Does a supplier from outside the EU refuse to provide the GPS coordinates of the plantation? Without them, the importer will not be able to submit a due diligence statement or place the goods on the EU market.
EUDR obligations from 30 December 2026
From 30 December 2026, large and medium sized entities placing coffee, cocoa, wood, rubber, soy, palm oil or cattle on the EU market will be required to submit due diligence statements through the EU information system.
Geolocation of every plot is required
The statement requires the geolocation of every plot of land from which the relevant commodity originates. The December amendment postponed the application date by one year, but it did not remove thisrequirement. Without the coordinates, there can be no statement, and without the statement, the goods cannot legally enter the EU market.
Why suppliers may refuse to provide the data
In practice, the absence of data may result from:
• reliance on trade secrecy; the Commission confirms that the absence of data means no access to the EU market,
• the belief that classification as a low risk country removes the GPS requirement; it simplifies the risk assessment, but not the collection of data,
• confusion between the exception for micro and small primary producers and the position of an importer.
How to prepare cooperation with suppliers
The standard approach should include EUDR clauses in purchasing agreements, clear communication to the supplier regarding the required scope of data and a backup plan involving alternative sources of supply.
Conclusions
What else will change before December 2026, and how should cooperation with suppliers be structured before a refusal to provide data becomes a customs problem?
We support importers and operators in preparing EUDR procedures, verifying the scope of required data and drafting appropriate contractual provisions for suppliers. We also help assess the risks associated with missing geolocation data and prepare alternative solutions before the new obligations begin to apply.
We bring together in one place the legal developments that matter most to businesses: updates on legislative changes, practical commentary and guidance. We also offer a behind-the-scenes look at our work, sharing the matters we are involved in and where you can meet us.
