable either way.

Point or polygon

The EUDR definition of geolocation permits at least one latitude and longitude point using at least six decimal places, and requires a polygon with enough points to describe the perimeter for non-cattle plots larger than four hectares.

That legal submission rule is not the same as the technical input a farm-area analysis needs. A point identifies a location; it does not define a boundary, and without a boundary there is no area over which forest-loss hectares can be calculated. A circular buffer drawn around a point is not the farm, and presenting one as the farm misstates the evidence.

For mixed or aggregated products, Article 9 requires all contributing plots. One clean farm report does not establish the origin of a whole batch.

Commodities, and where a crop screen stops

EUDR covers seven commodities, cattle, cocoa, coffee, oil palm, rubber, soya and wood, and only the derived products listed in Annex I. The commodity list has stayed the same through the product-scope updates; the derived-product list has changed. A commodity dropdown alone cannot establish that a particular product is in scope.

The same land-change analysis works across several crops, but it stops in specific places:

What ATI produces

A dated, plot-level report naming its sources, methods and limits, for the responsible operator’s retained evidence file. The engine screens a submitted polygon against Hansen/UMD tree-cover change, the JRC Global Forest Cover 2020 baseline and SBTN Natural Lands, and reports loss as a share of the forest baseline rather than of the polygon. Those are different numbers, and the polygon-relative one is misleading because it ignores whether the land was forest to begin with.

Where the datasets disagree, or where a baseline cannot be established, the report says so instead of resolving the ambiguity in the customer’s favour. GPS coordinates are optional at intake, because most smallholders have neither a GPS device nor a formal address; field verification is the alternative path.

How plot evidence works · Request plot evidence · Methodology

Common questions

Is tree-cover loss the same as deforestation under EUDR?

No. EUDR concerns conversion of forest to agricultural use after 31 December 2020. Tree-cover loss datasets record any tree change, including plantation harvest, fire, storm and road building. A plot can show tree-cover loss and still be deforestation-free under the Regulation, and a forest baseline can be missed when a global product classifies an agroforestry landscape differently from the legal definition.

Does a satellite report count as a due diligence statement?

No. The due diligence statement is the operator’s own structured declaration in the EU Information System. A satellite evidence report belongs in the evidence file that supports that statement. Operators and EU competent authorities make compliance determinations; an evidence provider does not.

Do I need a polygon, or is a GPS point enough?

The Regulation permits at least one latitude and longitude point to at least six decimal places, and requires a polygon for non-cattle plots larger than four hectares. That is the legal submission rule. It is not the same as the technical input a satellite analysis needs: a point identifies a location but does not define the boundary over which forest-loss hectares are calculated.

When does EUDR apply?

On the dates recorded in ATI’s September 2026 review of the consolidated text: 30 December 2026 for large and medium enterprises and for micro and small enterprises already covered by the EU Timber Regulation, and 30 June 2027 for most other micro and small enterprises. The timeline has been amended more than once, so confirm against the consolidated text before relying on it.

Which commodities does EUDR cover?

Cattle, cocoa, coffee, oil palm, rubber, soya and wood, together with the derived products listed in Annex I. The commodity list has stayed the same through the product-scope updates; the Annex I derived-product list has changed.

How long do records have to be kept?

Five years, and they must be made available to a competent authority on request.