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Guide

Europe's no-deforestation rule, in plain words.

Europe's no-deforestation rule (EUDR) says cocoa and rubber sold into the EU must come from land where forest was not cut after 31 December 2020. This page explains what that means for a Nigerian exporter, buying agent or cooperative. It is not legal advice.

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The short version

  • The date that counts is 31 December 2020. Land where forest was cut after that day cannot supply cocoa or rubber to the EU.
  • The EU buyer files the EU form. You, the Nigerian supplier, give that buyer proof: where each plot is, that no forest was cut there after 2020, and that bags from clean plots were kept apart.
  • Nigeria is standard risk. Buyers must run the full risk check on every shipment. That is more work than for Ghana or Togo, and it is why buyers ask suppliers for more.
  • Satellite maps help but do not decide. They are often wrong over shaded cocoa and rubber, so a person must look at every Check, and at every farm where the maps and the photos tell different stories.

The dates

WhoMust follow the rule from
Large and medium EU buyers30 December 2026
Micro and small EU buyers30 June 2027
The date that counts for land31 December 2020

The EU delayed the rule twice. A review in May 2026 left both dates as they are. A further change would need a new EU law. Cocoa and rubber were not covered by the EU's older timber law, so no earlier date applies to them.

Who must do what

  • The EU buyer (the law calls it the operator). The first company in the EU that receives the goods is treated as the operator. It collects the information, runs the risk check, takes steps against any risk, and files the EU form in the EU Information System, the EU's online system where the form is filed. It keeps the records for five years.
  • You, the Nigerian supplier. The law puts no direct duty on you, but your buyer is responsible for what you tell them. They need the plot locations and the proof, and they must be able to show the locations are correct.
  • Companies further down the chain (for example a chocolate maker) keep the reference numbers of the forms and the names of suppliers and customers.
  • A lighter "simplified declaration" exists for small farmers selling their own crop, but only in low-risk countries. Nigeria is not one, so it does not apply to Nigerian producers.

What the EU form needs

The EU form is called the due diligence statement. For a shipment it asks the EU buyer for:

  1. Their name, address and EORI number (the EU customs number).
  2. The product code (1801 for cocoa beans, 4001 for natural rubber), a short description, and the net weight in kilograms.
  3. The country where the goods were grown, and the location of every plot they came from.
  4. A statement that the buyer did the due diligence and found no, or only a negligible, risk.
  5. A signature.

Behind the form, the buyer must keep the dates or season the crop was harvested, the names and addresses of suppliers and customers, proof that the goods are free of forest cut after 2020, and proof they were produced legally. When the EU system accepts the form it gives a reference number (up to 14 characters) and a verification number. The next company in the chain uses those two.

The farm location file

Plot locations go to the EU system as a GeoJSON file (the farm location file). These rules are checked when it is uploaded.

  • Plots over 4 hectares need a farm edge. Plots of 4 hectares or less can be one point or a farm edge. One hectare is 100 metres by 100 metres, about 2.5 acres.
  • Six decimals for latitude and longitude, in the WGS84 system, with longitude first. The EU system cuts extra digits rather than rounding, which can turn a good farm edge into a bad one, so the file should be cut and checked before it is sent.
  • A clean farm edge: the line closes on itself, does not cross itself, has no holes, and is not a straight line. A line with no area is refused.
  • Exact property names: ProducerName, ProducerCountry ("NG"), ProductionPlace and Area. Area is a number in hectares, not text.
  • Under 25 MB for one form. Small plots as single points and thin straight edges keep the file small.

Forestline builds this file for you and runs 16 error checks before it writes it. If a plot would break the file, it tells you which plot.

What counts as forest

  • Forest is land of more than half a hectare with trees taller than 5 metres covering more than a tenth of the ground, that is not used for farming or towns.
  • Deforestation means forest turned into farm land. Fire or storm followed by farming counts too.
  • Cocoa farms, cocoa under shade trees and rubber plantations are farm land, not forest. The law calls them agricultural plantations.
  • The test is not "are there trees?" It is "was there forest here on 31 December 2020, and was it cut to make this farm?" Cutting forest to plant rubber or cocoa is deforestation. Cutting old rubber and replanting it is not.

Why the EU forest map can be wrong

The EU Joint Research Centre publishes a Global Forest Cover 2020 map that many buyers use. The EU says plainly that this map is optional and not legally binding, and that land marked forest on it is not automatically a breach. It is a flag for a closer look.

Researchers at the Joint Research Centre found the map is about 91% accurate overall, but about 1 in 4 of its forest calls in Africa (24.6%, plus or minus 3.1) are false, mostly where shade trees grow over cocoa or coffee, or where there are rubber and oil palm plantations. Hansen's University of Maryland record of tree loss has its own limits: it shows trees lost, not forest cut. So Forestline uses several records together, shows its working, and has a person review every Check.

Nigeria is standard risk

The EU sorts countries into low, standard and high risk. Nigeria is in none of the lists, which makes it standard risk. For an EU buyer this means:

  • The full risk check and the steps to deal with any risk are needed for every shipment. The lighter process for low-risk countries is not allowed.
  • Each year, authorities must check at least 3% of the buyers who handle goods from standard-risk countries.
  • Ghana and Togo are low risk. Buyers can use the lighter process for them, so Nigerian cocoa competes against cocoa that is cheaper for the buyer to document.

The EU says the list can change after reviews. No change for Nigeria has been published.

Four decisions before a handoff

Forestline keeps four decisions apart, because one does not stand in for another. A Clear result is not a review. A review is not traceability. And none of the three is a person's approval of the handoff.

  1. Satellite check. Forestline reads the EU 2020 forest map, the forest loss record, alerts and satellite photos. The answer is Clear, Check or Stop. It is a screening result. It does not clear a farm on its own.
  2. A person's review. A person reads the evidence and accepts or rejects the farm. They write what they found and why. When the maps say no forest was cut but Forestline AI sees forest cut in the photos, the farm is a Check, never Clear.
  3. Traceability. Each bag in a lot traces to a farm that is Clear or accepted on review. Lots are kept apart. The weights of the bags, the lots and the shipment add up, and the farm location file covers every kilogram.
  4. Shipment approval. The owner or a manager approves the handoff to the EU buyer, with a note. Approval is kept as a record. If the evidence changes after that, the shipment goes back to waiting for approval.

Goods that were mixed in the store stay mixed. Taking a problem farm out of the farm location file does not make mixed bags fit for the EU, and the file must cover every kilogram in the shipment. When the weights do not add up, Forestline blocks the shipment and says why.

The EU form draft is a draft. For goods coming in from Nigeria the EU buyer files an import statement. Forestline checks its own file against the EU rules it knows. That is not an answer from the EU Information System, which has the last word.

Keeping bags apart

The EU does not allow mixing by weight ("mass balance"). Bags from Clear plots must be kept apart from bags of unknown origin or from plots that are not Clear, at every step from the buying post to the ship. One bad plot in a mixed lot makes the whole lot unfit. You do not need to follow every bag to one farm, but you must know which plots could be in it.

The goods must also be produced in line with the laws of the country where they are grown. The law lists eight areas. The buyer needs proof for each:

  1. The right to use the land (certificate of occupancy, family land, a lease).
  2. Environmental protection, which includes not farming inside a protected forest.
  3. Forest-related rules, where they concern cutting wood.
  4. The rights of other people on the land.
  5. Labour rights.
  6. Human rights.
  7. The right of local communities to agree before their land is used.
  8. Tax, anti-corruption, trade and customs rules.

The proof must be real and checkable. The buyer has to take the risk of corruption and false papers into account.

Penalties

EU countries set the penalties, but the law says they must include:

  • Fines with a highest amount of at least 4% of the company's yearly turnover in the EU.
  • Confiscation of the goods and of the money made from them.
  • Up to 12 months out of public funding and public contracts.
  • A temporary ban on selling or exporting the goods, for serious or repeated breaches.

These fall on the EU buyer. That is why the buyer asks you for proof.

What EU buyers ask for

No large cocoa or rubber buyer has published its supplier questionnaire. This list is drawn from the law, from certification schemes such as Rainforest Alliance and from trade guidance, so treat it as what to expect:

  1. A file of every plot behind the shipment: farm edges for plots over 4 hectares, six decimals.
  2. The farmer, village, state, and the cooperative, buying agent or processor the bags passed through.
  3. The harvest season and the weight from each plot, tied to the lot. Buyers use yields to catch overselling.
  4. The link from lot to plot, and proof bags were kept apart.
  5. The deforestation check: which records were used, when, the result, and what was done about flagged plots.
  6. Proof the farm is legal.
  7. Names and contacts of suppliers and customers, the exporter's EORI number, the product code and net weight.
  8. A signed declaration from you, and the right to audit.

Where the rule is unclear

  • Which rubber products stay in scope. Some rubber goods, such as conveyor belts and other rubber articles, are being removed from the law. Natural rubber in primary form (product code 4001) is the core product and stays.
  • Whether the law's mention of forest degradation applies to cocoa and rubber. The definition of deforestation-free for these crops rests on deforestation.
  • Exact guidance from the EU buyer's side. Each buyer reads the law its own way.

Sources

Forestline gathers and checks evidence. It does not file the EU form and does not tell you that your goods may enter the EU. Ask a lawyer or your EU buyer about your own case.