EUDR geolocation data: when a supplier won't provide it

If a supplier won't or can't give you plot-level coordinates, you cannot reach negligible risk for that consignment under Article 10, and you cannot file a due diligence statement that relies on it. Your options are to collect the coordinates yourself, find a supplier who can provide them, or stop sourcing that product from that supplier before your deadline. There is no EUDR exemption for an unresponsive supplier.

Who actually needs to solve this problem

Geolocation is an Article 9(1)(d) information requirement, and only the operator placing the product on the EU market for the first time, or exporting it, has to collect it. If you buy from an EU distributor who already filed a due diligence statement upstream, you are a downstream trader: you collect that statement's reference number, not fresh coordinates. See who still needs a due diligence statement if you are not sure which side of that line you sit on.

If you are the first operator placing the product on the market, or you export it from the EU, the geolocation obligation is yours, and it is not negotiable by contract with your supplier. The geolocation requirements guide covers the format: a point for plots up to 4 hectares, a polygon above that, cattle establishments always as a single point, six decimal places minimum.

Why "we trust this supplier" isn't a substitute

Trust, certification and a long trading relationship are inputs to your risk assessment under Article 10, not substitutes for the Article 9 information set. A due diligence statement without plot coordinates is incomplete, and an incomplete statement cannot be submitted through the Information System. Simplified due diligence under Article 13 removes the risk assessment and mitigation steps for products sourced entirely from low-risk countries — it does not remove the geolocation requirement, which the Article 13 guide and the regulation both make clear applies regardless of country tier. There is no lower tier of due diligence that lets you skip collecting coordinates.

Why suppliers actually refuse or stall

Refusal rarely means the supplier is hiding something illegal. The common reasons:

• No record exists. Smallholders and informal aggregators in many origin countries have never measured their plots with a GPS device and do not know their own coordinates to six decimal places.
• Aggregation hides the origin. Cooperatives and collection points often blend produce from dozens or hundreds of smallholders before it reaches an exporter, so the exporter itself may not hold farm-level data.
• Legal uncertainty in the exporting country. Some countries restrict sharing geospatial data under surveying, mapping or data-security law. Advisers covering Chinese suppliers, for example, report hesitation rooted in China's surveying and mapping law, data security law and personal information protection law — but no outright statutory ban on sharing commercial plot coordinates with a buyer. The caution is real; it is not usually a legal dead end.
• Competitive concern. An exporter may worry that precise plot locations let a buyer go around them and deal with the grower directly.
• Capacity, not willingness. A supplier may agree in principle but lack the staff, mapping tools or budget to produce GeoJSON polygons for hundreds of plots before your deadline.

Knowing which of these you are dealing with changes what you do next.

What to do before you give up on the supplier

Work through these before writing the supplier off:

1. Ask for what they already have, not a finished polygon. A printed land title, a cooperative's own farm register, or even a screenshot from a phone's maps app often contains enough to plot a point yourself. You do not need the supplier to produce a GeoJSON file; you need the underlying location.
2. Offer a mapping method that fits their reality. A free smartphone GPS app can capture a usable point in minutes. For smallholder cooperatives, a single bulk data-collection exercise, run once across all member farms, is usually cheaper per plot than chasing each farmer individually.
3. Put the obligation in the contract, with a deadline. Many supply agreements still don't mention Article 9 information at all. A written requirement, with a date and a named format, moves the request from a favour to a condition of the contract.
4. Ask your competent authority or an industry body about sector-specific routes. Some trade associations in low-geolocation sectors have proposed that downstream actors rely on an upstream supplier's due diligence statement reference rather than collecting their own coordinates, where that supplier has verifiably already done the work. This is an industry position, not settled Commission guidance, and it applies to downstream actors relying on someone else's completed statement — not to the operator placing the product on the market for the first time, who has no such upstream statement to rely on.
5. Check whether a different supplier for the same plots already has the data. Coordinates are tied to the plot, not to the trading relationship. If a competitor sources from the same cooperative and has already mapped it, a data-sharing arrangement between buyers can save everyone the fieldwork.

What happens if the data genuinely isn't available in time

If none of that produces usable coordinates before you need to place the product on the market, your realistic options narrow to three:

Situation	What you can do	What you cannot do
Supplier has the data but is slow or reluctant	Keep escalating with a deadline; consider a short-term alternative supplier for the volume at risk	Submit a statement with placeholder or approximate coordinates
Supplier genuinely has no farm-level data and cannot get it in time	Source the same product, same deadline, from a supplier who can provide geolocation	Rely on certification, an audit report or a trading history as a substitute for Article 9 information
No alternative supplier exists for the volume or specification you need	Delay placing that specific consignment on the market until the data exists	Treat "best effort" as compliance, or file a statement you know is incomplete

A due diligence statement filed without valid geolocation is not a weaker version of compliance — it is not a due diligence statement the Information System will accept, and placing the product on the market without one is the position the penalties guide covers. Weigh that against the commercial cost of dropping a supplier before you decide fieldwork is "too expensive."

Does this count against you in a risk assessment?

A genuine, documented difficulty getting geolocation data is not itself evidence of deforestation risk, and a competent authority inspecting your file is more interested in what you did about the gap than in the fact that it existed. Keep a dated record of every request, every response and every alternative you tried — that record is part of the risk assessment and mitigation documentation competent authorities expect to see, and it is what distinguishes a supply chain you are actively fixing from one you are simply hoping nobody checks.

FAQ

Can I use the exporter's registered business address instead of plot coordinates? No. Article 9(1)(d) requires the geolocation of the plot of production, not the trader's or exporter's address. A business address identifies a company, not a piece of land, and will not pass validation in the Information System.

Does a sustainability certificate (FSC, RSPO, Rainforest Alliance) cover the geolocation requirement? No. Certification can inform your risk assessment, but it does not substitute for the Article 9 information set, which includes geolocation as a standalone requirement regardless of what else you hold on file.

My supplier says sharing coordinates breaches a law in their country. Is that true? Sometimes there is a genuine legal constraint on sharing certain geospatial data, and sometimes it is caution rather than a hard rule. Treat the claim seriously, ask for the specific law cited, and get local legal advice before concluding there is no way through — a blanket refusal is not always the only legally available answer.

Is a single average coordinate for a cooperative good enough if I can't get individual farm data? No, if the cooperative sources from more than one plot. Each plot above 4 hectares needs its own polygon, and each plot of 4 hectares or less needs its own point; an averaged or centroid coordinate for a group of plots does not meet the Article 9(1)(d) requirement.

How long can I keep trying before I have to act? There is no fixed grace period in the regulation. Practically, you need usable coordinates before you place the relevant product on the EU market or export it, so work backwards from your application deadline and treat unresolved geolocation gaps as a sourcing risk, not an administrative one.

If I switch suppliers to solve this, do I still need geolocation from the new one? Yes. The requirement attaches to the product and its plot of production, not to a particular supplier. Changing supplier only helps if the new one can actually provide valid coordinates for its own plots.

Does the 4-hectare point-versus-polygon rule change any of this? No. Whether a plot needs a single point or a full polygon affects the format you collect, not whether you need to collect it. A supplier who can't produce a polygon for a large plot still has to provide one; asking for a point instead is not a lawful shortcut.

Can my own staff collect the coordinates if the supplier won't? Yes, if you or an agent you contract can physically access the plot, or obtain its location from a land registry, satellite imagery cross-check or other reliable source independent of the supplier. That doesn't resolve the underlying relationship, but it does get you a compliant statement for that consignment.

Not sure whether this obligation falls on you or further up your supply chain? Check what EUDR requires of your business and get a verdict based on your actual role, products and size band.