akar.earthThe EUDR Forest and Degradation Definitions
The EUDR forest definition and forest degradation definition explained, with Indonesian examples: plantations, agroforestry, jungle rubber and fallow land.
The EUDR defines forest as land spanning more than 0.5 hectares with trees higher than 5 metres and canopy cover of more than 10 percent, or trees able to reach those thresholds in situ, excluding land predominantly under agricultural or urban use. Deforestation is the conversion of such forest to agricultural use; forest degradation, which matters mainly for wood, is the conversion of primary or naturally regenerating forest into plantation forest or other wooded land.
Why the definition matters more than the map
The EUDR does not use Indonesia’s legal forest estate (kawasan hutan) to decide what is forest. It uses a land cover definition based on the FAO approach. This creates two mismatches:
- Land outside the forest estate can still be EUDR forest. Much of the forest cleared for plantations in Indonesia was on land designated for other uses (APL).
- Land inside the forest estate is not always EUDR forest. Long-established gardens and degraded land within the estate may not meet the thresholds.
So the deforestation-free test looks at what was on the ground on 31 December 2020, not at its legal designation. The legal designation is a separate legality question.
The thresholds, applied to Indonesian land
| Land type | EUDR status | Notes |
|---|---|---|
| Natural lowland or hill forest | Forest | Clearing after 2020 is deforestation |
| Peat swamp forest | Forest | Also a legality concern under peat rules. See peat restoration rules |
| Mangrove forest | Forest | Conversion to ponds or plantations after 2020 is deforestation |
| Secondary forest and old regrowth meeting the thresholds | Forest | Includes some long fallows |
| Oil palm, rubber, cocoa, coffee plantations | Agricultural plantation, not forest | Replanting is not deforestation |
| Agroforestry where crops grow under tree cover | Agricultural plantation | Establishing it by clearing forest after 2020 is deforestation |
| Acacia or eucalyptus pulpwood plantations | Plantation forest (forest) | Harvest and replanting is not deforestation; converting natural forest into them is degradation |
| Shrubland, grassland, young fallow below thresholds | Not forest | Planting here is compatible with the EUDR |
Agricultural use and agricultural plantations
The definition excludes land predominantly under agricultural use. The Regulation treats tree stands in agricultural production systems, such as oil palm plantations, fruit orchards and agroforestry systems where crops are grown under tree cover, as agricultural plantations. This covers plantations of the relevant commodities other than wood.
This is good news for long-established Indonesian smallholder systems. A cocoa garden under gliricidia in Sulawesi or a shade coffee garden in Gayo is agricultural use, even if satellite products classify it as tree cover. The Commission’s Guidance includes a section on the term “agricultural use”; check it when a case is borderline. See EUDR and agroforestry.
Forest degradation and wood
Forest degradation is defined narrowly. It means structural change to forest cover, taking the form of:
- conversion of primary forests or naturally regenerating forests into plantation forests or into other wooded land; or
- conversion of primary forests into planted forests.
Selective logging that keeps natural forest as natural forest is not degradation under this definition, although it must still be legal. Converting a logged-over natural forest into an acacia plantation after 2020 is degradation, and wood from it is non-compliant. This matters for pulp and paper and for timber from mixed concessions. See wood and the EUDR.
Hard cases in Indonesia
Jungle rubber. Old rubber agroforests in Jambi and West Kalimantan can exceed 5 metres and 10 percent canopy cover. They are agricultural use, but a global map may call them forest. Document their age and use.
Shifting cultivation. Long fallows can grow back into forest. If a fallow met the thresholds on 31 December 2020, clearing it afterwards counts as deforestation. Short fallows below the thresholds do not.
Abandoned plantations. An oil palm plot abandoned for a decade with natural regrowth may cross into forest. Clearing and replanting it needs careful assessment.
Small patches. Patches under 0.5 hectares are not forest under the definition, but they may still matter for buyers’ own policies and for high conservation value assessments.
Using the definition in practice
Screen plots with satellite data first, using tree height and canopy cover where available. For flagged plots, check land use in the field: crop type, crop age, and management. See satellite verification. The same canopy and height data feeds carbon baselines, as covered in our guide to canopy height models.
The EUDR hub has the full topic map. For borderline plots in your supply base, contact us on WhatsApp through our EUDR compliance services.
Frequently asked questions
How does the EUDR define forest?
Land spanning more than 0.5 hectares with trees higher than 5 metres and canopy cover of more than 10 percent, or trees able to reach those thresholds in situ, excluding land that is predominantly under agricultural or urban use.
Is an oil palm or rubber plantation a forest under the EUDR?
No. Plantations of the covered agricultural commodities are agricultural plantations, which are excluded from the forest definition. Converting forest into them after 31 December 2020 is deforestation.
What is forest degradation under the EUDR?
Structural changes to forest cover, in the form of converting primary or naturally regenerating forest into plantation forest or other wooded land, or converting primary forest into planted forest. It mainly matters for wood.
Is agroforestry counted as forest?
Agroforestry systems where crops are grown under tree cover are treated as agricultural plantations. But clearing natural forest to establish agroforestry after the cut-off date is still deforestation.