Busting 3 Myths about Deforestation Monitoring for the EUDR

The European Union’s Deforestation Regulation (EUDR) is currently expected to go into effect at the end of 2025. While this delay gives companies more time to prepare, they should not postpone their efforts to meet the requirements and ensure they have robust systems established for deforestation monitoring and risk assessment.

The European Commission has provided updated compliance guidance and debunked some pervasive myths, but the details of the regulation are complex so there continue to be many misconceptions about monitoring, compliance and due diligence requirements.

In this blog, we break down three common myths and explain how companies can effectively use open-source data like that on GFW Pro for EUDR compliance.

Myth 1: You need very high-resolution satellite imagery to accurately monitor deforestation under the EUDR.

Truth: The EU clearly states it will not impose the use of specific satellite imagery tools, or thresholds on satellite imagery resolution, to document the absence of deforestation. Further, when it comes to accurate monitoring, whether a specific spatial resolution is “good enough” depends on what we need to detect, as well as the definition of forest and deforestation used — and higher resolution isn’t always better.

The EUDR definitions for forest and deforestation are based on the definitions adopted by the Food and Agriculture Organization of the United Nations (FAO): A forest is land spanning more than 0.5 hectare with a tree canopy cover of more than 10% that is not primarily under agricultural or urban land use; and deforestation is the conversion, whether human-induced or not, of forest to agricultural use.

Photo by David Raino Cortes

To measure forests and deforestation under this definition with satellites requires translating raw satellite data into a model that can accurately measure both the presence of a 0.5-hectare parcel of forest, and its change from forest to a non-forest use.

Satellite-based measures of forest are achieved by analyzing the intensity of dozens of electromagnetic field (EMF) spectrums (visible, radar, infrared, near-IR, etc.) reflected at different strengths with various revisit intervals. Thus, 30-meter pixels analyzed with many sensors over time can yield rich insights into the nature of the land cover that is present.

High-resolution data like open, monthly optical images from Planet (available on GFW Pro and through a number of private service providers) can be useful for expert human inspection but is by no means required to detect commodity-driven deforestation.

While high-resolution data can capture loss on the scale of a single tree, these losses generally don’t constitute deforestation, so this degree of resolution is not needed for detection of deforestation.

Additionally, just because geospatial maps are modelled at a particular resolution does not mean that the level of detail indicated by the resolution is always observable. For example, a recent study analyzed three global 10-meter maps and only one captured 10-meter features in the landscape well.

Therefore, 30-meter Landsat data, like the University of Maryland (UMD) Tree Cover Loss data set and the Glad-L alerts available on GFW Pro, is well-equipped for accurately monitoring deforestation under the EUDR. This data has been used for mapping deforestation with a high degree of confidence for more than 20 years. Landsat data captures losses driven by a range of activities including conversion to coffee and cocoa (although capturing where these are grown understory is a challenge for all satellite-derived products).

Myth 2: Open data is not suitable for deforestation monitoring against EUDR due diligence requirements.

Truth: Not only is open data suitable for EUDR deforestation monitoring, but most “proprietary” forest models from commercial providers (with the exception of those from large aerospace companies maintaining their own network of private satellites) are built primarily on open data developed by trusted public agencies and research teams such as NASA, the European Space Agency, the University of Maryland (UMD), Wageningen University and Research, the EU Joint Research Centre (JRC), World Resources Institute (WRI), INPE (Brazil's national space research institute), and MapBiomas.

In fact, the “reduction in false positives” often marketed by proprietary service providers has little to do with proprietary models but is usually based on use of ground data provided by customers to filter open data to exclude known non-forest areas like farms.

Trusted, high-quality open-source data like global forest extent maps, annual tree cover loss and near-real-time deforestation alerts can be used in combination with local models and ground data to filter and omit areas that are known not to be forests. This includes open data sets on Oil Palm Concessions and the Spatial Database of Planted Trees (SDPT), which are frequently cited by proprietary service providers.

Oil Palm Concessions in Indonesia, as viewed on GFW Pro

The SBTN Natural Lands Map is a good example of this approach, leveraging more than 70 national forest maps as well as MapBiomas national ecosystem mapping to complement global data with locally informed models.

In the context of the EUDR, what is more important than whether a forest model is using open data or a proprietary method is whether the results are credible and reproducible for competent authorities.

For example, the European Forest Institute advised that companies choosing data or providers to assess EUDR compliance should ensure that the data is “based on transparent methodologies and international standards; and, ideally, peer-reviewed.”

Unlike opaque black-box solutions, transparent methodologies allow for the independent verification and replicability of results, letting stakeholders scrutinize and validate the findings. Furthermore, every data set has limitations, so it’s important to consider whether the limitations are transparently reported.

Ultimately, no single forest monitoring data set will be adequate on its own to serve EUDR compliance needs. In evaluating monitoring solutions, companies will need to weigh the needs and trade-offs between accuracy, transparency and cost-effectiveness for their specific use case. But overall, open data has immense value for both reporting and compliance purposes.

For this reason, GFW Pro provides supply chain actors with 38 data sets and counting, allowing them to harness a wide range of information through multiple leading open-source global forest models — including UMD and JRC, local/national forest data, protected areas, Indigenous and community lands through LandMark and Planet-NICFI high-resolution images — to inform all elements of a due diligence process.

GFW Pro offers 38 data sets on forest change, land cover, land use, protected areas, Indigenous and Community Lands and regional/national data.

Myth: Your EUDR compliance solution or certification scheme should provide you with a report that guarantees your product’s direct compliance with the EUDR.

Truth: EUDR solution providers may offer services such as verification of EUDR compliance or automated generation and submission of the Due Diligence Statement (DDS) to the EU. But the regulation clearly states that just because a product is certified, this does not negate the need for other forms of risk assessment or mitigation. The legal liability ultimately lies with the company placing products on the EU market: according to Article 6 of the EUDR text, the operator and trader will be responsible for any breach and therefore cannot outsource the legal responsibility for compliance to a third party service or a particular data set.

What certification or third-party verification schemes can provide is important evidence that key elements of the EUDR are being met provided that a scheme’s standards are adequate, as noted in the EUDR guidance document. For example, if companies can show that a certification scheme’s standards are sufficiently robust to prevent deforestation and forest degradation, or uphold the rights of Indigenous Peoples, then the fact that a product is certified to that scheme can be used as part of a company’s evidence of compliance.

However, operators and traders must be able to credibly defend the system they use to reach a due diligence conclusion.

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Learn more here about how GFW Pro supports EUDR compliance. If you have questions about using GFW Pro for deforestation monitoring or due diligence, please contact us at gfwprosales@wri.org

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