The regulatory clock and the wrong question
Regulation (EU) 2023/1115, the EU Deforestation Regulation, applies from 30 December 2026, with a six-month extension to 30 June 2027 for micro and small enterprises, according to the French government’s EUDR explainer. It covers seven commodities — coffee, cocoa, rubber, oil palm, soya, cattle and wood — and prohibits placing on the EU market or exporting from it products that contributed to deforestation or forest degradation after 31 December 2020.
The public debate about soy and the EUDR tends to ask whether Brazilian soy is clean enough. That is not where the binding constraint sits. A 2026 case study by Proforest and RMR Consulting, supported by GIZ, modelled three Brazilian export corridors for a single soy trader and found that the deforestation-free requirement is not the primary operational barrier for most traders, because only a small volume of soy in Brazil is not deforestation-free. The barrier is proof: the data, paperwork and physical segregation needed to demonstrate compliance for a specific lot moving through a specific port.
That distinction matters for anyone tracing material flows rather than reading press releases. A traceability system can generate enormous volumes of geolocation data and still fail to change land use, because the constraint is not the satellite layer. It is the silo, the rail siding, the barge terminal and the truck route.
Three corridors, three different problems
The Proforest/RMR study is explicit that it is based on a single trader and that more research is needed. Its value is not statistical representativeness but mechanism: it shows how the same regulatory requirement lands differently depending on the physical structure of each export route.
Rio Grande: origin data is the bottleneck
In Rio Grande, Rio Grande do Sul, the study finds a high prevalence of smallholder farmers selling through intermediaries and cooperatives, which makes farm-level origin data difficult to obtain. The problem here is upstream of the port. A cooperative may know which members delivered to which silo on which day, but the chain from individual plot to aggregated lot runs through intermediaries whose records are not built for parcel-level traceability. No amount of satellite monitoring resolves that; it is a records and contracting problem.
Santos: the infrastructure is shared
In Santos, São Paulo, the study documents significant mixing between traders at the railway terminal and within the port itself, and states that this cannot easily be solved without major infrastructure modifications or inter-trader collaboration. This is a different failure mode: the origin data may exist, but the physical system co-mingles volumes from multiple traders before export. Segregation at Santos is a capital and coordination problem, not a data problem.
Santarém: tractable, but not free
The Santarém corridor, in Pará, sourcing from Mato Grosso, is described as a more viable path to compliance. The study attributes this to two factors: the predominance of large-scale farms in Mato Grosso, which makes traceability considerably more tractable, and a processing facility that already has dedicated intake lines and segregated storage to support compliant batching.
This is the crux of the argument. Santarém is not better because the soy there is more deforestation-free. It is better because the physical infrastructure already permits separation. Traceability, in other words, is an industrial-logistics property before it is a data property.
The emissions trade-off, stated precisely
The study concludes that, under current conditions, the trader would likely shift 100% of EU-bound soybean meal to the Santarém route to ensure cost-effective EUDR compliance. A Life Cycle Assessment found that under a fully segregated, EUDR-compliant scenario, logistics-related greenhouse gas emissions would be approximately 48% higher than under business-as-usual conditions.
The mechanism is specific: increased distances and higher-carbon transport modes, with road transport replacing rail and waterways. This is not a rounding error. It is a structural consequence of routing segregated volumes through a corridor that requires more trucking over longer distances.
Two caveats must travel with that number. First, the study is based on a single trader; the authors state the findings are likely representative of the sector but do not claim sector-wide measurement. Second, the 48% figure covers logistics-related emissions only. It does not offset or diminish land-use emissions, which remain the larger stake. The finding is a trade-off within the compliance regime, not a verdict on whether the regime is worth having.
What the farm-level picture actually shows
Context on Mato Grosso helps calibrate how much of the problem is land use versus proof. A separate commercial assessment published via LinkedIn, using SIGEF land registry data, a 2020 forest-cover baseline, RADD and GLAD deforestation alerts, verified alerts and soy planted-area maps, categorized approximately 97.21% of assessed soy plot area as compliant and about 2.79% as non-compliant. The authors describe the 2.79% as likely a lower-bound estimate and state that applying stricter rules to unregistered plots could raise the non-compliant share to around 5% of the total. They also identified 36 soy plots inside designated Permanent Forest Reserves across eight districts.
These figures come from a single commercial analysis, not a government dataset, and should be read as an order-of-magnitude indication rather than an official statistic. But the direction is consistent with the Proforest/RMR finding: most Mato Grosso soy area is not the deforestation problem. The problem is proving which lots are clean and keeping them physically separate from the rest.
What a useful traceability test looks like
If the binding constraint is segregation infrastructure, then traceability proposals should be judged on whether they identify the specific port, silo and transport mode where separation happens — and whether they account for the emissions delta of that separation. A system that produces a due diligence statement without naming the physical point of segregation is a documentation exercise, not an environmental intervention.
Three practical implications follow from the corridor evidence:
- Corridor-specific investment beats generic platform promises. Santos needs segregated terminal capacity or inter-trader agreements; Rio Grande needs cooperative-level data systems that connect member plots to delivered lots. These are different projects with different cost structures.
- Rail and waterway capacity is an EUDR compliance asset. If segregation pushes volumes onto roads, the emissions penalty is a direct function of missing low-carbon infrastructure. Investment in rail and barge capacity changes the compliance calculus, not just the transport bill.
- Inter-trader collaboration is unavoidable at shared terminals. Where multiple traders use the same railway terminal and port, no single company can segregate its volumes alone. The study names this explicitly for Santos.
Where independent monitoring fits
Platforms such as Trase map global supply chains of agricultural commodities and provide insight into how consumer markets are exposed to deforestation via their imports. That is useful for identifying which municipalities and exporters carry risk. It is not a substitute for the silo-level segregation that the EUDR’s due diligence system requires. The two layers answer different questions: Trase-style analysis tells you where exposure concentrates; corridor-level logistics analysis tells you whether compliance is physically achievable and at what emissions cost.
The Proforest/RMR study closes by pointing toward a need to rethink what level of traceability is actually useful for driving action on deforestation in commodity markets and represents an effective allocation of resources. That is the right question. For the e-guana.net audience, the answer will be found in named ports, named terminals, named transport modes and measured emissions deltas — not in the volume of data a platform claims to ingest.
FAQ
Does the EUDR require farm-level geolocation for soy?
The regulation requires operators to collect information attesting to compliance, including the locations where products were grown, harvested or raised, according to the European Commission’s Green Forum guidance. Non-EU producers do not have direct obligations unless they place products on the EU market, but they may be asked to provide location data to help EU-based operators meet their requirements.
Is Brazilian soy mostly deforestation-free already?
The Proforest/RMR case study states that only a small volume of soy in Brazil is not deforestation-free, and that it is already viable to provide deforestation-free soy. A separate commercial assessment of Mato Grosso found roughly 97% of assessed soy plot area compliant, with a caveat that stricter treatment of unregistered plots could raise the non-compliant share to around 5%. These are not official government statistics.
Why would compliance increase emissions?
Because segregation requires moving specific volumes through specific corridors. The Proforest/RMR Life Cycle Assessment found logistics-related emissions approximately 48% higher under full segregation for the modelled trader, driven by longer distances and road transport replacing rail and waterways.
Does a certification scheme satisfy EUDR due diligence?
The European Commission’s guidance acknowledges the role of certification and third-party verification schemes, but the Green Forum page does not establish that certification is equivalent to due diligence. Operators remain responsible for their own due diligence statements in TRACES.
When does the EUDR apply to soy imports?
From 30 December 2026, with a deadline of 30 June 2027 for micro and small enterprises, according to the French government’s EUDR explainer. The regulation was amended by Regulation (EU) 2025/2650 as regards its date of entry into application and certain implementing rules.