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EUDR & compliance 3 min read17 August 2026

The 31 December 2020 Cut-Off and What a Satellite Alert Actually Means

Short answer

The cut-off is about the land, not your paperwork: goods must come from land that was not converted from forest after 31 December 2020. In practice this is checked by overlaying your plot polygons on public satellite forest-change data. An alert on your polygon means tree cover was lost there — which may be legal harvesting of a plantation, a storm, a road, or genuine deforestation. The regulation does not treat satellite maps as legally conclusive; they support the risk assessment. Your job is to explain what happened, with evidence.

The 31 December 2020 Cut-Off and What a Satellite Alert Actually Means

Harvesting a plantation is not deforestation

This is the single most common panic. An acacia or eucalyptus plantation is harvested on a cycle and replanted. Satellite data sees the tree cover disappear and raises an alert. Under EUDR that is not deforestation, because the land remains forest land in use — what matters is conversion of forest to another land use.

What clears the alert is evidence: the harvest permit, the replanting record, the plantation establishment year. Have these ready before the buyer asks and an alert becomes a two-email conversation instead of a cancelled order.

Why the date matters more than the documents

A plot converted from natural forest to plantation in 2019 is compliant. The identical conversion in 2022 is not, and no Vietnamese permit changes that — the permit makes it legal under Vietnamese law, which is a separate requirement, but EUDR asks both questions and you have to pass both.

Screen early, not thoroughly

The cost of an alert depends entirely on when you find it. Before you sign a supply contract, a problem plot costs you one source and an afternoon. After the container has sailed, it costs you the shipment, the buyer's trust and often the relationship. Run the check when you take a supplier on, not when the paperwork is due.

Screening is also cheap and repeatable, which the rest of the dossier is not. Coordinates plus public forest data gives you an answer in minutes, long before you spend money collecting documents for a plot that will not pass anyway.

Questions buyers ask about this

Which satellite data is official for EUDR?+

None is official in the sense of being legally binding. The EU points to observatory and Copernicus resources and states clearly that such maps support risk assessment rather than decide compliance. That cuts both ways: an alert does not condemn you, and a clean map does not absolve you.

Our plot shows an alert from a storm. What do we send?+

Anything contemporaneous: local authority damage reports, insurance claims, dated photographs, the replanting record afterwards. The point is to show the tree cover loss was not a conversion to another land use, and that the land is still forest land.

Can we just exclude any plot with an alert?+

You can, and for a small supplier it may be the cheapest route. But plantations generate alerts by design, so a blanket exclusion rule will eventually remove most of your legitimate supply base. Investigating is usually cheaper than replacing suppliers.

Does LELOI decide whether a plot passes?+

No. We run the screening, record what the data shows, and structure your explanation and evidence. The compliance decision belongs to the EU operator who files the statement and carries the liability. Any provider claiming to certify a plot as compliant is overstating what they can do.

Screen a plot against satellite data

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