Deforestation-free: Definition
What does deforestation-free mean under the EUDR? The legal definition, the 31 December 2020 cut-off, and how Indonesian exporters can prove it.
Deforestation-free, under the EU Deforestation Regulation (EUDR), means a product was made from commodities produced on land that has not been subject to deforestation after 31 December 2020, and, for wood, that it was harvested without causing forest degradation after that date. It is one of three conditions, with legality and a due diligence statement, for placing cattle, cocoa, coffee, oil palm, rubber, soya, wood or listed derived products on the EU market.
Why it matters
The Commission states the regulation applies from 30 December 2026 for large and medium operators, with later dates for micro and small enterprises. Products that cannot be shown to be deforestation-free cannot be sold in or exported from the EU. For Indonesia, that affects palm oil, coffee, cocoa, rubber and wood exports.
How it is tested
- Every production plot is identified by geolocation.
- Plots are checked against land cover at the cut-off date and later imagery.
- “Forest” follows the EUDR definition: land over 0.5 ha with trees over 5 m and canopy cover over 10%, or able to reach those thresholds, excluding land mainly under agricultural use. See forest definition.
- Conversion of forest to agricultural use after the cut-off fails the test, whether legal locally or not.
Indonesia and Southeast Asia angle
Agroforestry is a grey zone. Shade coffee, cocoa under trees and jungle rubber can look like forest in satellite data. Operators need field evidence and land use history to show a plot was agricultural before 2021. Satellite verification plus ground observations reduces false flags.
Legality is a separate test. A product can be deforestation-free and still fail EUDR if it was produced in breach of the laws of the country of production, such as land use, environmental, labour or tax rules.
Common mistakes
- Equating deforestation-free with “zero deforestation” company pledges, which may use different dates and definitions.
- Relying on global forest maps without checking local land use.
- Assuming mass balance supply chains can be deforestation-free; EUDR does not accept them.
Start at the EUDR hub.
Frequently asked questions
Is a certified product automatically deforestation-free under EUDR?
No. Certification such as RSPO or ISPO can support a risk assessment, but the operator must still have plot geolocation and its own due diligence showing no deforestation after the cut-off date.
Does deforestation before 2021 matter?
Not for EUDR. The test is whether deforestation happened after 31 December 2020. Earlier clearing does not make a product non-compliant, though it can matter for other standards.