💡 Explanation · For suppliers who answer a Product Origin Request with geolocation data and want to understand why only the plots that supplied the product belong in the answer.
⚠️ Important: Declaring every plot you know of, instead of the plots that actually supplied the product, does not make your answer safer. It goes against the traceability the EU Deforestation Regulation (EUDR) requires, and a single problem plot will block your customer's entire Product Origin Request.
When you answer a Product Origin Request, it can seem safer to list every plot in your sourcing area, just in case. This article explains why the EU sees it differently, in which narrow cases declaring extra plots is allowed, and what over-declaring costs you and your customer.
What the EUDR expects: strict traceability
The EUDR is built on one principle: every product must be traceable to the plots of land where its commodity was produced. Article 9 requires the geolocation of all plots that contributed to the product. The European Commission reads this as strict traceability: the plots in the statement should be the plots the product came from. Its FAQ states that the regulation requires "a correspondence" between the product placed on the market and the plots where it was effectively produced.
A Due Diligence Statement (DDS) states that the product is deforestation-free and legally produced. That can only be checked if the plots in the DDS are the plots the product came from. If the geolocation of all contributing plots cannot be collected, the product may not be placed on the EU market at all. Adding extra plots does not close that gap.
When declaring extra plots is allowed
The Commission calls this a "declaration in excess" and accepts it in two cases only:
Bulk commodities that are fully traced. The commodity is traced to its plots, but it is mixed during storage, transport or processing, for example in a silo, on a ship or in a mill. When only part of that mixed lot is sold, you may declare all the plots that fed the lot.
Crop rotation on one farm. For example, soy is grown each year on a different part of the same farm's arable land.
Even in these cases, the Commission expects the traceability data to be as granular as possible.
Declaring plots on a regional or country-wide basis is not one of these cases. The Commission states that such practices are generally not in line with the regulation: they would not allow operators to comply with their core due diligence obligations, and they make the checks of the competent authorities difficult or even impossible. Listing every plot you have ever sourced from runs into the same problem.
What over-declaring puts at risk
Every declared plot becomes a liability
Usually your customer, as the Upstream Operator, files the DDS with the plots you provide. Whoever files a DDS with extra plots takes full responsibility for every plot in it, including the plots that did not supply the product. The Commission is explicit: if one declared plot is not compliant, the whole set of declared plots is not compliant, and full due diligence is required on every one of them.
In practice, the more plots you declare, the more chances there are that one of them shows forest loss after 31 December 2020 or a legality concern.
One plot will block the whole request in Prewave
Your customer's checks run on every plot you provide. In Prewave, an origin takes the result of its weakest plot, and a Product Origin Request takes the result of its weakest origin. One Non-negligible plot that never supplied the product is enough to make its origin Non-negligible and block the Due Diligence Statement for the entire Product Origin Request.
Your customer then has to investigate a plot that has nothing to do with the goods, and this means work for you as well. You will be asked to provide further information and to contribute to the investigation, and trade is on hold until it is resolved, which can take a long time. A halt like this can put your relationship with your customer at risk.
Mixing with unknown origin is not allowed
Over-declaring can also point to a different problem: goods of known and unknown origin mixed together. The EUDR does not allow mass balance, where compliant goods are mixed with goods of unknown origin at any step. Declaring the origin of an amount equal to what was sold, for example from a silo, is not allowed either. If non-compliant goods are mixed in and cannot be separated, the whole batch is non-compliant. The Commission's example is a bulk batch linked to several hundred plots: one plot deforested after 2020 makes the entire batch non-compliant.
Your customers will notice
A long list of plots that cannot all have supplied one product is a warning sign in your customer's own risk assessment. Your customer may come back with follow-up questions or remove origins from its due diligence, which delays the import or transaction process.
What good practice looks like
Declare the plots that supplied the products in the request. Declare more only in one of the two cases above, and then every extra plot must meet every EUDR requirement. If you do not know which plots supplied a product, forward the request to your own supplier or producer, who holds that information.
To provide origin information, check this article: Step-by-Step Guide | Product Origin Request
To find the geolocation of your plots, check this article: Finding geolocations outside of Prewave