---
title: Traceability for EUDR compliance
url: "https://www.unknowngravity.com/en/servicios/eudr-traceability"
site: Unknown Gravity
published: "2026-10-16T17:06:39+00:00"
modified: "2026-10-16T19:33:21+00:00"
language: en
description: "The EUDR applies from 30 Dec 2026: plot geolocation, due diligence statements in TRACES and chain of custody. Where blockchain helps and where it does not."
section: "Home > Services > Traceability for EUDR compliance"
---

# Traceability for EUDR compliance

PLOT GEOLOCATION DUE DILIGENCE IN TRACES VERIFIABLE CHAIN OF CUSTODY

[Book a meeting](/en/meeting)

The EU Deforestation Regulation (Regulation (EU) 2023/1115) requires proof that cattle, cocoa, coffee, oil palm, rubber, soya and wood placed on the EU market or exported are free of deforestation after 31 December 2020 and legally produced, backed by the geolocation of every plot and a due diligence statement. It applies from 30 December 2026, and from 30 June 2027 for micro and small operators. Unknown Gravity designs the data model, the TRACES integration and the shared ledger that carry that proof from the plot to the EU importer.

**If you buy or sell coffee, cocoa, soya, palm oil, rubber, wood or cattle products, the EUDR asks for what your ERP does not hold: the geolocation of every plot and an unbroken chain of custody from the farm to EU customs. We help you build it, and we tell you which part no technology can solve.**

## 01 / What the EUDR requires and when it applies

[Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1115) bans placing seven commodities and their derived products on the EU market, making them available or exporting them unless three conditions are met at once (Art. 3): they are **deforestation-free**, they were **produced in line with the laws of the country of production**, and they are covered by a **due diligence statement** (DDS) or, for micro and small primary operators, a simplified declaration.

- **Commodities:** cattle, cocoa, coffee, oil palm, rubber, soya and wood (Art. 1), plus the Annex I products, from cocoa beans to chocolate or wooden furniture.
- **Deforestation-free:** produced on land not deforested after **31 December 2020**; for wood, also harvested without forest degradation since that date (Art. 2(13)).
- **Legality:** land use, environment, labour, human and third-party rights, and the free, prior and informed consent of indigenous peoples, among other laws of the country of production (Art. 2(40)).
- **Geolocation:** of every plot, with the date or time range of production (Art. 9(1)(d)). At least six decimal digits, and polygons for plots over four hectares other than cattle (Art. 2(28)).
- **Statement:** the DDS is submitted before the product is placed on the market or exported (Art. 4(2)), in the EU information system, a dedicated tool of the [TRACES](https://green-forum.ec.europa.eu/deforestation-regulation-implementation/information-system-deforestation-regulation_en) platform. Its reference number goes to customs (Art. 26(4)) and records are kept for five years (Art. 9(1)).

**Who is covered.** Since [Regulation (EU) 2025/2650](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2650), the **operator** that places the product on the EU market or exports it files the DDS; if the person placing it on the market is established outside the EU, the first person established in the EU who makes it available also counts as an operator (Art. 7). **Downstream operators** (who process products already declared, such as a coffee roaster) and **traders** file no DDS: those that are not SMEs register, and the first of them in the chain keeps the reference numbers. For a legal person, the maximum fine must be at least 4% of its annual EU turnover (Art. 25).

**Current dates**, according to the [European Commission](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en) and Art. 38 as amended by Regulation 2025/2650:

| Who | From |
| --- | --- |
| Large and medium-sized operators, and downstream operators and traders | 30 December 2026 |
| Micro and small operators (natural persons, micro and small enterprises) established as such by 31 December 2024 | 30 June 2027 |
| Micro and small operators, for timber products listed in the Annex to the old EU Timber Regulation (EU) No 995/2010 | 30 December 2026 |

In its [report of 4 May 2026](https://environment.ec.europa.eu/document/download/a3c5c3a0-232e-43c4-b0b8-1eecb1df45c7_en?filename=Report+from+the+Commission+to+the+Council+and+Parliament+on+the+EUDR.pdf), the Commission does not consider it appropriate to propose further amendments to the legal text. Annex I has changed, though: [Delegated Regulation (EU) 2026/2102](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R2102), published on 17 September 2026, removes cattle hides, skins and leather from the scope and adds, among others, soluble coffee from 30 December 2027. Check the list in force before you fix your scope.

## 02 / The real chain of custody and where it breaks

In coffee or cocoa, a typical chain runs from producer to cooperative or aggregator, exporter, importer (the EU operator) and processor (downstream operator). The data is born at the first link and declared at the fourth. It breaks in four places along the way:

1. **Mixed lots.** If a product comes from several plots, all of them must be geolocated (Art. 9(1)(d)): a single unmapped farm leaves the cooperative's whole lot without proof.
2. **Mass balance.** Several certification schemes accept it; the EUDR does not when compliant product is mixed with product of unknown origin. The [Commission guidance document](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025XC04524) states that this is not acceptable under the Regulation. The way out is segregation or identity preservation.
3. **Badly captured polygons.** A point where a polygon was needed, fewer than six decimals, overlapping plots or plots inside forest. If nobody validates them at origin, the error shows up with the goods already in transit.
4. **Reference numbers that do not travel.** Every operator must pass them downstream (Art. 4(7), as amended by Regulation 2025/2650). If they arrive in a PDF by email, the processor cannot match them to its lots.

On top of that, Art. 10 requires assessing the risk of mixing with products of unknown origin, and according to the Commission, evidence of legality should be proportionate to the level of risk. If you also need the lot traceability of Regulation 178/2002, see our [food traceability system](/en/servicios/food-traceability-system).

### Coffee and cocoa from Latin America: what your EU buyer will ask for

If you export coffee or cocoa from Colombia, Peru, Ecuador, Central America or Brazil, your EU customer normally files the DDS, but the data comes from you: the geolocation of each farm (a polygon above four hectares), the harvest date, proof of legality and lots with no unmapped farms. Colombia, Peru, Ecuador, Brazil, Mexico, Honduras, Guatemala, El Salvador and Nicaragua are not listed in [Implementing Regulation (EU) 2025/1093](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1093), so they are standard risk. Costa Rica is low risk, and only in such countries can micro and small primary operators file a simplified declaration with a postal address instead of geolocation.

The cooperative is where compliance is won or lost: a register of farms with their polygons, collection segregated by lot, and one data package per container (GeoJSON, lot, quantities and evidence) for the importer. According to the Commission's May 2026 report, Honduras has already shipped fully traceable coffee to the EU using an open digital infrastructure that includes smallholders, and the AL INVEST Verde programme supports traceability efforts in Latin America.

Coffee and cocoa cases with their status, and how the chain is organized from the farm, are covered in [coffee and cocoa traceability](/en/servicios/coffee-cocoa-traceability).

## 03 / Where blockchain helps with the EUDR, and where it does not

The EUDR neither requires nor mentions blockchain: it asks for verifiable information, kept for five years and declared in TRACES. A blockchain is one way of moving that data from one link to the next without anyone rewriting it. It helps in three ways:

- **A shared record between companies that do not trust each other.** Cooperative, exporter, importer and processor do not share an ERP. Each one logs its signed event (collection, shipment, receipt, processing), and none of them can rewrite it alone.
- **A fingerprint of the geolocation and the statement.** What goes on chain is the [hash](/en/glosario/hash) of the GeoJSON file, the evidence and the DDS with its reference number, not the data itself. In an inspection within the five years, you can prove what you declared and when. GS1 provides for this fingerprint of EPCIS events for notarisation.
- **Verifiable credentials.** The operator's identity or the outcome of a review ("plot checked against satellite imagery") travel signed, and the next link verifies them without asking for the document again.

What it does not solve:

- **The source data.** If the polygon is wrong or the farm was cleared in 2022, the chain keeps the error. This is the [oracle](/en/glosario/oraculo) problem.
- **Satellite imagery and the risk assessment** of Art. 10: a separate layer.
- **Verification on the ground.** Whether the beans in the bag come from that plot is proven by physical segregation, inspections and audits.
- **Personal data.** A smallholder's name and coordinates are personal data. The EDPB Guidelines 02/2025 call for storing data off chain and warn that even metadata can be personal data.

If a single importer controls the data end to end, an audited database is enough. The same pattern applies to the [digital product passport](/en/articulos/digital-product-passport-dpp), and the sector-by-sector framework is in [blockchain traceability](/en/servicios/sistema-trazabilidad-de-productos).

## 04 / Verified cases and references, with their status

Unknown Gravity has no EUDR traceability projects of its own to publish. These are third-party cases, with their primary source and status as of 16 October 2026:

| Case | Commodity | What it does | Status |
| --- | --- | --- | --- |
| [FORTRA](https://alastria.io/en/fortra-forest-traceability-2/), Xunta de Galicia (Amtega) | Wood | Records, from forest to market, the operations of the companies that process the wood, on Alastria's Red T network, with a QR code for consumers. | In Alastria's use-case catalogue (entry of 13 June 2023); 12 active companies according to the entry. |
| [Digitanimal](https://redisbe.com/casos-de-uso/) | Livestock | Livestock traceability with GPS collars and blockchain event records. | In the use-case catalogue of Spain's blockchain services infrastructure (ISBE). |

Two caveats: FORTRA does not name the EUDR (it is a precedent for timber legality), and for cattle raised in the EU, Regulation 2025/2650 recognises equivalent traceability obligations under Regulation (EU) 2016/429, with the data held in national databases.

**Public systems cited by the Commission** in its report COM(2026) 191: traceable coffee from Honduras, the Ghana Cocoa Traceability System, Argentina's VISEC platform for soya and Brazil's "Selo Verde". The report does not say that they use blockchain: they set the level of data your importer will expect.

**Vendors, not cases:** [Bext360](https://www.bext360.com/) (coffee, with producers in Honduras, Mexico, Peru, El Salvador and Nicaragua, among others) and [OpenSC](https://opensc.org/) (palm oil) sell origin traceability with blockchain. We have not verified their deployments.

**What was withdrawn.** IBM withdrew IBM Food Trust from marketing on 14 May 2025, with no direct replacement ([announcement AD25-0032](https://www.ibm.com/docs/en/announcements/cloud-service-withdrawal-supply-chain-intelligence-suite-blockchain-transparent-supply-select-parts-withdrawal-sterling-order-management?region=US)), and [Maersk and IBM announced in November 2022 that they would discontinue TradeLens](https://www.maersk.com/news/articles/2022/11/29/maersk-and-ibm-to-discontinue-tradelens), with the platform due to go offline by the end of the first quarter of 2023. The lesson: keep data in open formats (GeoJSON, EPCIS) that can leave the platform. More cases by sector in [blockchain in the supply chain](/en/articulos/casos-de-uso-de-blockchain-en-la-cadena-de-suministro).

## 05 / How we approach it: data, TRACES, network and deliverables

We do not sell a closed platform: we design the data and integrity layer on top of what you already use.

1. **Assessment.** Annex I products and codes, your role (operator, downstream operator or trader), sourcing countries and their risk level, and what data each supplier holds today.
2. **Data model.** Plot (GeoJSON with six decimals, a polygon above four hectares, production date and evidence of legality), lot (net kilograms, plots, segregation and processing) and DDS (reference number and lots covered). Events in EPCIS 2.0.
3. **ERP and TRACES integration.** The information system accepts geolocation in GeoJSON and offers an API to submit statements in bulk. We validate polygons before they are sent.
4. **Network.** For a consortium of cooperatives, exporters and importers, [Spain's blockchain services infrastructure (ISBE)](/en/blockchain/desarrollo-blockchain-isbe): public-permissioned, EVM-compatible, with verified company identity and a monthly subscription with a transaction quota, with no token or gas fees. If governance calls for it, a [private consortium network](/en/servicios/blockchain-privadas); if proof of existence is enough, anchoring fingerprints on a public network. Unknown Gravity is a member of Alastria, which operates ISBE.
5. **Data protection.** Personal data off chain and a data protection impact assessment before going live.

Deliverables:

- Supply chain map with each link's role and its mixing points.
- Data model justifying what goes on chain and what stays off it.
- Polygon capture and validation for cooperatives and exporters.
- Connector to the TRACES API and to your ERP.
- Smart contracts for logging events and fingerprints, with test suites.
- A per-lot file ready for an inspection for five years.

**Sources**

- [Regulation (EU) 2023/1115 (EUDR)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1115)
- [Regulation (EU) 2024/3234](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3234)
- [Regulation (EU) 2025/2650](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2650)
- [Delegated Regulation (EU) 2026/2102](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R2102)
- [Implementing Regulation (EU) 2025/1093](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1093)
- [Guidance document C/2025/4524](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025XC04524)
- [Commission report COM(2026) 191](https://environment.ec.europa.eu/document/download/a3c5c3a0-232e-43c4-b0b8-1eecb1df45c7_en?filename=Report+from+the+Commission+to+the+Council+and+Parliament+on+the+EUDR.pdf)
- [EUDR information system (TRACES)](https://green-forum.ec.europa.eu/deforestation-regulation-implementation/information-system-deforestation-regulation_en)
- [EDPB Guidelines 02/2025](https://www.edpb.europa.eu/documents/guideline/guidelines-022025-on-processing-of-personal-data-through-blockchain_en)
- [GS1 CBV 2.0](https://ref.gs1.org/standards/cbv/)
- [ISBE (redisbe.com)](https://redisbe.com/)
- [ISBE fee policy ADM1010](https://github.com/red-isbe/legal)

FAQ

## Frequently asked questions

**Has the EUDR been delayed again?**

Yes, twice. The original text applied from 30 December 2024; Regulation (EU) 2024/3234 moved it to 30 December 2025, and Regulation (EU) 2025/2650, published on 23 December 2025, to 30 December 2026 (30 June 2027 for micro and small operators). In May 2026, the Commission said it does not consider it appropriate to propose further amendments. Plan around those dates.

**Who has to comply with the EUDR?**

The operator that places the product on the EU market or exports it, which files the due diligence statement. Downstream operators and traders do not file one, but they keep supplier and customer data for five years, and register if they are not SMEs. An exporter outside the EU that sells to an EU importer has no direct obligation, but that customer will ask for the geolocation and the evidence.

**What is the EUDR due diligence statement (DDS)?**

It is the statement the operator submits in the EU information system, within TRACES, before placing the product on the market or exporting it. It includes the operator's details and EORI number, the customs code and quantity, the country of production, the geolocation of the plots and a declaration that no risk, or only a negligible risk, was found (Annex II). The system returns a reference number that goes to customs and to the next links. According to the Commission, one statement can cover several shipments.

**What geolocation does the EUDR require, and in what format?**

Latitude and longitude with at least six decimal digits for every plot of origin, with the date or time range of production. For plots over four hectares, a polygon with its perimeter; for cattle, every establishment where the animals were kept. The information system accepts coordinates in bulk as GeoJSON files.

**How does the EUDR apply to SMEs?**

Micro and small operators established as such by 31 December 2024 have until 30 June 2027, except for timber covered by the old EU Timber Regulation; that deferral does not extend to downstream operators or traders. Downstream operators and traders that are SMEs do not register, although the first one in the chain still collects the reference numbers. And micro and small primary operators in low-risk countries file a single simplified declaration, where they can give a postal address instead of geolocation.

This page is informative. It is not legal, tax or investment advice, and it does not replace a case-by-case review. The rules cited change: check the current version on [BOE](https://www.boe.es) and [EUR-Lex](https://eur-lex.europa.eu).

RELATED SERVICES

[Blockchain traceability for supply chains](/en/servicios/sistema-trazabilidad-de-productos) [Coffee and cocoa traceability for the EU](/en/servicios/coffee-cocoa-traceability) [Blockchain food traceability system](/en/servicios/food-traceability-system) [Private blockchains](/en/servicios/blockchain-privadas)

[All blockchain services](/en/servicios)

GUIDES AND COMPARISONS

[Digital Product Passport (DPP): EU rules, timeline and how to build one](/en/articulos/digital-product-passport-dpp) [Blockchain in the supply chain: verified use cases, what shut down and the limits](/en/articulos/casos-de-uso-de-blockchain-en-la-cadena-de-suministro) [Food traceability: what Regulation (EC) 178/2002 requires and how to build your plan](/en/articulos/food-traceability)

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