Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
Under Article 9, operators must collect the geolocation of every plot of land where the commodity was produced; for soy, cocoa, coffee, palm oil, rubber and timber, plots of more than four hectares must be described with polygons (Article 9(1)(d) read with Article 2(28)). Cattle only require a single latitude and longitude coordinate per establishment, the premises where the animals were kept, regardless of the size of the operation. That satisfies the letter of the requirement, but a coordinate says nothing about how much grazing land surrounds it. For operators sourcing cattle from countries not classified as low risk under the EUDR benchmarking system, the gap between compliant data and sufficient evidence is where the real due diligence work sits.
Under the EU Deforestation Regulation, cattle is treated differently from every other commodity in scope. For soy, cocoa, coffee, palm oil, rubber and timber, larger plots have to be described as polygons. For cattle, a single latitude and longitude per establishment is enough.
That makes compliance straightforward. It does not make the underlying question answerable. And for anyone importing cattle products from a country that is not benchmarked as low risk, the difference between those two things is where the real work sits.
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What the EUDR geolocation requirement actually asks for
Article 9 requires operators to collect the geolocation of all plots of land where the relevant commodity was produced. For cattle, it requires the geolocation of all establishments where the animals were kept.
The term “establishment” is borrowed from EU animal health law, where it covers premises, structures, and – in the case of open-air farming – any environment or place in which animals are kept.
Two things follow from that wording.
First, the obligation is not one location. It covers every establishment across the animal’s life: where it was born, where it was fed, where it grazed, and the slaughterhouse. Cattle move, sometimes several times, and each stop is part of the record. There is no exception to that chain.
Second, cattle establishments never require polygons, whatever their size. The Commission’s guidance on traceability and geolocation is explicit that the four-hectare polygon threshold applies to commodities other than cattle. One coordinate pair per establishment, expressed to at least six decimal places, satisfies the requirement – whatever the size of the property and whatever the risk classification of the country.
That is the compliance answer. Here is the practical one.
Why a coordinate point isn't the same as a boundary
A coordinate tells you that a place exists. It tells you nothing about how large that place is or where it ends.
The point will usually land on a farmyard or a registered address. The grazing land associated with that establishment might run to thousands of hectares in one direction. It might be a smallholding of a few. It might sit under grazing rights on land some distance from the address on file. You cannot infer extent from a point, and you cannot draw a circle around it and treat the result as pasture, because you would be inventing a shape and then assessing the shape you invented.
Pasture is precisely where cattle-driven deforestation happens. Forest is cleared to make grass. If your geospatial analysis is anchored to a dot on the homestead, you are examining the one part of the operation that was almost certainly never forest to begin with.
Where the geolocation gap becomes an operational problem
Country benchmarking is what turns this from a curiosity into an operational problem.
If all your relevant commodities come from countries classified as low risk and the risk of circumvention or of mixing with products from other countries is negligible, Article 13 lets you apply simplified due diligence. You still collect the full set of Article 9 information, including every establishment coordinate. What you are relieved of is the full risk assessment under Article 10 and the mitigation measures under Article 11. Points are sufficient in that setting – not because they are informative, but because you are not being asked to reach a substantive conclusion about the land.
If you source from a standard or high risk country, Article 10 applies in full. You have to assess risk against criteria that include the presence of forest in the area of production, land use, and the presence of indigenous peoples. You have to conclude that the risk of non-compliance is negligible. And you have to be able to show a competent authority how you got there.
This is the bind. The data your supplier is obliged to give you is not sufficient for the assessment you are obliged to perform. Neither the regulation, nor the FAQ, nor the guidance documents resolve that tension. It is left to operators to close.
Legality and land rights compound the geolocation gap
Deforestation is only one of the three conditions in Article 3; the product must also be covered by a due diligence statement (or a simplified declaration). Another condition is that the commodity must have been produced in accordance with the relevant legislation of the country of production – a definition that reaches land use rights, environmental protection, the rights of third parties, and human rights protected under international law, including the principle of free, prior and informed consent as set out in the UN Declaration on the Rights of Indigenous Peoples.
Whether grazing land encroaches on indigenous or community territory is a question about one boundary meeting another. Testing a single coordinate against a titled or claimed area answers nothing. It is the same analytical failure as the deforestation question, in a domain where the consequences fall on people rather than on tree cover.
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What operators can reasonably do about EUDR cattle geolocation
The useful move is to separate two things clearly.
What your supplier is required to provide: a point per establishment, covering the full life of the animal.
What you need in order to discharge your own obligation: the extent of the grazing and pasture land, wherever country benchmarking does not already do the work for you.
Asking suppliers in non-low-risk origins for polygons of grazing areas is not a regulatory requirement, and it should not be presented as one. It is a commercial and evidentiary request – and a reasonable one, because you are the party who has to stand behind a negligible-risk conclusion and defend it later.
Build it into supplier onboarding and contracts early rather than at the point of filing. Expect uneven data quality. And treat a supplier who genuinely cannot describe their own pasture boundaries as having told you something useful about risk.
Frequently asked questions
Operators must collect the geolocation of every establishment where the animals were kept across their full life - birth, feeding, grazing, and slaughter. A single coordinate pair per establishment, expressed to at least six decimal places, is enough: cattle establishments never require a polygon. For other commodities, plots of up to four hectares can also be described with a single point; larger plots need a polygon.
The Commission's guidance on traceability and geolocation explicitly limits the four-hectare polygon threshold to commodities other than cattle. A single coordinate satisfies Article 9 for cattle regardless of the size of the establishment.
No - the geolocation data collected is the same regardless of country risk classification. What changes is what you have to do with it: where all commodities come from low-risk countries and the risk of circumvention or mixing is negligible, Article 13 lets operators skip the full risk assessment (Article 10) and mitigation measures (Article 11), but the same establishment coordinates still have to be collected.
No. A coordinate indicates a location, not an area - the actual grazing land could extend in any direction and to any size. Treating an assumed radius as pasture boundary data means assessing a shape you invented rather than the land actually in question.
Yes. Article 3 requires legality as well as deforestation-free status, which includes land use rights and human rights protections such as free, prior and informed consent for indigenous peoples. A single coordinate is equally insufficient for assessing land rights as it is for assessing deforestation risk.
At Trusty, this is one of the questions our clients bring to us most often, and it is one the EUDR Passport is built to help them work through. If you are sourcing cattle products from origins where a coordinate will not carry your risk assessment, we are happy to talk it over.
Sources: Regulation (EU) 2023/1115 (EUDR), Articles 3, 9, 10, 11, and 13; European Commission Guidance Document on EUDR traceability and geolocation; UN Declaration on the Rights of Indigenous Peoples.
Related reading: how the EUDR country risk classification works, whether you are an operator or a trader, and which products fall within EUDR scope.
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