When data decides who can sell to the EU: eight recommendations to protect smallholders under the EUDR
A sub-group of the EUDR Community of Practice, facilitated by IDH and Tony’s Chocolonely, has published eight recommendations to stop smallholder data requirements from becoming a route to market exclusion.
The EU Deforestation Regulation (EUDR) asks companies to collect detailed data on where and how their commodities are produced. For the millions of smallholders behind cocoa, coffee and palm oil, that means being mapped, screened and verified, often several times over by different buyers using systems that do not talk to each other.
Between June and October 2026, a sub-group of the EUDR Community of Practice (CoP) met four times to look at this problem. The CoP is the wider multi-stakeholder forum supporting EUDR implementation, and you can learn more about it on the European Forest Institute’s EUDR Community of Practice page. The sub-group focused on smallholders and data ownership, verification, and sharing. IDH facilitated this work together with Tony’s Chocolonely.
Who took part
Participants came from companies, certification bodies, data and assurance providers, NGOs and smallholder organisations: 60 Decibels, Barry Callebaut, Edelsource, Enveritas, the European Forest Institute, Fairtrade International, FERN, Ferrero, Hershey’s, IDEF (Côte d’Ivoire), IKEA, ISEAL, Koompassia Enviro Institute (Indonesia), Olam Agri, Rainforest Alliance, RSPO, SOCA2PD (Côte d’Ivoire), Solidaridad, Uganda Coffee Farmers Alliance and Walter Matter. Discussions followed the Chatham House rule, so the report reflects what was shared without attributing it to any organisation.
Three connected challenges
- Market exclusion: when a compliance risk cannot be conclusively resolved, operators tend to exclude the plot or the farmer. Satellite screening adds to this, with case evidence showing false positive rates as high as 98% in one cocoa supply base and between 55% and 78% in agroforestry-dominated coffee regions
- Cost: registration, verification and annual updating are repeated by each buyer, and the burden falls heavily on cooperatives and exporters
- Data rights: data flows up from farmers to buyers, while ownership, consent and the right to correct a finding remain unclear
Eight recommendations
The sub-group ranked its recommendations at the final meeting on 9 October 2026, by strategic importance and by how readily each can be achieved.
- Clarify risk screening and exclusion criteria, including how corrective action fits alongside the duty to exclude non-compliant products
- Agree shared data, mapping and interoperability standards, and recognise credible national and regional systems
- Adopt collaborative ground-truthing and false positive protocols, so a farmer verified once is not rechecked by every buyer
- Set data governance and personal data standards covering consent, access, retention, sharing and correction
- Put a standard appeal and right-to-correction mechanism in place for farmers who contest exclusion decisions
- Share the cost of producing compliant data fairly, including the cost of annual updates
- Combine pre-season screening with a “verify once, share many” approach to monitoring
- Establish consistent, authoritative geospatial reference data, so the same plot does not receive different verdicts depending on the tool used
What happens next
Each recommendation names the actors best placed to act, from policy makers and competent authorities to companies, multi-stakeholder initiatives, cooperatives and donors. Interested participants plan to continue to work on the practical recommendations. Organisations that want to join this follow-up are welcome to get in touch.
Read the full report.