Agroforestry and EUDR

Agroforestry requires a land-use assessment

Agroforestry does not create a blanket EUDR exemption. Agricultural plantations include agroforestry systems where crops are grown under tree cover, and predominantly agricultural land is excluded from the forest definition. The assessment must establish the actual system, predominant use and history of the relevant area.

This can mean that an established predominantly agricultural agroforestry area is not forest under Article 2(4), even with substantial trees. It does not mean qualifying forest can be converted to such a system after the cut-off without a deforestation issue. The starting land use and subsequent change still matter.

The deforestation-free requirement explains the historical condition. Apply the current Articles 2(4) to 2(6) with the detailed agroforestry discussion in the July 2026 guidance.

Understand what the system actually does

Agroforestry can combine woody plants with crops or animals in spatial arrangements or sequences. The guidance discusses agrisilvicultural, silvopastoral and related systems. Their physical appearance alone may not reveal whether agriculture predominates or whether limited agricultural activity occurs within continuing forest.

Record the production purpose, crop or livestock activity, management, planting history and area involved. A supplier's preferred label is not enough. The same word can describe an established agricultural system, limited side production in forest or a transition from forest to commercial agriculture.

The legal classification should explain why the actual facts meet the relevant definition. Avoid treating a sustainability benefit, shade canopy or diverse species mix as a substitute for analysing predominant land use. Those features can provide context without deciding the EUDR category.

Distinguish predominant agriculture from forest side activities

The guidance says predominant agroforestry use can fall within agricultural use. It also explains that small-scale side production, such as coffee, and occasional extensive or small-scale grazing may not make agriculture predominant where the production and activities do not detrimentally affect the forest habitat.

The distinction is fact-sensitive. Do not turn the side-production discussion into a universal percentage threshold or a permission to expand commercial agriculture without review. Assess the activity's scale, purpose, management and effect in the actual area, using the complete guidance.

Seasonal silvopastoral and climate-limited practices are also discussed in the guidance. Their treatment depends on the circumstances described, including the forest category where relevant. Preserve the reasoning and supporting evidence rather than applying a single rule to all grazing under trees.

Reconstruct the history of a new agroforestry source

A current shaded coffee or cocoa system can look tree-covered while having replaced qualifying forest after 2020. Establish what preceded the agricultural system and when the change occurred. A current canopy map cannot alone distinguish an old agricultural system from recent forest conversion.

Conversely, shade-tree planting on established agricultural land is not automatically conversion of agriculture to forest under the EUDR definition. Predominant use and the full facts matter. Check relevant guidance for particular temporary afforestation and agricultural-use circumstances instead of making a broad assumption based on tree age.

For mixed holdings, assess forest and agricultural sections separately. A large agricultural area does not remove the forest classification of a distinct qualifying section. Mapping should show the actual production area and any changes so the historical conclusion concerns the source of the goods.

Collect evidence suited to mixed systems

Dated imagery, production records, planting history, management information and land-use records can complement one another. Imagery may show canopy continuity while farm records clarify the agricultural purpose. A land register can support history, but does not override objective forest characteristics merely by using an agricultural label.

Ask suppliers to distinguish long-established production areas from recent expansions and to identify changes in shade, cropping or grazing management. Keep the product connection through plot and batch records. Evidence for a model farm should not silently stand in for every actual source in a cooperative.

Where a claim relies on a specific guidance circumstance, preserve the supporting facts and documents. Primary non-agricultural purposes with ancillary agriculture are a different issue from predominantly agricultural agroforestry. Do not combine the two into a broad exception that neither the Regulation nor guidance states.

For a shaded coffee source, ask whether records show longstanding agricultural management under retained trees or a recent introduction of agriculture into qualifying forest. Both can appear as coffee beneath canopy in a current image. Production history, earlier imagery and evidence about management intensity can clarify the distinction. If the claim is that coffee remains limited side production within continuing forest, record the specific facts supporting that interpretation, including the activity's scale and effect, rather than relying solely on the supplier's agroforestry label.

Reach a narrow, reviewable conclusion

State the source area's classification, the historical sequence, evidence and unresolved questions. Explain whether a change to agricultural use occurred after the cut-off rather than merely calling the system agroforestry-friendly. Full product compliance also requires the separate legality and coverage conditions.

The article on plantations and forest definitions clarifies the related distinction between agricultural plantations and forest categories. Wood sourced from a mixed system may also need its own scope and forest-condition assessment under the relevant definitions.

Review the conclusion when production expands, boundaries change or new evidence appears. A supported classification allows beneficial land-management features to be described accurately while keeping the EUDR assessment tied to the actual legal test.