how do I provide geolocation if my batch comes from multiple plots or countries

Geolocation for multiple plots or countries

For a mixed batch, you provide the geolocation of each plot from which the raw material originates, not a single average location for the entire batch. If the batch comes from multiple countries, you also split this in your submission by country: each plot belongs to the country where it is located, with the corresponding coordinates. In practice, this means that a batch of coffee coming partly from Uganda and partly from Ethiopia is substantiated with a list of plots per country, not with a single collection point that indicates "origin: East Africa".

How large this list becomes depends on the number of plots from which the batch is composed, and each plot has its own rules regarding the format of the geodata: a point may suffice for smaller plots, while larger plots must be provided as a polygon. On when a point suffices and when a polygon is needed this distinction is elaborated further. In practice, a mixed batch therefore mainly means more entries in the file, not a different type of data. Those who do not yet possess these data themselves but must obtain them via a supplier will find the approach for this under requesting geolocation from suppliers.

Where this follows from: Article 9 and Annex II

Regulation (EU) 2023/1115 requires in Article 9 the specification of the geographical location of all plots where the relevant raw material was produced, including the country of production; Annex II sets out which geolocation data belong to this, including the form (point or polygon) that applies per plot. The regulation itself does not provide for an exception or simplified submission for batches composed of multiple plots or countries — the obligation applies per plot, and a mixed batch is therefore a sum of plots, each with their own location data. For the exact text, Article 9 and Annex II of the regulation on EUR-Lex are the source to consult.