The Geolocation Gap in Timber Supply Chains

The European Union Deforestation Regulation (EUDR) requires operators to provide geolocation data corresponding to the plots of land where commodities were produced. In principle, this requirement is straightforward. In the operational reality of timber supply chains, it is often not.

Unlike some other commodities, timber is rarely sourced from centralized production systems with clearly defined boundaries. In regions such as the Southern United States and Western Canada, ninety percent of harvests occur on private land. Three-quarters of that land is owned by non-industrial families and individuals with varied harvesting practices, no obligation, no incentive and often strong reasons not to disclose the exact boundaries of their plots. Even if they disclose, there is limited standardization of geolocation data. Compounding the problem, a single consignment of graded US hardwood lumber in the EU may contain wood sourced from 20,000 to 30,000 individual plots. As a result, the information required for compliance is either not available or not always readily available in a complete or consistent form.

This creates a gap between regulatory expectations and supply chain realities. The challenge is determining how accurate and reliable geolocation data can be developed in environments where it has historically been difficult to obtain.

This paper outlines that challenge and presents a practical, collaborative approach developed by 11Foundry and Epoch.

Expanding from Data Collection to Data Development

In many compliance frameworks, required data is assumed to be directly available from supply chain participants. In timber, this assumption often breaks down.

A more effective approach is to expand beyond data collection to include data development through a combination of inputs and methods. Supplier-provided data remains central. However, it may need to be supplemented, validated, refined, or in some cases reconstructed using additional sources of information.

This includes historical records, spatial context, and independent geospatial observation. The objective is not to bypass what data may be provided directly by upstream partners, but to arrive at accurate and reliable geolocation information through a structured and evidence-based process, even when direct data is incomplete or difficult to obtain.

This expanded approach, combining data collection and data development, is central to making EUDR compliance workable in timber supply chains.

A Practical Methodology for Developing Geolocation Data

To address this challenge, 11Foundry and Epoch have developed a combined methodology that integrates geospatial analysis with operational due diligence workflows.

This methodology solves cases where harvest sites are not disclosed and reported by producers and where harvest sites are disclosed across varying levels of accuracy or consistency.

For cases where no harvest sites are disclosed, Epoch’s geospatial AI technology stack identifies harvest sites (whether through clear cuts or through thinning) directly across large areas of interest - counties, states or entire sourcing regions, all without any input from producers. This approach enables operators to generate the geolocation data EUDR requires, at scale, without asking producers to disclose commercially sensitive information — whether that is precise boundary data, standing timber inventories, or harvest schedules that inform their negotiating position with buyers. Because this approach only identifies the harvest sites, entire plot boundaries are never shared. Producer privacy is preserved. Anti-trust constraints are respected. And operators get a defensible, evidence-based due diligence system that holds up to regulatory scrutiny.

For cases where harvest sites are disclosed, 11Foundry’s Command Center provides the structure where geolocation data is collected, validated, augmented (if necessary), and evaluated with Epoch’s capabilities, which incorporate multiple authoritative datasets, including JRC, GLAD, TMF, and other global forest monitoring layers, alongside advanced analytical techniques such as Continuous Change Detection and Classification (CCDC). These steps are documented with a complete audit trail as part of the due diligence.

Together, these capabilities support several key processes:

  • Harvest site detection at scale — Epoch’s platform scans entire sourcing regions (counties, states) to identify and delineate all harvested plots, generating plot-level geolocation data without requiring producer-submitted boundaries. This directly addresses the privacy constraints that make traditional data collection impractical.
  • Point-to-polygon resolution — Where only point data or GPS coordinates are available, Epoch’s algorithms delineate likely harvest area boundaries, converting limited inputs into complete geolocation datasets.
  • Supply shed generation — When data is limited to broader sourcing regions, geospatial analysis identifies areas of likely harvest activity and generates sourcing area boundaries automatically.
  • Supplier data validation — Supplier-provided polygon data can be ingested into Command Center and cross-referenced against Epoch’s independent satellite observations to identify inconsistencies that require review.
  • Structured due diligence workflows — Across all scenarios, Command Center maintains a clear, auditable record of how geolocation data was developed, validated, and documented.

This methodology does not eliminate the need for supplier engagement. It provides a structured way to develop, validate, and contextualize geolocation data when direct collection alone is not sufficient.

Where This Approach Matters Most

This approach is particularly relevant in supply chains characterized by fragmentation and limited data availability. This includes regions with distributed ownership, aggregated sourcing, and developing data systems.

In such contexts, the ability to combine supplier information with independent geospatial analysis can materially improve both the quality of geolocation data and the consistency of due diligence processes.

In supply chains where high-quality geolocation data is already available, these capabilities can still play an important role in validation and verification.

Conclusion - A Practical Path Forward for EUDR Compliance in Timber

The challenge of geolocation under EUDR in timber supply chains is structural. It reflects the way these supply chains are organized, not simply a lack of technology or data.

Addressing this challenge requires a system-level response. Geolocation data must be developed through a combination of inputs. It must be validated using independent methods. It must be used within a structured and well-documented due diligence process.

The collaboration between 11Foundry and Epoch represents a best-in-class approach to this problem. By integrating geospatial intelligence with operational due diligence systems, it provides a practical framework for developing, validating, and managing geolocation data in line with regulatory expectations.

Proven Technology, Trusted by Leading Platforms

Epoch’s geospatial intelligence platform is already the first-mile data layer for several of the largest supply chain compliance platforms globally:

  • Assent — delivering automated EUDR compliance across 800+ enterprise customers
  • Sphera — powering first-mile intelligence for their Supply Chain Transparency platform, serving over 8,000 customers
  • Altana — enabling end-to-end traceability and environmental monitoring across agriculture and forestry value chains

This partnership with 11Foundry extends these proven capabilities to the timber trade’s most specialized compliance platform, giving timber operators access to the same caliber of geospatial intelligence that major enterprises across other commodity sectors already rely on.