You are already paying to collect EUDR deforestation data, and with a TNFD nature disclosure also on the desk, the obvious hope is that one job covers the other. It half does. Where it does not is where a nature disclosure quietly understates what a business depends on, and that boundary is worth getting right before the next data request goes out to suppliers.
The reuse question in four points
- The overlap is real, not invented: TNFD’s own sector guidance points reporters to the EUDR as a source for the Locate phase.
- The evidence transfers. The coordinates you collect for EUDR are more precise than TNFD requires and drop straight into your Locate work.
- The verdict does not. An EUDR deforestation-free pass understates nature in four ways: a narrower definition of deforestation, a 2020 cut-off, seven commodities in one market, and a pass-or-fail output.
- Collect supplier location data once, to the stricter of the two definitions, and both jobs are covered. Retrofit it after the fact and you pay twice.
If your company sells cattle, cocoa, coffee, palm oil, rubber, soy or wood into the European
Union, you are probably in the middle of an expensive data exercise right now. The EU Deforestation
Regulation, usually shortened to EUDR, applies from 30 December 2026 for most operators. That is
under five months away. Meeting it means collecting the coordinates of every plot of land your
commodities came from, and showing that none of it was deforested.
Many of the same companies also owe a nature disclosure, either voluntarily under the Taskforce on
Nature-related Financial Disclosures (TNFD), or as a legal requirement under the European
Sustainability Reporting Standards. Both ask where your business touches nature.
So the question comes up in almost every planning meeting: we are already buying all this
deforestation data, does it count for the nature disclosure too?
The short answer is that the evidence counts and the conclusions do not. The coordinates you gather
for EUDR are more precise than TNFD asks for, and they can go straight into your nature
assessment. But an EUDR pass is a narrower statement than it sounds, and treating it as a nature
answer will leave your disclosure understated in four specific ways.
Here is where each one sits.
| EUDR output | Transfers to TNFD? | Why |
|---|---|---|
| Plot coordinates and polygons (six decimals) | Yes | Finer than TNFD requires; feed the Locate phase directly |
| Land cover and forest-change history | Yes | Feeds the sensitive-location screen |
| Deforestation-free verdict | No | Bounded by a narrower definition of deforestation |
| Post-2020 cut-off status | No | TNFD’s assessment has no start date |
| Seven-commodity, EU-market scope | No | TNFD covers four realms across the whole business |
| Pass-or-fail result | No | Nature disclosure needs the gradient a market gate discards |
TNFD’s own sector guidance lists the EU Deforestation Regulation as a source for the Locate phase
This overlap is not something we invented to connect two topics. TNFD says it directly.
TNFD’s recommended method for working out where your business meets nature is called LEAP, which
stands for Locate, Evaluate, Assess and Prepare. The Locate phase breaks into four steps, numbered
L1 to L4.
In its guidance for the food and agriculture sector, TNFD writes that “useful additional tools and
sources for the food and agriculture sector for the L2 component of the Locate phase include:
Regulation (EU) 2023/1115 of the European Parliament and of the Council.” Regulation (EU) 2023/1115
is the EUDR. The guidance for apparel, accessories and footwear says the same thing in the same
words. In plain terms, TNFD is telling reporters in these sectors to go and look at the
deforestation regulation while they work out where nature matters to them.
It goes further than a reading recommendation. TNFD’s food and agriculture guidance carries an
annex titled “High deforestation risk derived products”, listing cattle, cocoa, coffee, oil palm
and soy along with their derived products. The source note reads: “Commodities listed based on EU
Commission (2023) Regulation (EU) 2023/1115.” TNFD took the EU’s commodity list and reused it as a
nature screening shortcut.
And TNFD’s glossary defines “deforestation-free” by quoting the EUDR directly, citing “EU
Regulation (EU) 2023/1115 on deforestation-free products” as its source.
Three separate borrowings: a screening input, a commodity scope, and a definition. If you are doing
Locate and you ignore the EUDR work sitting in the next department, you are discarding something
TNFD points you toward.
One precision worth holding onto, because it shapes everything below. Both sector guidances place
the EUDR at L2. TNFD describes that step as “dependency and impact screening”, and it asks
whether any of your sectors, value chains and direct operations carry potentially moderate and high
dependencies and impacts on nature.
The EUDR is never listed as a source for L4, “interface with sensitive locations”. That is the
step that asks which of your locations are ecologically sensitive. TNFD uses the deforestation
regulation to help you decide which parts of your business to look at. It does not use it to decide
whether a place is sensitive.
EUDR requires coordinates to six decimal places and polygons above four hectares, while TNFD sets no resolution requirement at all
This is the part that makes reuse worth doing, and it runs opposite to what most people expect.
The EUDR defines geolocation as “the geographical location of a plot of land described by means of
latitude and longitude coordinates corresponding to at least one latitude and one longitude point
and using at least six decimal digits”. For plots over four hectares producing anything other than
cattle, it requires “polygons with sufficient latitude and longitude points to describe the
perimeter of each plot of land”. Six decimal places of latitude is roughly a tenth of a metre. A
polygon is the actual shape of the field, not a dot near it.
TNFD asks for nothing of the kind. Its LEAP guidance accepts that reporters will arrive with
whatever resolution they have, noting that how organizations “work their way through the Evaluate
phase may vary based on the granularity of geographic locations generated in the Locate phase”. Its
criteria for a good nature metric treat adaptability as a strength, valuing metrics that “can be
applied at varying levels of spatial resolution”. In plain terms, TNFD sets no floor.
So on precision, the EUDR asks for more than TNFD does. A dataset built to satisfy a customs
officer will comfortably satisfy a nature assessment. That is why the reuse instinct is right, and
it is worth saying plainly before getting to the limits.
The EUDR also asks a question TNFD never asks. Placing products on the EU market requires not only
that they are deforestation-free but that “they have been produced in accordance with the relevant
legislation of the country of production”. Legality is central to the EUDR. TNFD’s definition of
deforestation counts forest loss “regardless of whether or not it is legal”, so legality does not
enter its assessment at all.
Two frameworks, then, that each demand something the other does not. Now the four places where an
EUDR pass covers less ground than a nature disclosure needs.
EUDR counts deforestation as conversion of forest to agricultural use, while TNFD also counts conversion to plantation and severe degradation
The two frameworks use the same word for different things, and the gap is easy to miss because the
word looks settled.
The EUDR says “‘deforestation’ means the conversion of forest to agricultural use, whether
human-induced or not”. Forest becomes farmland.
TNFD’s glossary takes its definition from the Accountability Framework initiative, a separate
standards body, and it is wider: “loss of natural forest as a result of: (i) conversion to
agriculture or other non-forest land use; (ii) conversion to a tree plantation; or (iii) severe and
sustained degradation.”
Look at limb (ii). Clearing a natural forest and replanting it as an industrial plantation is not
deforestation under the EUDR, because the land did not go to agricultural use. Under TNFD’s
definition it plainly is. The same is true of limb (iii): a forest degraded to the point of
collapse but never formally converted stays outside the EUDR’s core test and inside TNFD’s.
For a business sourcing from plantation landscapes, that single word can be the difference between
a clean compliance file and a material nature impact you have not reported.
EUDR’s deforestation-free test begins on 31 December 2020, while TNFD’s assessment has no cut-off date
The EUDR’s test is anchored to a date. Products qualify if the commodities were “produced on land
that has not been subject to deforestation after 31 December, 2020”.
That date does real work. Land cleared in 2015 and farmed ever since produces fully compliant
commodities today. Nothing in the regulation looks further back.
TNFD asks a different kind of question, and it has no start date, because it is about your current
relationship with nature. If your supply chain sits on land that was forest a decade ago, the
ecosystem services you now depend on are the ones that remain, and the impact that changed them is
part of your business’s history with that landscape. A pre-2021 conversion is invisible to the
EUDR and fully visible to a nature assessment.
EUDR covers seven commodities entering one market, while TNFD covers land, ocean, freshwater and atmosphere across the whole business
The EUDR’s reach is deliberately narrow. It applies to “cattle, cocoa, coffee, oil palm, rubber,
soya and wood”, and only where those products are placed on, or exported from, the EU market.
TNFD’s scope is the whole organization across what it calls the four realms of nature: “land,
ocean, freshwater and atmosphere”.
Everything in the space between those two is a gap you have to fill from somewhere else. Water
availability at your processing sites. The condition of the ecosystems your operations sit inside.
Whether your facilities are near protected areas. Any commodity outside the seven. Any site outside
the EU trade flow. Your own manufacturing, warehousing and offices, none of which place cocoa on
any market.
A company can hold a complete set of due diligence statements and have looked at a small fraction
of its interface with nature.
EUDR asks a pass-or-fail question about a product, while TNFD asks a continuous risk question about a business
This difference is structural, and it explains why the first three gaps exist at all.
The EUDR is a market access gate. Its information requirements state that “any deforestation or
forest degradation on the given plots of land shall automatically disqualify all relevant
commodities and relevant products from those plots of land from being placed or made available on
the market”. The output is binary. The product goes to market or it does not.
Nature disclosure needs the gradient that a gate throws away. How much do we depend on this
watershed. How exposed are these sites. Which locations matter most. A file of passes contains none
of that, because passing was the only thing it was built to record.
The EUDR does create one nature-related risk that shows up in disclosure, which is the regulatory
and market risk of non-compliance itself. That is a transition risk rather than a physical one, and
it sits outside what this piece covers. Our EUDR compliance guide deals
with the obligations, penalties and due diligence mechanics.
Regulation (EU) 2025/2650 lets micro and small primary operators in low-risk countries give a postal address instead of coordinates
Those four gaps are all about what an EUDR pass means. There is a separate limit on the underlying
data itself, and it is recent enough that most readers have not registered it.
In December 2025 the EU amended the EUDR through Regulation (EU) 2025/2650, which pushed the
deadlines back and simplified several obligations. One of those simplifications matters for anyone
planning to reuse EUDR data. It sits in a newly inserted Article 4a(5):
“For micro or small primary operators, the geolocation referred to in Article 9(1), point (d),
may be replaced by the postal address of all plots of land or the postal address of the
establishment from which the relevant commodities that the relevant product contains, or has been
made using, were produced.”
In plain terms, some of your smallest suppliers can now give you an address instead of coordinates.
An address cannot be laid over a satellite forest-loss layer or tested against a protected area
boundary. Where that substitution is used, the precision advantage described earlier disappears.
Be careful how far you take this, because the substitution is bounded. “Micro or small primary
operator” is defined as a producer “established in a country classified as low risk in accordance
with Article 29”. The EUDR sorts every country into high, low or standard risk, and this relief
reaches only the low-risk tier. It does not open a hole across smallholder supply chains generally.
Which leads to the point underneath all of this.
EUDR sorts risk by country tier, while TNFD decides priority locations by ecological criteria at the site
The two frameworks answer the question “where” at completely different resolutions, and this is the
distinction to carry out of the whole comparison.
The EUDR’s risk logic is jurisdictional. A country is high, low or standard risk, and that
classification determines how much scrutiny a shipment gets.
TNFD’s logic is ecological and site-specific. A location counts as sensitive if it meets any one of
five criteria:
“Areas important for biodiversity, including species; and/or areas of high ecosystem integrity;
and/or areas of rapid decline in ecosystem integrity; and/or areas of high physical water risks;
and/or areas of importance for ecosystem service provision, including benefits to Indigenous
Peoples, Local Communities and stakeholders.”
Only one of the five needs to be met.
Nothing about a country’s tier tells you whether a particular field borders a protected area, sits
in a water-stressed basin, or lies in an ecosystem in rapid decline. A plot in a low-risk country
can meet several of TNFD’s criteria. A plot in a high-risk country can meet none.
Sensitive locations are one of two routes into what TNFD calls a priority location. Its glossary
defines priority locations as material locations, meaning places where the business has identified
material nature-related dependencies, impacts, risks and opportunities, and sensitive locations,
meaning places meeting the ecological criteria above. Either route qualifies a location.
That distinction matters here, because an EUDR file speaks to neither route. It cannot tell you a
site is ecologically sensitive, and it cannot tell you a dependency there is material to your
business. So it cannot answer TNFD’s Strategy Disclosure D, which asks reporters to “disclose the
locations of assets and/or activities in the organisation’s direct operations and, where possible,
upstream and downstream value chain(s) that meet the criteria for priority locations.”
The EUDR tells you a product may be sold. Disclosure D asks which of your places matter most for
nature. No due diligence statement contains that.
| Dimension | EUDR | TNFD |
|---|---|---|
| Deforestation definition | Conversion of forest to agricultural use | Also conversion to plantation and severe degradation |
| Time cut-off | After 31 December 2020 | None |
| Scope | Seven commodities, EU market | Land, ocean, freshwater and atmosphere; whole business |
| Spatial resolution | Six-decimal coordinates; polygons above four hectares | No resolution floor |
| “Where” logic | Country risk tier | Ecological criteria at the site |
| Output | Pass or fail (market access) | Continuous risk and dependency |
Collecting supplier location data once, to the stricter of the two definitions, costs less than retrofitting it
The practical consequence is a decision being made in supply chain teams right now, ahead of
30 December 2026.
If you specify your supplier data request to the EUDR minimum, you get the EUDR minimum: seven
commodities, coordinates where required, a 2020 cut-off, and a set of pass results. When the nature
disclosure comes around you go back to the same suppliers and ask again, which is slower and more
expensive the second time, and some of them will have moved on.
If you specify it once against the stricter reading on each axis, the marginal cost at collection
time is close to zero. In practice that means asking for coordinates or polygons even where a
postal address would satisfy the regulation, recording land cover history rather than only
post-2020 status, capturing conversion to plantation and degradation alongside conversion to
agriculture, and extending collection to sites and commodities beyond the seven where you already
have the supplier relationship open.
None of that is a compliance requirement. All of it is cheap while the request is already going
out, and awkward afterward.
Protected area, ecoregion, forest change and water stress layers cover four of TNFD’s five sensitive-location criteria at a screening level
Once you have locations, whether from EUDR work or elsewhere, some of the screening is now
routine. Satellite land cover and forest change data will tell you what a site looked like across
time. Protected area databases will tell you what a site is near. Ecoregion and water stress layers
give you environmental context.
At Continuuiti we run this as an automated screen from coordinates, using the World Database on
Protected Areas for proximity, RESOLVE ecoregions for context, Hansen Global Forest Change for
tree cover loss, and water stress data for basin conditions. That covers four of TNFD’s five
sensitive-location criteria at a screening level.
It does not replace Key Biodiversity Area data, species records, or the ecosystem service
provision criterion, which includes benefits to Indigenous Peoples and Local Communities. Our
deforestation layer measures loss of tree canopy, which is a signal of ecosystem change rather than
a complete measure of ecosystem condition. Those remain separate exercises, and any vendor telling
you a coordinate screen closes them out is overselling.
Free Nature Risk Report
Screen your supplier locations for nature and deforestation risk
Free land-cover change, deforestation exposure, and protected-area proximity for any site. No call required.
Reuse the EUDR evidence and leave the EUDR verdict behind
The coordinates, polygons and land cover history you are assembling for the EU Deforestation
Regulation are more precise than TNFD requires, and they should flow straight into your Locate
work. What does not carry across is the conclusion. A deforestation-free determination is bounded
by a narrower definition, a 2020 start date, seven commodities, one market, and a pass-or-fail
output.
TNFD asks a wider question, and it asks it about places rather than products. The gap between those
two is where nature disclosures quietly understate what a business actually depends on.
Frequently asked questions about TNFD and EUDR
Does your EUDR data count toward a TNFD nature disclosure?
The evidence counts; the conclusion does not. The plot coordinates and land-cover history you collect for the EU Deforestation Regulation feed a TNFD assessment directly. The deforestation-free verdict does not carry across, because it rests on a narrower definition of deforestation, a 2020 cut-off, seven commodities in one market, and a pass-or-fail test.
Can you reuse EUDR coordinates for TNFD’s Locate phase?
Yes. The EUDR requires coordinates to at least six decimal places, and polygons for plots above four hectares, which is finer than anything TNFD asks for. TNFD sets no spatial-resolution floor and treats variable resolution as a strength, so an EUDR-grade dataset comfortably satisfies a nature assessment.
Does an EUDR deforestation-free pass mean a site is not ecologically sensitive?
No. The EUDR sorts risk by country tier, while TNFD judges sensitivity by ecological criteria at the site. A plot in a low-risk country can still border a protected area, sit in a water-stressed basin, or lie in an ecosystem in rapid decline. A pass says the product may be sold, not that the place is unimportant for nature.
Which TNFD LEAP step does the EUDR help with?
L2, dependency and impact screening. TNFD’s food and agriculture and apparel sector guidance both list the EU Deforestation Regulation as a source for L2. It is never listed for L4, the sensitive-locations step, so the EUDR helps you decide which parts of the business to look at, not whether a location is ecologically sensitive.
Does the 2025 EUDR simplification change what data transfers?
For some suppliers, yes. Regulation (EU) 2025/2650 lets micro and small primary operators in low-risk countries give a postal address instead of coordinates. Where that substitution is used the precision advantage disappears, because an address cannot be laid over a forest-loss layer or tested against a protected-area boundary. The relief is confined to low-risk countries and does not open a hole across smallholder supply chains generally.
