When Does EUDR Require Polygon Data?

Polygons are required above four hectares

Article 2(28) requires polygon geolocation for production plots larger than four hectares used for relevant commodities other than cattle. The polygon must contain sufficient latitude and longitude points to describe each plot's perimeter. Exactly four hectares does not exceed that threshold, and the rule applies to the production plot rather than a supplier's total landholding.

The area decision should be supported by a credible plot definition and area record. A spreadsheet rounded to “4 ha” is not conclusive evidence that a plot measuring more than four hectares falls below the threshold. Where the underlying area is uncertain, investigate it before deciding a point alone is sufficient.

Establish the legal production unit first

Article 2(27) describes land within a single recognised real-estate property with sufficiently homogeneous conditions for assessing deforestation and degradation risk. The first task is to identify that unit in the actual production setting. A farm name can encompass several properties, and an internal management block may not match the unit used for the legal assessment.

Record the evidence explaining the boundary and its relationship to the production activity. A large production plot should not be split into artificial rows merely to keep every row under the threshold. The representation must describe the real sourcing land and allow the required assessment, rather than optimise an upload by changing the facts.

Do not add unrelated plots together

A shipment can combine commodity from many small plots without those plots becoming one large plot. If separate legitimate plots of two, three and four hectares contribute, the applicable ordinary point-or-polygon decision is made for each plot. All contributing locations still need to be included.

A cooperative's combined mapped area therefore does not determine whether every member must provide polygons. Nor can its total area be represented by one perimeter enclosing all members and the land between them. Keep separate plot identities even where a technical file packages their geometries together for a convenient submission.

Borderline measurements need supporting evidence

Suppose a producer reports a plot as four hectares, while the supplied boundary calculates as approximately 4.3 hectares. This discrepancy should trigger a review. The difference may reflect a measurement method, a misunderstood unit, an incorrect boundary or inclusion of adjacent land. It should not be resolved by deleting the inconvenient measurement.

Ask for the source of the reported area, inspect the geometry and determine which evidence identifies the actual production unit. Record the result and the basis for the chosen format. If a new survey or corrected boundary establishes a larger plot, update the geometry requirement and consider any affected earlier assessment.

Area calculations should identify their method and units. Measuring degree coordinates as if they were metres can produce an invalid area, while confusing acres with hectares can change the threshold conclusion. Have a suitably informed reviewer resolve such discrepancies and retain the original figures so the correction can be understood later.

A polygon must follow the perimeter

Meeting the polygon requirement is more than changing the geometry label. The coordinates need to describe the relevant perimeter faithfully. A triangle around the approximate centre of a large plantation does not become an adequate production boundary simply because the file is syntactically a Polygon.

The point-versus-polygon comparison explains what each representation communicates. Use enough vertices to follow the material boundary features. Avoid including unrelated forest or neighbouring farms merely because a coarse outline is easier to draw. The file should make the assessed area understandable to someone who did not collect the coordinates.

Cattle and primary operators require separate treatment

The greater-than-four-hectares clause expressly excludes cattle. Their information requirement concerns all establishments where the animals were kept. A cattle establishment's size should not be used to impose the ordinary crop-plot polygon rule. Establishment coverage and traceability through the animal's history remain essential.

Article 4a(5) also provides a postal-address alternative for qualifying micro or small primary operators. That narrow category has its own eligibility criteria. A small importer or a large cooperative cannot infer an address-based exemption from the size of the individual farmers it purchases from. Determine the applicable regime rather than treating every small supplier as interchangeable.

Check the exported geometry, not only the map

The Commission's current GeoJSON description uses WGS 84 decimal degrees with longitude first. Polygon rings need to close correctly, and unsupported shapes must be handled according to the actual system specifications. A local mapping application can display a geometry that fails the destination system's checks.

Keep the source boundary and the export separately. If a geometry is simplified for compatibility, verify that it still describes the production plot adequately. Do not remove a relevant area simply to eliminate a technical error. Have a person familiar with the land evidence review material shape changes before the resulting file supports a release decision.

Review the requirement when the plot changes

Expansion, subdivision or a corrected area measurement can change the appropriate representation. A point originally used for a genuine three-hectare production plot should not follow an expanded six-hectare plot without review. Link each geometry version to the production period and goods for which it was used.

The geolocation requirements pillar connects these format decisions to traceability and compliance evidence. The legal source is Articles 2(27), 2(28) and 9(1)(d), with the official GeoJSON specification governing the technical exchange. Document both the area conclusion and the reason the submitted geometry represents the actual production land.