EUDR Starts in less than 90 Days. Is Your Plot Data Ready?

What plantation companies need to map before 30 December 2026?

From 30 December 2026, palm oil, rubber, coffee, cocoa, and wood entering the EU must be traced back to the plot where they were grown. Here is what that means for plantation companies in Indonesia, and where plot data usually falls short

Topic

Geospatial Systems

Publish Date

Sep 30, 2026

EUDR Starts in less than 90 Days. Is Your Plot Data Ready?

Overview

On 30 December 2026, the EU Deforestation Regulation (EUDR) starts applying to large and medium companies that place certain commodities on the EU market. The list covers oil palm, rubber, cocoa, coffee, soya, wood, and cattle, along with many products made from them. Micro and small companies have until 30 June 2027.

The regulation has already been postponed twice. The European Commission has said there will be no third delay.

For Indonesian producers, the impact lands on the supply side. EU buyers must submit a due diligence statement proving that each shipment is deforestation-free and legally produced. To do that, they need the geographic location of every plot of land the commodity came from.

That makes EUDR a data problem as much as a sustainability problem. Many plantation companies already have maps of their own estates. The gaps usually sit in places that are harder to reach: smallholder plots, third-party suppliers, and historical records.

Main Points

1. Every Plot Needs a Location

Under EUDR, sustainability claims alone are no longer enough. The EU buyer has to show exactly where the commodity was grown, down to the plot.

Indonesia is classified as a standard-risk country in the EU's country benchmarking. That means buyers sourcing from Indonesia must carry out full due diligence, including risk assessment and risk mitigation.

A due diligence statement typically needs:

the geolocation of every plot that contributed to the shipment
proof that the land was not deforested after 31 December 2020
evidence that production followed local laws, including land rights
a clear link between the plot, the harvest, and the shipment

If one supplier in the chain cannot provide plot locations, the buyer carries the risk. In practice, that supplier may simply be dropped.

2. Smallholder Plots Are the Weakest Link

Company-owned estates usually have concession boundaries, HGU maps, and survey data. Smallholder supply is a different story.

Indonesia's palm oil sector relies on millions of independent smallholders, and many of their plots have never been formally mapped. Fresh fruit bunches often pass through collectors before reaching the mill, so the mill may not know which plot the fruit came from.

Common gaps in smallholder data include:

no GPS coordinates, only village or farmer names
land documents that do not match conditions on the ground
fruit mixed at collection points before it reaches the mill
supplier lists that change from season to season

Certification schemes such as RSPO and ISPO help with risk screening. They do not replace plot-level geolocation in the due diligence statement.

3. Small Plots Need a Point. Bigger Plots Need a Polygon.

EUDR sets a simple rule for how a plot is recorded. For plots of 4 hectares or less, a single latitude and longitude point is enough. Plots larger than 4 hectares need a polygon that traces the full boundary.

The technical requirements are strict:

coordinates with at least six decimal places
polygons submitted in GeoJSON format
polygons that are closed and follow the actual plot boundary
one polygon per plot, with no single shape covering several plots

A point taken at the farmer's house or the village office will not hold up. The coordinate has to fall on the plot itself. Collecting this data in the field, checking it, and keeping it updated takes time, and 90 days goes by fast.

4. Deforestation-Free Has to Be Proven Back to 2020

Having the location is only half the work. The buyer must also show that no deforestation happened on that plot after the cut-off date of 31 December 2020.

This is where satellite imagery comes in. By comparing imagery from before and after the cut-off date, teams can check whether forest cover on a plot has changed.

A practical verification workflow usually includes:

overlaying plot points and polygons on historical satellite imagery
comparing forest cover in 2020 with current conditions
flagging plots that overlap protected areas or recent clearing
documenting results so they can be shared with buyers and auditors

Doing this plot by plot in spreadsheets does not scale. When plot data, imagery, and risk flags sit on one map, the review is faster and much easier to audit.

Summary

EUDR moves traceability from paperwork to coordinates. From 30 December 2026, a commodity that cannot be linked to a mapped plot becomes much harder to sell into the EU.

For Indonesian plantation companies, the hardest part is rarely their own estates. It is the smallholder and third-party supply that sits outside formal mapping.

The next 90 days are a good window to check where plot data is missing, which suppliers still need field mapping, and whether historical imagery has been reviewed against the 2020 cut-off.

Companies that treat plot data as a long-term asset will be in a stronger position, both for EUDR and for whatever traceability rule comes next.