Can You Rely on a Government Traceability System for EUDR Due Diligence? A Country-by-Country Assessment

Your supplier sends over a certificate from the national government registry. "Everything's covered," they say. "The system has our farm coordinates, our licence, our registration number." It's a reasonable thing to say - and it's not wrong. But it doesn't answer the question you actually need to answer before you file your Due Diligence Statement.

This post works through that question country by country: what each major producer-country system actually contains, what it was built to do, and where your own compliance file has to pick up.

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The Legal Starting Point: The Obligation Stays With You

Before assessing any national system, one point needs to be stated plainly. Under Regulation (EU) 2023/1115, operators must exercise due diligence in accordance with Article 8 prior to placing relevant products on the market or exporting them. That duty does not transfer to a third party - not a certification body, not a private platform, and not a government registry.

The regulation is explicit: any operator referring to a due diligence statement already submitted retains responsibility for the compliance of the relevant products with Article 3, including that no or only a negligible risk was found. The same logic applies to information sources. A government system can be a valuable input under Article 9 (information collection). It cannot substitute for the risk assessment under Article 10 or the mitigation measures under Article 11. Those steps remain yours.

This mirrors the Commission's position on certification schemes: useful evidence, never a complete substitute for operator-level due diligence. Competent authorities will check whether you evaluated the system - not whether you deferred to it.

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Four Tests to Apply to Any National System

Before you decide how much weight to give a government registry, run it through these four questions.

1. Does it produce plot-level geolocation in the form EUDR requires? The regulation needs a point coordinate (latitude/longitude) for plots under 4 hectares, and a polygon for larger plots. A licence number, a district code, or a village-level reference does not meet this requirement. Check whether the system outputs actual coordinates - and whether those coordinates are linked to the specific consignment you are sourcing.

2. Does it carry a land-cover baseline usable against the 31 December 2020 cut-off? Most national systems were designed for licensing, extension services, or tax purposes - not to record the state of land cover on a specific historical date. A registration record tells you a farm exists and is licensed. It does not, by itself, tell you whether that land was forested on 31 December 2020. These are different questions, and the EUDR asks the second one.

3. Can you extract the underlying data per consignment, in a form you can retain? Operators must keep all documentation related to due diligence for at least five years and make it available to competent authorities upon request. A portal screenshot or a summary attestation is not the same as a retained, exportable data record tied to a specific shipment. Ask whether you can pull raw data - coordinates, registration dates, licence status - and keep it in your own system.

4. Does it cover legality as well as location? Article 3(b) requires that products were produced in accordance with the relevant legislation of the country of production. Geolocation alone does not satisfy this. Does the system record land tenure status, environmental permits, and labour law compliance - or only farm coordinates?

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Country-by-Country Assessment

Côte d'Ivoire - Conseil du Café-Cacao National Traceability System

Côte d'Ivoire's Coffee and Cocoa Council (Conseil du Café-Cacao, CCC) has been building a national traceability system since 2019, when farmer and plantation registration began. The CCC officially launched the National Traceability System (SNT) on 12 June 2026, after operational implementation began in 2023. The SNT relies on three tools: a producer card (which follows farmer and plantation registration), an electronic payment terminal, and traceability seals. From 1 September 2026, the producer card is mandatory for commercial transactions in the cocoa sector.

The system's registration scale is a genuine asset. Farmer IDs and plot polygons are being collected across the country, and the ambition is to cover every cocoa plot. In Côte d'Ivoire alone, this means digitising data for an estimated 800,000+ smallholder farms.

What the system does well: It is designed to link individual farmers to specific plots with geolocation data, and to follow cocoa through the marketing chain. For operators sourcing through formal, registered cooperatives, it provides a meaningful starting point for Article 9 information collection.

Where your file has to pick up:

• Data access for foreign buyers. The system is primarily designed for domestic market governance. Whether EU operators can extract per-consignment, per-plot data in a form they can retain for five years is still evolving. Check the current data-sharing modalities before assuming the portal output is sufficient.
• The cut-off date. Registration began in 2019 and has been ongoing. A registration record does not automatically establish what the land looked like on 31 December 2020. You will need to cross-reference plot coordinates against an independent land-cover dataset - satellite imagery or a validated forest map - to address the deforestation-free requirement.
• Indirect sourcing. Research by Trase found that only around 35% of Côte d'Ivoire's cocoa exports were directly sourced from farmer cooperatives, with the remainder passing through additional intermediary suppliers. For indirectly sourced cocoa, the SNT data may not flow through to you automatically.

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Ghana - COCOBOD and the Ghana Cocoa Traceability System (GCTS)

The Ghana Cocoa Board (COCOBOD) developed the Ghana Cocoa Traceability System (GCTS) as part of its digital transformation, with development fast-tracked to align with the EUDR. The GCTS is designed to trace every bag of cocoa beans from the farm plot where it was harvested to the port where it leaves the country, using GPS mapping, barcode labelling, and mobile data capture.

COCOBOD has reported significant registration progress: COCOBOD had measured 1,239,169 farms with a total of 1,380,566 hectares belonging to 761,753 farmers. The GCTS was officially introduced at the start of the 2025-2026 main crop season, with Licensed Buying Companies (LBCs) now required to use it for upcountry supply chain operations.

COCOBOD is also developing a Deforestation Risk Assessment Module (DRM) with technical support from the European Forest Institute, specifically to provide evidence that cocoa was produced on land not converted from forest after 31 December 2020.

What the system does well: The chain-of-custody design - from farm through purchasing clerk, depot, and port - is the most complete farm-to-port architecture among the major cocoa-producing countries. The centralised, COCOBOD-managed structure gives it institutional credibility.

Where your file has to pick up:

• The last mile into your own DDS. A preparedness assessment by the EU's Zero Deforestation Hub noted that COCOBOD is working on interoperability between operators' and COCOBOD's systems, and on data access modalities to enable private operators to access data. Until that interoperability is confirmed and tested, you cannot assume the GCTS data will flow directly into your due diligence statement.
• The cut-off date, again. The DRM is still under development. Until it is operational and validated, the GCTS geolocation data needs to be cross-checked against an independent forest-cover baseline for the 31 December 2020 reference date.
• Land tenure complexity. Around 80% of land in Ghana is held under customary tenure rather than formal titles, which creates challenges for the legality dimension of Article 3(b).

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Indonesia - The National Commodity Dashboard (SIPERIBUN / e-STDB)

Indonesia's response to the EUDR has been to build a National Commodity Dashboard that draws on two existing licensing registries: SIPERIBUN (the Plantation Licensing Information System, covering larger plantation business permits) and e-STDB (the Integrated System for Electronic Cultivation Business Registration, covering smallholder registration), alongside the Ministry of Environment and Forestry's forest cover maps. The dashboard covers palm oil, coffee, cocoa, rubber, and timber.

The ambition is significant: a blockchain-based, inter-ministerial platform designed to display geolocation data, legal documents, and forest cover overlays for every exported product. Indonesia is a standard-risk country under the EUDR, which means Articles 10 and 11 - risk assessment and mitigation - apply in full.

What the system does well: It integrates data from multiple government sources and is explicitly designed with EUDR compliance in mind. For large plantation operators registered in SIPERIBUN, geolocation data is available.

Where your file has to pick up:

• The cut-off date problem. This is the central documented gap. The EUDR uses a cut-off date of 31 December 2020 for deforestation-free status, but neither SIPERIBUN nor e-STDB were originally designed to incorporate a cut-off date - they were built for licensing and registration purposes. The Indonesian government has indicated that planting date information is included in these systems and can be used to classify compliance, but the practical question for EU operators is whether that classification is verifiable and auditable against an independent forest-cover baseline. A licence record is not, by itself, cut-off-date evidence.
• Smallholder registration gaps. As of mid-2024, e-STDB certification rates among independent smallholders were very low for several commodities - a significant issue given that smallholders account for a large share of Indonesian palm oil production.
• Data access. The dashboard is designed as a government-to-government transparency tool. Whether EU operators can extract per-consignment data in a retainable format - rather than viewing summary information through a portal - remains a practical question to verify with your supplier and the relevant Indonesian authorities.

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Brazil - A Stack of Systems, Not One System

Brazil does not have a single national traceability system for EUDR purposes. It has a stack of overlapping tools, and understanding what each one does - and does not - cover is essential.

CAR (Rural Environmental Registry): A self-declaration system in which rural property owners register the boundaries and environmental status of their land. CAR is the primary source of plot-level geolocation for Brazilian farms. However, CAR is self-declared and its information requires validation by environmental agencies - CAR validation remains a significant bottleneck, with almost all states in Brazil lagging behind. A CAR registration is not the same as a verified, deforestation-free declaration.

SISBOV (Brazilian System for Individual Identification of Bovines and Buffalos): The individual cattle identification system, and the route through which farms become eligible to export to the EU. Only farms that are part of SISBOV can export cattle products to the EU. However, SISBOV participation is voluntary, and the system was designed for sanitary control - not for environmental compliance. Individual animal traceability tells you where an animal was at slaughter; it does not automatically tell you whether any of the farms the animal passed through experienced deforestation after 2020.

GTA (Animal Transit Guide): A compulsory document for transporting cattle, recording movements between properties. Combined with CAR and deforestation monitoring data, GTA records can be used to trace an animal's history - but this cross-referencing is not automatic.

The indirect-supplier problem: Traceability to all plots of land of production, as required by the EUDR, is not yet a complete process in Brazilian cattle supply chains, with significant gaps particularly in indirect segments. Cattle in Brazil routinely move through multiple ranches before slaughter. Each of those earlier farms is a potential deforestation risk that SISBOV alone does not resolve.

Pará's programme: The state of Pará launched Brazil's first environment-focused, mandatory, animal-level traceability policy in 2023, with the ambition of tagging its entire herd of approximately 24 million cattle. However, in December 2025, Pará's governor postponed full implementation of the mandatory traceability programme until 31 December 2030, citing a lack of market reward for the state's efforts. The programme remains the most advanced state-level model in Brazil, but its timeline has shifted significantly.

Soy: The CAR provides plot-level geolocation for soy farms, and tools like the Selo Verde platform cross-reference CAR data with Brazil's official Prodes deforestation monitoring data to check for post-2020 deforestation. The Selo Verde platform, developed by UFMG researchers, uses official records to cross-check data on land use, deforestation, cattle transport, and compliance with environmental laws of rural properties, and has been adopted in several Brazilian states.

A critical scope note: The 13 July 2026 Delegated Act removed cattle hides, skins, and leather from Annex I of the EUDR. If you are sourcing leather, you are no longer in scope for the deforestation regulation (though the act is subject to a parliamentary scrutiny period before becoming binding law). Beef and other cattle products remain in scope. Similarly, soybeans for sowing were removed from Annex I by the same Delegated Act, but soybeans for other uses remain covered.

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What "Using" a National System Correctly Looks Like

Treating a government system as a source of information under Article 9 - rather than a substitute for due diligence - means doing the following:

1. Record provenance and date of extraction. Note which system you accessed, the date you accessed it, and the version or dataset reference. Systems are updated; your record needs to reflect what you saw at the time of your due diligence.

2. Keep the raw data export, not just the portal screenshot. A screenshot of a summary page is not a retainable record. Export the underlying coordinates, registration numbers, and licence data in a format you can store and produce for a competent authority.

3. Cross-check a sample against an independent satellite or land-cover dataset. For the 31 December 2020 cut-off, you need evidence that is not derived solely from the national system. Run a sample of plot coordinates through a validated forest-cover dataset - Global Forest Watch, the EU's own JRC forest map, or a comparable source - and document the results.

4. Document the residual risk and any mitigation. If the national system covers geolocation but not the cut-off date, that is a documented gap. Your risk assessment should name it, explain how you addressed it (e.g., satellite cross-check), and record the outcome.

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What to Write in Your Risk Assessment

Competent authorities are not looking for a statement that says "we relied on the government system." They are looking for evidence that you evaluated it. Here is the kind of language that demonstrates a genuine assessment:

"We obtained plot-level geolocation data for [X] farms from [system name], extracted on [date]. We verified that the coordinates were in the format required under Article 9 of Regulation (EU) 2023/1115. We cross-referenced [Y% / a sample of Z farms] against [forest-cover dataset] to assess land-cover status as of 31 December 2020. [X farms / no farms] showed evidence of post-2020 deforestation. The national system does not independently verify [legality dimension / cut-off date / indirect suppliers], and we addressed this gap by [specific mitigation step]. We assessed the residual risk as [negligible / low / standard] on the basis of [reasoning]."

The key elements: what you accessed, when, what it covered, what it did not cover, how you addressed the gaps, and what risk conclusion you reached. That is an evaluated source. A portal screenshot with "government certified" written on it is not.

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Sequencing Ahead of the Deadlines

Two application dates now govern EUDR compliance:

• 30 December 2026: Large and medium operators and traders, plus micro and small operators already covered by the EU Timber Regulation (EUTR).
• 30 June 2027: Other micro and small operators.

These deadlines were confirmed by the 13 July 2026 Delegated Act and Implementing Act, which settled the product scope and the technical rules for the EUDR Information System.

If you are a large or medium operator sourcing from any of the four countries assessed here, you have roughly four months to complete your due diligence systems before the first deadline. That is not enough time to build a data collection programme from scratch - but it is enough time to assess what your suppliers' national system actually provides, identify the gaps, and put targeted cross-checks in place.

The practical sequencing: first, establish what data the national system can actually deliver to you (not what it theoretically contains). Second, map that against the four tests above. Third, design your own verification steps for the gaps. Fourth, document everything in a form that survives a five-year audit window.

Government traceability systems are real assets. They represent significant investment by producer-country governments and provide a foundation that did not exist five years ago. The job of an EU operator is not to dismiss them - it is to use them correctly, understand their limits, and build the rest of the file themselves.

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