# My farm or forest has a sustainability certificate. Can I send that to my EU buyer instead of plot data under the EU Deforestation Regulation (EUDR)?

Canonical: https://senseible.earth/answers/eudr-certificate-or-plot-data-for-eu-buyer

No. Article 9 asks for the map positions of your plots, and the Commission lists certificate information among the extra inputs a buyer may weigh when judging risk, if it meets Article 9. Our reading: send both.

## First, the words

- A plot is one piece of land. Its geolocation is its position on a map, like dropping a pin in a map app.
- Due diligence is the homework your EU buyer must finish before the goods come in. It has three steps: collect the facts, judge the risk, reduce the risk.
- A certificate is a paper from an outside body saying your farm or forest follows a scheme's rules. Think of a reference letter for a job: it helps, but the employer still wants your own papers.

## Where a certificate fits in the three steps

Step 1 is collecting the Article 9 information. The Commission calls the geographic coordinates (geolocations) of the plots a key requirement of this step. It also says that if the operator cannot collect the required information, it must not place the product on the EU market or export it.

Step 2 is the risk assessment. Among the Article 10 points to weigh, the Commission lists "complementary information on compliance with this Regulation, which may include information supplied by certification or other third-party verified schemes, including voluntary schemes recognised by the Commission under Article 30(5) of Directive (EU) 2018/2001". The condition follows: "provided that the information meets the requirements set out in Article 9 of this Regulation".

The Commission's guidance also "acknowledges the role of certification and third-party verification schemes".

## What follows for you

- Our reading: a certificate is an extra input to step 2. It sits beside the Article 9 information and does not stand in for it.
- India is listed as low risk in the Commission's 2025 country list (Implementing Regulation (EU) 2025/1093), which can be reviewed. A buyer sourcing only from low risk origins can use simplified due diligence under Article 13 and does not have to carry out Articles 10 and 11, but only if it has checked there is no mixing with other origins, and full steps return if it learns of a risk. Our reading: the step where certificates are named may then not apply. Step 1 stays.
- A certificate helps only to the extent it carries what Article 9 asks for, such as plot locations and production dates. Check whether yours does.

## What to send

1. The plot coordinates and production dates for the lot, from your own records.
2. The certificate, with its scope, the plots it covers and its validity dates, as a supporting document.
3. A note of which plots in the lot the certificate covers and which it does not.

## A list of schemes is being built

The Commission says the International Trade Centre (ITC) is developing a repository, which is a public list, of certification and third-party verification schemes for the covered commodities. The page marks it "under construction" and says it "will be launched ahead of the EUDR's entry into application". It read that way on 7 November 2026. Ask your buyer whether it will rely on that list.

## A lot where the certificate covers only part

- Lot: 12.0 tonnes of green coffee from 40 plots
- Certificate covers 31 plots that delivered 9.3 tonnes
- Not covered: 40 minus 31 = 9 plots, and 12.0 minus 9.3 = 2.7 tonnes
- Plot coordinates are still needed for all 40 plots. The certificate adds supporting information for 9.3 of the 12.0 tonnes, which is about 78%

Example figures, not a real lot.

## What Senseible does here

Senseible turns fuel invoices and electricity bills into an emission record. For EUDR it does not collect plot coordinates, hold certificates, file due diligence statements or check deforestation-free status.

- [Three due diligence steps and what each needs](https://senseible.earth/answers/eu-deforestation-three-due-diligence-steps-what-each-needs)
- [India as a low risk country under EUDR](https://senseible.earth/answers/eudr-country-risk-category-india)
- [What an Indian supplier gives the EU importer for the statement](https://senseible.earth/answers/eudr-due-diligence-statement-supplier-data)
- [EUDR readiness: what applies to your goods](https://senseible.earth/eudr)

Sources: [European Commission Green Forum, Understand due diligence under the EU Deforestation Regulation](https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/understand-due-diligence_en), [European Commission Green Forum, Deforestation Regulation implementation](https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation_en), [Commission Implementing Regulation (EU) 2025/1093 on country benchmarking under the EUDR (EUR-Lex)](https://eur-lex.europa.eu)

Last reviewed 2026-11-07. Both Commission pages read on 7 November 2026. The Commission says to read them with the guidance, the Frequently Asked Questions (FAQs) and the legal text. Your buyer decides what it accepts, so ask in writing.