Five ways Trase can and cannot support the EU deforestation regulation

From 30 December 2024, the European Union deforestation regulation (EUDR) comes into effect. Trase has received a large number of questions from companies, governments and civil society on how we can support efforts to implement this regulation. While Trase's freely available data provides a crucially important bird's eye view of the subnational sourcing patterns and deforestation exposure of entire export markets for key forest-risk commodities, Trase is not designed to meet all the varied needs that the regulation brings. This article aims to clarify what Trase can and cannot do to help with the EUDR for different stakeholders.

1. Trase can be used to inform risk-based plans to target enforcement checks by competent authorities

Under the EUDR, competent authorities of EU member states need to develop risk-based plans to identify the checks on commodity imports that they will carry out. The regulation sets out the different risk criteria for non-compliance that they should use, and it allows them to use data from the EUDR’s Information System as well as other relevant sources such as monitoring data, or risk profiles from international organisations. These risk criteria include aspects such as the complexity and length of the supply chain, the risk of mixing, and the presence of forests and deforestation. With budgets tight, using open data from multiple sources – even if not fully aligned with the EUDR – can play an important role in supporting a risk-based approach to enforcement that will increase the robustness of the regulation.

Trase is one such open dataset that can enable competent authorities to triage risk. This includes subnational risk benchmarking of commodity deforestation for risk profiling operators that supply EU member states and for risk profiling ports of export based on their likely sourcing patterns, as shown in Trase’s work for the French government. This information enables competent authorities to develop risk-based plans that can target shipments from higher risk operators, higher risk ports of export, and where plots of land are in high-risk subnational regions. Trase data shows that risks are often highly concentrated in a few production regions. Using subnational data can help target the relatively small percentage of checks on the highest risk products.

2. Trase can be used to evaluate the impact of the regulation and provide evidence for planned reviews

Reviews of the EUDR will include its possible extension beyond forests to other natural ecosystems, and the coverage of more products and new commodities. Trase data can be used to provide an important part of the evidence needed for these reviews. This includes data on the EU’s subnational sourcing patterns for key commodities and its exposure to conversion of different ecosystems. Trase data has already highlighted the EU’s exposure to the conversion of ‘other wooded land’ and native grasslands in South America, which are currently not covered by the EUDR. The new DeDuCE dataset developed at Chalmers University of Technology, a Trase science partner, can also support these crucially important reviews as it maps deforestation driven by the expansion of agriculture and forestry globally across all commodities and links these to trade and consumption by markets including the EU.

More broadly, these datasets are important inputs for analyses that will inform the EU’s first general review that will take place by June 2028, which encompasses an evaluation of the regulation’s impact on commodity deforestation, trade patterns, and farmers and smallholders. Trase’s systemic view of global trade will be critical to understanding the net effect of the regulation and any ‘leakage’ effects where deforestation shifts to other commodities, markets or ecosystems.

3. Trase cannot be used by operators and traders to demonstrate compliance in terms of traceability to plots of land

Companies need to provide the geolocation (as polygons or, in some specific cases, points) of the plots of land where commodities were produced. Trase data (with the exception of Indonesian pulp) maps subnational regions of production rather than individual farms or concessions, as this data is not publicly available at scale. Trase cannot therefore be used as a compliance tool to trace commodity production to plots of land under the EUDR.

Companies also need to demonstrate that the commodities they are selling or exporting to the EU have been sourced from plots of land which are compliant and have not been mixed with any commodities from non-compliant or unknown sources. This requires a sufficiently robust and credible traceability system that can ensure there is no risk of mixing or laundering.

While Trase maps the supply chain by bringing together lots of publicly available datasets, some of which are likely to be useful to evidence traceability such as cattle transit documents or supplier lists, Trase is not a traceability tool and does not map the individual transactions between producers, processors and traders.

4. Trase can be used by operators and traders as one source of evidence in the risk assessment step of the due diligence process (but other data sources would be needed)

Central to the due diligence process for operators and traders is to assess the risk that commodities being imported or sold in the EU do not comply with the requirement that they are deforestation-free and produced in accordance with the relevant legislation of the origin country. Only those assessed as posing no risk or only negligible risk can be placed on the market or exported.

The EUDR sets out fourteen criteria that should be included in the risk assessment. Trase can provide relevant information for criteria on “the prevalence of deforestation in the country of production or parts thereof”through its extensive data on subnational commodity deforestation. Although Trase’s definition of deforestation is not fully aligned with the EUDR (as we also include the conversion of other types of native vegetation where data is available), or with the end-of-2020 cut-off date, it can provide an excellent overview of subnational commodity deforestation exposure. This shows that deforestation is often highly concentrated in a minority of production regions, as is the case for Brazilian soy.

In some cases, Trase data can help companies understand at a high level the complexity of the relevant supply chain and the risks of mixing with non-compliant or unknown products (two other important risk criteria). For example, Trase data shows that 60% cocoa from the Côte d’Ivoire is indirectly sourced or of unknown origin. Work by Trase researchers has found similar issues across the soy, cattle, cocoa and palm oil supply chains.

5. Trase data can be used by civil society to help hold governments and companies accountable for effectively implementing the EUDR

Third parties are able to submit substantiated concerns to competent authorities about non-compliance of operators or traders, which the authorities are required to assess. Operators and traders who receive substantiated concerns should also investigate them and notify competent authorities where this information indicates that products already placed on the EU market are non-compliant.

While Trase data alone is unlikely to provide sufficient evidence of non-compliance as set out above, it can be used by civil society to identify high-risk shipments, ports, operators and sourcing regions where they can target investigations. This is especially the case in the absence of transparency on per-shipment import data by the EU and the lack of access for civil society to the EUDR Information System.

Trase will continue to support the effective implementation of the EUDR by investing in the enabling information environment. We welcome further questions and feedback on how we can help ensure its success. Please email us at info@trase.earth