akar.earthThe EUDR Cut-Off Date of 31 December 2020
The EUDR cut-off date is 31 December 2020. What it means for Indonesian plots, how to prove land status at that date, and common mistakes to avoid.
The EUDR cut-off date is 31 December 2020. Cattle, cocoa, coffee, oil palm, rubber, soy and wood, and their listed derived products, are only compliant if they were produced on land that has not been deforested since that date, and for wood, harvested without forest degradation since that date.
What the cut-off date does
The cut-off date is a fixed line in time. It does not move with the application date. When an EU operator files a due diligence statement in 2027, it still asks whether the plot was forest on 31 December 2020 and whether that forest was lost afterwards.
This has two consequences for Indonesian supply chains:
- Old conversion is not penalised. A coffee garden planted in Lampung in the 1990s, or an oil palm plot in Riau planted in 2010, can supply compliant product, provided the plot is also legal.
- Recent conversion is excluded permanently. A plot cleared in 2022 cannot supply the EU market, whatever is planted on it and however well it is managed. There is no restoration route back into compliance for that plot under the current rules.
The test is about the land, not the farmer. A farmer can have one compliant plot and one non-compliant plot, and the two volumes must then be kept apart.
Legal clearing still counts
The EUDR applies its own deforestation test on top of national law. Clearing that was authorised under an Indonesian permit, for example in a plantation concession or on land released from the forest estate, still counts as deforestation under the EUDR if the land met the EUDR forest definition on the cut-off date. This is the key difference from the old EU Timber Regulation, which only targeted illegal logging.
Legality is a separate test. A product must pass both: deforestation-free since 31 December 2020, and produced in line with the laws of the country of production.
How to show land status at the cut-off date
Nobody can visit a plot in 2020 now, so evidence comes from imagery and records. A credible approach combines:
| Evidence | What it shows | Limits |
|---|---|---|
| Medium-resolution optical imagery (Sentinel-2, Landsat) | Tree cover before and after the cut-off date | Cloud cover is persistent in much of Sumatra, Kalimantan and Papua |
| Radar imagery (Sentinel-1) | Structural change through cloud | Harder to interpret in mixed agroforestry |
| Global forest maps, such as the EU’s 2020 forest cover map | A first screen of where forest was | Not legally binding, and errors at plot scale are common |
| Very high-resolution imagery | Detail on small plots | Cost, and archive gaps in 2020 |
| Field records and farmer interviews | Planting dates, crop age, land history | Needs cross-checking against imagery |
Our guide to satellite verification covers the workflow in detail. The short version: screen every plot automatically, then send people to look at the plots the screen flags.
Indonesian cases that need care
Agroforestry and old gardens. Shade coffee in Gayo or Toraja, cocoa under gliricidia and coconut in Sulawesi, and jungle rubber in Jambi can look like forest from space. A global map may label them forest in 2020, then flag routine thinning or replanting as loss. Field evidence of crop age and the agroforestry status of the land helps resolve these cases.
Fallow and shifting cultivation. Regrowth on fallow land in Kalimantan or Papua may have reached forest thresholds by 2020. Clearing it again after the cut-off date can count as deforestation even if the family has used the land for generations.
Replanting. Replanting old oil palm or rubber is not deforestation, because the land was under agricultural use on the cut-off date. Keep records that show this.
Fire. Burned forest is not automatically converted land. If forest burned in 2019 and was later planted with a commodity crop, the history needs careful reading.
Common mistakes
- Treating a certification audit date as proof of land status in 2020. Certificates may support the case, but they do not replace plot-level evidence.
- Using a single map layer and accepting its result without checking.
- Mapping only the farmer’s house or a collection point instead of the plot.
- Forgetting that new plots added after 2020 need the same check.
Where this fits
The cut-off date is one of three pillars, along with legality and due diligence. For the full picture, start at the EUDR hub. Plot data collected for this check can also feed carbon baselines, as explained in one dataset for carbon and EUDR. If you need plots screened against 2020 imagery, see our EUDR compliance services or message us on WhatsApp.
Frequently asked questions
What is the EUDR cut-off date?
31 December 2020. A covered commodity cannot enter or leave the EU market if it was produced on land that was deforested after that date, or for wood, from forest degraded after that date.
Does legal clearing after 2020 still count as deforestation?
Yes. The EUDR applies its own test. Clearing that was permitted under Indonesian law after 31 December 2020 still makes the commodity non-compliant if the land met the EUDR forest definition.
What about plantations cleared before 2021?
Land converted to agriculture before the cut-off date can supply compliant commodities, provided the production is also legal and the plot is properly geolocated.
How do you prove land status on 31 December 2020?
With time-series satellite imagery covering the plot around and after the cut-off date, interpreted against the EUDR forest definition, and backed by field checks where the imagery is ambiguous.