You are already paying to collect EUDR deforestation data, and a TNFD nature disclosure is also on the desk. The obvious hope is that one job covers the other. It covers half. The other half is where a nature disclosure quietly understates what a business depends on. Settle that boundary before the next data request goes out to suppliers.
The reuse question in four points
- 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 stays behind. 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. Collecting it again later means paying 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. 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: reuse the evidence and leave the conclusions behind. The coordinates you gather for EUDR are more precise than TNFD asks for, and they can go straight into your nature assessment. 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
TNFD itself makes this link.
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.
TNFD also reuses the EUDR’s content. Its 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 choose which parts of your business to look at. Whether a place is sensitive is assessed separately, at L4.
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.
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 meter. A polygon traces the actual shape of the field.
TNFD sets no such requirement. 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 an EUDR inspector will comfortably satisfy a nature assessment. That is why the reuse instinct is right.
The EUDR also asks a question TNFD never asks. To be placed on the EU market, products must be deforestation-free, and the EUDR also requires 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 plays no part in its assessment.
So each framework has a requirement of its own. Next come 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 severe degradation of forest that is never converted
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.”
The EUDR’s definition is wider than it looks. Agricultural use includes crop plantations such as oil palm, rubber, cocoa and coffee, so clearing natural forest for any of them is deforestation under both frameworks. Turning primary or naturally regenerating forest into a plantation forest, the regulation’s term for an intensively managed tree plantation for wood, fiber or energy, counts as forest degradation. The EUDR states that any deforestation or forest degradation on a plot disqualifies all commodities from that plot.
The gap is TNFD’s limb (iii). A forest that is logged or burned and left badly degraded, without being turned into farmland or a plantation, can pass the EUDR’s tests. TNFD counts severe and sustained degradation as deforestation. For a business sourcing from landscapes where forests are being degraded without being cleared, a clean EUDR file can sit alongside a material nature impact that has not been 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 passes the deforestation test today. The test looks no 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. The EUDR’s deforestation test ignores a conversion made before 2021. A nature assessment counts it.
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 either goes to market or stays off it.
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, and this piece leaves it out. 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 in place of coordinates
Those four gaps are all about what an EUDR pass means. There is also a separate limit on the underlying data itself.
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 in place 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. That tier is large: 140 countries. The relief applies only where the small producer itself places the product on the EU market or exports it. Where an importer buys from smallholders and places the product on the EU market, the importer is the operator and must still collect plot coordinates.
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. Each country, or part of a country, is classed as high, standard or low risk. The class sets the minimum share of companies that national authorities must check each year, and operators sourcing only from low-risk countries may use simplified due diligence.
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, including crop plantations; conversion to plantation forest counts as degradation | Also severe degradation without conversion |
| 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 the full land cover history of each plot, capturing forest degradation where no conversion took place, alongside conversion to farmland and plantations, and extending collection to sites and commodities beyond the seven where you already have the supplier relationship open.
These steps go beyond the regulation. They cost little while the request is already going out, and more if added later.
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 OpenStreetMap protected-area boundaries (© OpenStreetMap contributors) 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. OpenStreetMap protected areas are mapped by contributors, so coverage varies by country.
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. That signals ecosystem change and gives a partial measure of ecosystem condition. Those remain separate exercises, and any vendor telling you a coordinate screen closes them out is overselling.
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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. The conclusion stays behind. 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. The EUDR asks it about products. The gap between those two is where nature disclosures quietly understate what a business depends on.
Frequently asked questions about TNFD and EUDR
Does your EUDR data count toward a TNFD nature disclosure?
The evidence counts. The plot coordinates and land-cover history you collect for the EU Deforestation Regulation feed a TNFD assessment directly. The deforestation-free verdict stays behind, 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. Whether the place matters for nature is a separate question.
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. The EUDR helps you decide which parts of the business to look at, and L4 decides 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 in place 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 applies only where the small producer itself places the product on the EU market or exports it. An importer buying from smallholders still needs plot coordinates.
