EUDR: what the revised dates and geolocation rules ask of land evidence

• Application from 30 December 2026.
• From 30 June 2027 for micro and small enterprises.
• Delegated Regulation (EU) 2026/2102 adds products from 30 December 2027.
• The deforestation cut-off date stays 31 December 2020.

Article 2(28) asks for geolocation coordinates with at least six decimal digits. Plots above 4 hectares (outside cattle) must be described by a polygon, not a point. A plot geometry that is rounded, reprojected without care or drawn from a listing photo does not meet that bar: the geometry itself needs a source and a method.

• A “downstream operator” category.
• A single simplified declaration for small primary producers in a low-risk country, where a postal address can replace geolocation.
• Records kept for five years.
• Country risk is set by Implementing Regulation (EU) 2025/1093.

Phoeniks supplies the land layer of the file: plot geolocation at the depth each country publishes, land-cover evidence, the source and licence behind every layer, an evidence level on every figure and a reproducible trail. It does not issue the due-diligence statement or certify an operator: the statement and its conclusion remain the operator's responsibility.

• Does every plot carry coordinates with six decimals, and a polygon above 4 hectares?
• Is the source of each geometry and land-cover layer named and dated?
• Can the evidence be reproduced in five years, as the retention rule implies?

• Regulation (EU) 2023/1115, consolidated text of 26 December 2025: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226
• European Commission, Regulation on deforestation-free products: https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en
• Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115; Implementing Regulation (EU) 2025/1093 (country benchmarking); Delegated Regulation (EU) 2026/2102.
• Phoeniks EUDR page: https://phoeniks.org/en/compliance/eudr