1. Are there legal restrictions on transmitting GPS data internationally?
Yes! Compliance requires meeting both EU and exporting country regulations:
● EU Requirement: Submit 6-decimal GPS coordinates of production plots (polygon coordinates for plots >4ha). Data must be included in Due Diligence Statements (DDS), collected via mobile/GNSS devices.
● Exporting Country Requirement: Verify local data sovereignty laws. Non-sensitive data may require separate archiving and transmission approval records.
2. Do all commodities require traceability?
Yes, with exceptions focusing on EUDR-regulated commodities:
● 7 Key Commodities (timber, soy, palm oil, beef, cocoa, coffee, rubber): Full traceability to plots required. DDS submission is mandatory for customs clearance.
● Exempt Items: Non-regulated products (e.g., bamboo) and transport packaging are excluded but must meet production country laws + EU standards.
● Intra-EU Transactions: Downstream operators may reference prior DDS to reduce duplication.
3. How to handle bulk commodities and composite products?
Differentiated traceability approaches:
● Bulk Commodities (e.g., soy): Ensure all production plots are identifiable with no post-2020 deforestation. Mixing with non-compliant sources is prohibited.
● Composite Products (e.g., chocolate): Only trace regulated components (e.g., cocoa in chocolate). Non-compliant mixed batches are fully prohibited.
● Special Categories (e.g., wooden furniture): Trace all wooden components, including minor parts.
4. What if products are partially non-compliant?
No partial compliance allowed:
● Separable Components: Immediately isolate and block non-compliant portions.
● Irreparable Mixing: Entire batch is deemed non-compliant.
5. Is mass balance approach permitted?
No!
EUDR prohibits mixing compliant/non-compliant commodities through mass balance. Independent traceability systems must ensure batch-level segregation to deforestation-free plots.