Geolocation exists, but cannot be linked to the tyre batch
Separate technical geometry checks from product linkage; trace the missing batch-to-input-to-plot relationship and write a precise clarification request.
There are two different checks
A geolocation file can be technically valid and still be irrelevant to the product you import. First, check whether the data correctly describes production locations. Then check why those locations belong in the evidence set for the particular goods.
For rubber, a manufacturer’s factory coordinates do not identify the land where the natural rubber was produced. Keep production plots, processing sites and manufacturing facilities as separate location types.
What the law asks for
Article 9 of the EUDR requires, for the standard operator due-diligence workflow, geolocation of the plots where the relevant commodities were produced and the production date or time range. The legal definition uses latitude and longitude with at least six decimal digits. For non-cattle commodities, plots larger than four hectares require polygons describing their perimeter.
Do not round “larger than four hectares” into “four hectares and above”. Also distinguish this standard workflow from the special simplified-declaration provisions for eligible micro or small primary operators introduced by the 2025 amendment; these are not a general exemption for small tyre importers.
A useful supplier request
- A stable plot identifier that will remain recognisable in later versions.
- The location data in a usable format, with the source and collection method.
- The plot area and relevant production date or period.
- The commodity and the upstream supplier or processor relationship.
- The product, material lot or supply period to which the plot set relates.
- An explanation of how updates, corrections and changed sourcing are communicated.
Request the original supplied file as well as any working conversion. Preserve both. If a spreadsheet is converted to GeoJSON, record the transformation and the reviewer.
A valid file can still be irrelevant to the batch
Correct coordinates and plausible polygons do not identify which rubber fed a tyre output. Source, period and product linkage need their own gate. Do not infer coverage from the manufacturer country or email receipt date.
| Gate | Checks/questions | Does not prove |
|---|---|---|
| Structure | Readable file, fields, plot IDs, coordinate order, valid geometry, appropriate shape for area | Product coverage |
| Source/period | File creator, assertion owner, factual period, correction history | Every relevant input included |
| Material relationship | Plots → sourcing set → input lots → output → shipment | Production legality/deforestation-free status |
| Substantive assessment | Reliable supporting records, relevant legal/land-use/risk work | Unlimited future sourcing approval |
Under Article 2(28), coordinate precision uses at least six decimal digits; non-cattle plots larger than four hectares require polygons. The exact threshold matters. Commission GeoJSON documentation supports technical formatting, not a legal conclusion.
PS-07 contains plot IDs and coordinates, but output B-A17 is not related to input lots NR-11/NR-12. Nor is it clear that PS-07 covers both. The next request is allocation and sourcing-set reconciliation, not extra decimal places.
The clarification request
- Identify the output batch or controlled production period.
- List relevant natural-rubber lots or explain a bounded candidate set.
- Identify processor/supplier and sourcing-set references.
- Map those inputs to plot identifiers and production periods with supporting records.
- Disclose absent locations, mixing, carry-over and uncertain coverage.
- State source, version and the change-notification owner.
Ask for an attributable explanation backed by records. A response saying “the same plots apply” is an assertion to review, not an automatic relationship.
Mixed sourcing needs an honest origin universe
If several candidate inputs may contribute, uncertainty must be disclosed and the actual controls examined. Do not select the best-documented farm while leaving unknown inputs out. Conversely, a huge processor-wide catalogue without a product/period relationship is not automatically sufficient. Article 10 includes supply-chain complexity and mixing/circumvention risks.
Keep conversions and corrections visible
Retain a spreadsheet source when converting it to GeoJSON and identify the derived version. Coordinate-order or identifier errors can arise in transformation. A corrected geometry, added plot and changed sourcing period are different changes; preserve both versions and identify affected reviews.
State the actual checks performed
Geometry validation, product linkage, land-use analysis and production-legality review may require different expertise. Do not label an inventory check as completed satellite analysis. The operator’s information and risk process under Articles 9–11 remains distinct from system format acceptance.
The sample report contains no real coordinates and explicitly marks its unperformed checks. A real diagnostic should be equally clear about the work completed and specialist dependencies.
Know what is ready.
Know what is missing.
A focused diagnostic before you commit to a recurring operating model.