compliance
EUDR Geolocation: Polygons, GPS Points and the 4-Hectare Rule
Geolocation is the part of EUDR compliance that has to happen on the ground, at origin, before anything can be filed. It is also the part most exporters have not started.
Of everything the EU Deforestation Regulation asks for, geolocation is the item that cannot be produced retrospectively from an office. Someone has to walk the boundary, or fly it, or trace it accurately from imagery — and then keep the result current as blocks are replanted and plots change hands.
The rule
Every plot of land on which the coffee was produced must be identified by geographic coordinates.
| Plot size | What is required |
|---|---|
| More than 4 hectares | A polygon — at least six coordinate points describing the plot boundary |
| 4 hectares or less | A single GPS point — latitude and longitude |
The threshold is per plot, not per farm. An estate of 60 hectares divided into blocks does not get to submit one point because each block is small; the relevant unit is the parcel of land the commodity was produced on, and how that is drawn matters. Ask the exporter how they have defined a plot.
Which plots
Only the plots that produced the coffee in the lot you are buying.
This sounds obvious and is where most of the practical difficulty lives. If an exporter offers you a lot assembled from twelve farms, you need coordinates for twelve farms. If they offer you a single-estate lot from four named blocks, you need those four blocks — not the estate's outer boundary, which would include the house, the roads and any land not under coffee.
A supplier who sends the outer boundary of the whole property when the lot came from three blocks has given you something that is technically a polygon and practically not an answer.
Formats
The regulation does not mandate a file format, and the EU information system accepts a defined structure rather than any particular file extension. In practice, ask for one of:
- GeoJSON — the most portable, and what most traceability platforms ingest.
- KML / KMZ — what most GPS and mapping apps export natively.
- Shapefile — common with agronomists and GIS consultants.
- A coordinate list — latitude and longitude in decimal degrees, WGS 84, with the plot identifier and area alongside.
Whatever arrives, check three things: that the coordinate reference system is stated, that polygons are closed, and that the stated area roughly matches the drawn area. A polygon whose area is 2 hectares attached to a plot described as 9 hectares is a mapping error, and it is better to find it before you file a statement that depends on it.
Checking what you receive
You do not need a GIS department to sanity-check a geolocation pack.
- Plot it. Load the file into any free mapping tool and look at it. Boundaries should follow terrain, not perfect rectangles, unless the land genuinely is rectangular.
- Compare with imagery. Historical satellite imagery is publicly available. Look at the plot in 2020 and look at it now. For a shade-grown farm you should see mature canopy in both.
- Check the area. Compare the polygon's computed area with the area the supplier states.
- Check it is not the office. More common than it should be: a point that resolves to the exporter's town address rather than the farm.
Why shade-grown origins have an easier case
The deforestation test is about land-use change after 31 December 2020. Farms carrying a mature multi-tier canopy present a straightforward case: the tree cover visible in imagery from before the cut-off is the same tree cover standing now, because the coffee grows underneath it rather than in place of it.
That is not a claim about virtue. It is a claim about evidence, and it is the reason an agroforestry origin is usually a shorter risk assessment than a recently expanded sun-grown one.
Smallholder lots
Around 80% of the world's roughly 25 million coffee farmers are smallholders, and mapping millions of sub-hectare plots is the central practical problem with this regulation. Most smallholder plots fall under the 4-hectare threshold, so a single point suffices — but somebody still has to collect 3,000 points for a 3,000-farmer cooperative, keep them linked to deliveries, and keep them current.
If you buy smallholder coffee, ask who collected the points, when, and how the link between a point and a delivery is maintained. If the answer is vague, the risk assessment is yours to carry.
What to send your supplier
For each lot, we need geolocation for the plots that produced it — polygons of at least six points for plots above 4 hectares, single points below — in GeoJSON or KML, in WGS 84, with a plot identifier and stated area for each. Farm outer boundaries are not sufficient where the lot came from specific blocks. We need this with the pre-shipment sample, not with the invoice.
Where Hoysala stands
Hoysala is a single contiguous estate in Chikmagalur, farmed in blocks between 900 m and 1,450 m under a two-tier canopy that long predates the 2020 cut-off, and it cures and grades its own coffee — so the chain from a block to a bagged lot is short.
The wider picture, including who files what and by when, is in EUDR for coffee, and the full supplier checklist is in EUDR at origin.
A working summary for buyers, not legal advice.