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What happens if your supplier's geolocation data is incorrect?

Incorrect or incomplete geolocation data undermines the core of your EUDR dossier. This article describes what happens in practice if that data turns out to be inaccurate and what you should watch out for.

If the geolocation data you received from your supplier turns out to be incorrect, it affects the foundation of your due diligence statement. The regulation requires the exact plots where a raw material was produced, and those plots form the core of the risk assessment you must conduct as a market participant. Incorrect coordinates mean that this assessment is based on wrong information, even if the rest of your dossier is in order.

What happens concretely depends on when the error comes to light. If you discover it yourself before submitting the statement, the usual course is: go back to the supplier, have the data corrected, and redo the risk assessment. If an error only emerges after a statement has already been submitted to the EU information system, that is more delicate, and it is advisable to discuss this with a lawyer or the competent supervisory authority.

Why coordinates are often more incorrect than expected

Geolocation data comes from far back in the supply chain and is not always measured by the supplier itself. In small-scale production, such as much coffee and cocoa cultivation, plots are sometimes recorded with a simple GPS app, with inaccuracy that can be tens of metres. In trade through multiple intermediaries, a coordinate can also simply be copied from the wrong plot, or belong to a harvest from an earlier season.

Moreover, suppliers use different formats: decimal degrees, degrees-minutes-seconds, or a polygon instead of a single point. Incorrect conversion between those formats produces a coordinate that looks valid but points to the wrong location. That is precisely why it is wise to not only collect the geodata you receive, but also verify it before it becomes part of a dossier.

What competent authorities can do in this regard

The regulation tasks competent authorities in the Member States with verifying on a sample basis whether the data in a statement matches the actual origin. In doing so, they may consult, among other things, satellite imagery and other geographical sources to verify whether a specified plot corresponds to what is actually being produced, and whether deforestation has occurred on or around that plot after the relevant date. How those checks are arranged in practice and with what intensity is a matter for the supervisory authorities themselves and falls outside what can be said with certainty here.

It is important to understand: an incorrect coordinate is not automatically equated with fraud or with a product that is not deforestation-free. It can just as easily be an administrative error that is quickly corrected upon inquiry. What matters is that you as a market participant can demonstrate that you have exercised the due diligence the regulation requires, and a dossier with traceable, substantiated data is part of that.

How you can limit this in practice

Most problems with geolocation data do not arise when submitting the statement, but much earlier: when requesting and recording the data from the supplier. Agreeing on a fixed format, asking about the measurement method and checking coordinates against a map on a sample basis prevents a large portion of errors before they end up in the dossier. Those managing multiple product streams at once will find that this goes faster with a set structure per supplier and per country of origin than with separate spreadsheets per shipment. In the knowledge base by topic the exact data required per raw material is set out and where common errors occur.

Because your own situation and the way you work with a supplier can vary greatly, a general checklist never tells the whole story. If you want to find out first which role and which obligation apply to your company before diving deeper into geolocation data, the role check provides a first indication in a few questions. Eudri.com structures and validates the data you provide and generates the declaration from it; how that process is set up in detail is explained on the page where the information comes from. We never declare ourselves that a product is deforestation-free: the risk assessment and responsibility for the accuracy of the data remain with you as an economic operator.

If you are uncertain whether the geolocation data in your file is complete and correct, that is a good time to have it reviewed before anything is submitted. Take the free role check or browse through the topics in the knowledge base to see which steps apply to your commodity and your role.

This article is general information and not legal advice.