Plantation Evidence Under EUDR sets out how plot level satellite evidence supports due diligence under the European Union Deforestation Regulation: what a plot was at the 31 December 2020 cut-off, what has changed inside it since, and what replaced the canopy where it did. The paper is written for compliance platforms, traders and processors filing due diligence statements, the producers who document their plantations, and the auditors who read the evidence.
Regulatory Background
The Regulation requires that commodities placed on the Union market be deforestation-free with reference to 31 December 2020, and that operators document how that was established for every plot of production.
- Large and medium operators: obligations apply from 30 December 2026.
- Micro and small enterprises: obligations apply from 30 June 2027.
- Penalties: up to four per cent of Union wide annual turnover.
The Regulation does not name satellite imagery. Its standard is adequately conclusive and verifiable information, and the Commission describes its own forest map as non-exclusive, non-mandatory and carrying no legal value. The burden of documentation sits with the operator, and plot level evidence fills that gap.
Reference Map Overlap
Global forest baselines classify mature plantations as tree cover. The paper documents the scale of the overlap:
- The Union’s global forest baseline classifies 31 per cent of rubber as forest, the highest overlap of any regulated commodity, against 7 per cent for oil palm and 6 per cent for cocoa.
- Its peer review reports an 18 per cent commission error and states that co-location with mapped forest does not by itself indicate non-compliance.
- An assessment of 21 global forest maps found two meeting all of the Regulation’s indicators.
- In one Mexican test, 75 per cent of 600 smallholder coffee plots established decades before the cut-off were flagged, because agroforestry reads as forest from above.
Rubber is felled and replanted on a 25 to 35 year cycle and drops its leaves every dry season. Neither is deforestation under the Regulation, which excludes land predominantly under agricultural use from its definition of forest. Both trigger tree-cover-loss alerts.
Method
- Cut-off State: the plot’s condition at the cut-off is established from the archive record that existed at the cut-off.
- Pixel Quality: archive reflectance is filtered per pixel using each mission’s own quality layers.
- Spectral Fractions: season matched dry window composites are resolved into green vegetation, non-photosynthetic vegetation, soil and shade by spectral mixture analysis against published generic endmembers.
- Change Detection: change between two dates is thresholded from the scene pair’s own scatter, and every change figure is quoted beside the area that noise alone produces at that threshold.
Spectral fractions identify what replaced a canopy. Felled stems and slash on the ground read differently from bare soil, separating a working estate on its rotation from a clearance.
Worked Example
The paper applies the method to a rubber estate on the Ivorian coast.
- Three years before the cut-off: change over the estate sits at the level noise alone produces at the same threshold, establishing no conversion.
- Five years since the cut-off: roughly a tenth of the estate has been opened, and the fractions show felled stems and slash far more than bare soil, consistent with a 25 to 35 year rotation.
- Seasonal monitoring: dry season leaf-fall lowers readings from December to March. Comparing each month against the same season a year earlier separates leaf-fall from felling.
Read the Paper
Plantation Evidence Under EUDR is 29 pages and covers the regulatory background, the method, the worked example, the validation design, the operational scope and the platform. It is available on its paper page and archived with a DOI: https://doi.org/10.5281/zenodo.22670550.