my supplier refuses to share plots – what should I do

Without geolocation data, no due diligence declaration

Without geodata from the parcels where the raw material comes from, no valid due diligence declaration can be drawn up — and without that declaration, the product cannot be placed on or traded in the EU market. The geolocation data of each parcel where the raw material was produced form a mandatory part of the information that a market participant must collect. A supplier who refuses to share that data effectively blocks the entire process: there is then no basis to carry out the risk assessment, let alone to complete it.

In practice, this means that alternatives must be sought: the conversation with the supplier about why this data is needed and what will and will not be done with it, another link in the supply chain that can provide the information, or ultimately a different supplier. How best to structure such a request — what exactly is asked and in what form — is described in the guide to requesting geolocation data from a supplier. For companies that also produce raw material themselves and therefore must provide their own parcels, the same obligation applies in mirror image; that part of the story is covered in the requirements for geolocation data of your own parcels.

Where this derives from: Article 9 and the definition of due diligence

This obligation stems from Regulation (EU) 2023/1115, in which Article 9 lists the information a market participant must collect before a product is placed on the market, including the geolocation of all production parcels as a fixed component. The regulation links that information collection directly to the due diligence obligation: without complete information, no due diligence declaration can be submitted to the EU information system for the deforestation regulation. For the exact text and the exceptions mentioned by the regulation, the full regulation can be consulted on EUR-Lex.