What the EU Deforestation Regulation requires
Four due diligence obligations, seven commodities and two compliance dates. This page sets them out and stops there: whether the regulation applies to you, and in which cohort, is a question for your own counsel.
Scope and compliance dates
The regulation covers seven commodities and the products derived from them, for anyone placing them on the EU market or exporting them from it.
- Cocoa
- Coffee
- Palm oil
- Soy
- Rubber
- Cattle
- Wood
Large and medium operators and traders
The first cohort. If you place any of the seven commodities on the EU market, or export them from it, and you are not a small or micro enterprise, this is your date.
Small and micro enterprises
Six months later. Cohort is determined by company size; your volume in any one commodity does not change it.
The four due diligence obligations
Three of the four fall due long before a submission window opens. A tool that only produces the statement covers the last quarter of the work.
- Information
You have to collect and keep specific information about each consignment, including the geolocation of every plot of land where the commodity was produced, and the date or time range of production.
- Risk assessment
You have to assess the risk that the commodity is not deforestation-free or was not produced in accordance with the law of the country of production, taking the Annex I criteria into account.
- Risk mitigation
Where the risk is more than negligible, you have to take measures to reduce it before placing the product on the market, and be able to show what you did.
- The statement
You submit a Due Diligence Statement through the EU information system, TRACES, and you keep the evidence behind it.
Geolocation and the 4-hectare threshold
A point is sufficient for a plot below 4 hectares. At 4 hectares and above you need a polygon describing the plot boundary.
That single threshold is what quietly breaks cocoa programmes. A cooperative collecting points for every farm is fine until one farm turns out to be 4.2 ha. The point collected two seasons ago is then not the evidence the regulation asks for, and the gap surfaces in the week you intended to file.
How Grovetrace handles plot dataFrequently asked questions
These come from real calls. Where an answer depends on your own company, it says so instead of guessing.
Does the December 2026 deadline actually apply to me?
It depends on your size, and the two cohorts have different dates. Large and medium operators and traders are in scope from 30 December 2026. Small and micro enterprises follow on 30 June 2027.
If you place cocoa, coffee, palm oil, soy, rubber, cattle or wood, or products derived from them, on the EU market, or export them from it, the regulation is aimed at you. Which cohort you sit in is a question for your own counsel; it is determined by company size, and your volume in any one commodity does not change it.
What counts as geolocation for a smallholder farm?
A point is sufficient for a plot below 4 hectares. Above that you need a polygon describing the plot boundary.
This is the detail that quietly breaks cocoa programmes. A cooperative collecting points for every farm is fine until one farm turns out to be 4.2 ha, and the point collected two seasons ago is then not the evidence the regulation asks for. Grovetrace stores plot geometry as PostGIS at SRID 4326, rejects what will not parse on the way in, and holds each plot’s deforestation verdict against it, so gaps surface months ahead of a submission window instead of inside one.
Do I have to replace the systems I already use?
No, and you should not have to. Grovetrace connects to what you already run: ERP exports, field-data platforms, cooperative spreadsheets and CSV. It maps each source once onto its own model: farmers to suppliers, plots to land plots, lots to batches.
That matters most at origin. A cooperative in Ghana will not adopt your compliance software, so the data has to be ingested in whatever shape it already arrives in.
Our plot data arrives in four different formats. Is that a problem?
That is the normal case, and it is the specific problem Grovetrace was built for. Each source gets its own mapping, so thirty origins sending thirty conventions still resolve to one set of suppliers, plots and batches.
The harder half is identity: the ERP holds a vendor code, the field tool a farmer ID, and the cooperative spreadsheet a name spelled three ways. Grovetrace resolves all three to one supplier and one plot, so your team is not reconciling them per shipment.
What about blending? Our lots come from many farms.
Aggregation is modelled explicitly. Beans from many farms become one lot, one container, one shipment, and the link from each batch back to the batches that fed it is retained, so a filed statement can still name every plot behind a blended consignment.
Traceability that survives the blend is what makes a statement defensible when it is examined.
What happens if TRACES rejects a statement?
The rejection and its reason are recorded against the statement, and the shipment returns to the worklist as an item to act on instead of disappearing into an inbox. You correct the underlying data and resubmit.
Most rejections trace back to the same few fields being absent or imprecise, and that is where the platform concentrates its effort.
Does Grovetrace file the statement, or do we?
Grovetrace files it. Submit, amend and withdraw are all handled in the platform, for domestic and import declarations alike, and the reference TRACES returns is stored against the shipment.
Each statement keeps the plot data and the assessments it was built from, so a filing can be produced and defended years later without reassembling it out of four systems.
Is this only for cocoa?
The platform is commodity-generic. All seven EUDR commodities work the same way, and consolidating cocoa and coffee into a single compliance function is a common reason operators come to us.
Cocoa is where the depth is, because cocoa is where the hard parts concentrate: thousands of smallholder plots, cooperatives in the middle of the chain, and aggregation before export.
This page is not legal advice
Grovetrace builds compliance software and does not give legal advice. Everything above is a plain-language summary written to help you work out which questions to ask. The regulation itself, as amended, is the authority, and your own counsel is who should tell you how it applies to your business.
If a line on this page is wrong or has gone out of date, tell us athello@grovetrace.com and it gets fixed.
See what your own data would produce
Twenty minutes, screen shared. Bring one shipment and the plot data behind it, and we will walk it through to a statement, stopping wherever it breaks.