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Quick summary: Learn how aggregated traceability under EUDR allows you to stay compliant—even when mixing products from multiple sources. Understand declaration in excess, risk mitigation, and real-world examples.
If you’re an agri-exporter, trader, or cooperative dealing with cocoa, coffee, rubber, or palm oil—you know that real-life sourcing is messy. Farmers deliver in small volumes, batches get blended at the warehouse, and shipments are rarely segregated plot by plot. The EU Deforestation regulation demands plot-level traceability—meaning every product placed on the EU market must be proven deforestation-free and legally sourced. Sounds great on paper, but for those working in the field, the idea of linking every bean, nut, or bunch back to a single farm can feel impossible. That’s where the concept of aggregated traceability under EUDR comes in.
Instead of requiring one-to-one sourcing records, EUDR allows exporters to declare multiple verified plots—even if you can’t say which one exactly produced the product in the shipment. Known as declaration in excess, this model gives your supply chain some breathing room, while still meeting the EU’s strict due diligence requirements. For agri-businesses dealing with thousands of smallholders or mixed commodity silos, aggregated traceability under EUDR is not just a workaround—it’s a lifeline. This article breaks down how it works, what’s allowed, what’s not, and how to stay compliant without disrupting your sourcing model.
Key Takeaways
If you’re a cocoa cooperative, a coffee exporter, or a rubber processor, you probably collect from dozens (or hundreds) of farmers. Once the beans or latex hit the silo or processing tank, they’re mixed together, because that’s how logistics and efficiency work on the ground.
But here’s the twist: EUDR doesn’t ask for perfect isolation of every batch—it asks for perfect clarity of where it came from.
That’s where aggregated traceability under EUDR comes in.
Aggregated traceability means you can declare multiple known, compliant plots of land as the possible sources of a product—even if you can’t link each item to one specific plot.
This approach—formally referred to as “declaration in excess”—is EU-approved and lets you ship mixed batches as long as you know (and can prove) all the possible plots involved.
It’s like saying: “This shipment came from Farms A, B, and C. We’re not sure which farm’s beans are in this specific bag—but all three are legally compliant and deforestation-free.”
Imagine you’re making a big pot of vegetable soup with carrots from Farm A, potatoes from Farm B, and beans from Farm C. Once it’s mixed, you can’t tell which spoonful contains which ingredient from which farm—but you can list every farm that contributed to the pot.
That’s aggregated traceability. You’re not guessing—you’re confidently declaring all possible sources because they’re all known, verified, and compliant.
EUDR compliance requires traceability to the plot of land where the commodity was grown, not just to the cooperative or region.
But recognizing the realities of mixed supply chains, Article 9 and 10 of the regulation allow for declaration in excess. As long as you:
Then you’re compliant—even if the batch is blended.
It’s the middle ground between rigid traceability and field-level practicality. It acknowledges the complexity of agri-sourcing while still meeting the EU’s demand for transparency.
If your business handles bulk, mixed, or multi-origin commodities, this model allows you to:
Imagine you run a cocoa cooperative in Côte d’Ivoire, sourcing beans from 600 smallholders scattered across remote villages. During the harvest season, farmers deliver their beans to your warehouse. You don’t store each farmer’s lot separately—it would be logistically impossible and too costly.
Instead, you bulk everything into a single silo and blend it for fermentation and drying.
Now here’s the challenge:
You’re preparing to export a 25-ton shipment to Europe.
The EU Deforestation Regulation (EUDR) requires you to prove this cocoa is:
But you can’t say exactly which 100 or 150 farms the final shipment came from—it’s all mixed. So what do you do?
You create a declaration that includes every farm (A to Z) that contributed to the bulked silo since it was last emptied.
Even if only 10 farms’ beans ended up in this shipment, you declare all 600 that were part of the full harvest cycle.
You ensure:
Your DDS includes:
Here’s the tradeoff:
By using declaration in excess, you gain flexibility—but you also accept responsibility for the compliance of every farm listed.
If even one of the 600 plots is found to be non-compliant, the entire DDS could be rejected. That’s why thorough due diligence isn’t optional—it’s everything.
Think of it like co-signing a group loan. Everyone has to be clean, or the whole shipment’s in jeopardy.
Do I need to segregate every farm’s beans? Can I comply without expensive logistics?
Yes, with aggregated traceability
What if I don’t know which farms are in the final batch? Is there a safe way to mix?
Declare all possible sources
Is this even allowed under EUDR? Will this pass an EU audit?
Yes—if all declared plots are compliant and documented
Aggregated traceability isn’t a shortcut—it’s a smarter system built for real-world sourcing. And with the right tools, you can handle it without losing control.
If you’re in the business of sourcing from hundreds—or even thousands—of smallholders, you already know: segregating every farmer’s output is not just inefficient, it’s often impossible.
You don’t have 200 silos.
You don’t have the luxury of tracing every bean, cup, or drop to a specific plot.
What you do have is the pressure of EUDR compliance—and the need to keep your business running without blowing up your operations.
That’s exactly where aggregated traceability offers a smart, scalable alternative.
Instead of setting up dedicated infrastructure to separate product by farm or plot, you can mix compliant materials from known sources, track them digitally, and maintain transparency without redesigning your supply chain.
Exporters want to comply—but not at the cost of logistics breakdowns. Aggregated traceability helps you do both.
Whether it’s cocoa in Ghana, rubber in Thailand, or coffee in Colombia, most sourcing still depends on smallholder networks—where data fragmentation and documentation gaps are real.
Aggregated traceability respects that reality. It lets you:
This is how cooperatives can stay competitive—and compliant—without burning out their field teams.
Your silos, processing tanks, and containers are designed to blend and move high volumes. Segregation would require new equipment, extra labor, and double the storage.
With aggregated traceability, you keep using your current flow, while building a digital layer of compliance over your existing infrastructure.
Exporters often ask: “Do I need to reinvent everything to be EUDR-ready?”
The answer: Not if you’re doing aggregated traceability right.
EUDR isn’t just about sending shipments—it’s about being able to prove your due diligence at any time.
Aggregated traceability allows you to:
It’s like having your compliance suitcase packed—ready for inspection, without needing to scramble.
Aggregated traceability under EUDR sounds like a win-win—and it is.
But let’s be honest: flexibility comes with responsibility.
Yes, you can mix products from multiple compliant plots.
Yes, you can submit a Due Diligence Statement without matching each kernel to a farm.
But you’re also saying to the EU:
“I vouch for every plot on this list. If one fails, I own the fallout.”
Imagine declaring 300 farm plots for a rubber shipment.
299 are fully compliant. But the 300th? Turns out it was linked to recent illegal clearing.
Even if only 1% of your shipment came from that farm…
Aggregated = Collective accountability. That’s the trade-off.
The EU is already watching for “lazy declarations”:
Exporters ask: “Can I just include all farmers in the cooperative to stay safe?”
The answer: Only if you’ve done full due diligence on every single one.
Aggregated traceability works best when backed by strong systems and verified data. Here’s how to reduce risk:
1. Limit declarations to verified plots only
Don’t list farmers you haven’t GPS-mapped, checked for land rights, or validated for deforestation-free status.
2. Use land-use history tools and satellite overlays
Platforms like TraceX help you run instant checks on plot clearance timelines using remote sensing data.
3. Conduct random plot audits
Use spot checks to keep your farmer network honest—and your DDS defensible.
4. Keep a clean, digital audit trail
The more you can show during an inspection (KML files, farmer declarations, risk reports), the more credible your case.
The smart play is simple: Declare only what you can prove.
When you back every geolocation with real data, you don’t just meet the regulation—you build resilience into your business.
Managing EUDR compliance manually—especially when dealing with hundreds of farmers, multiple sourcing zones, and mixed batches—can feel overwhelming. That’s where a purpose-built traceability platform like TraceX becomes more than just a tool—it becomes a compliance partner.
The TraceX EUDR platform is designed specifically for the realities of agri-exporters, processors, cooperatives, and trader networks. Here’s how it helps you stay compliant, without reinventing your operations:
TraceX lets you map every batch of your commodity (e.g., cocoa, rubber, palm, coffee) to the plots of land it may have originated from. This is core to enabling aggregated traceability under EUDR.
Example: A cocoa shipment can be linked to 50 farms based on your internal silo tracking, and you can declare all 50 plots—with full confidence and documentation.
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TraceX empowers field teams and farmer networks to:
All this information is stored securely and version-controlled, creating a full compliance trail that can be accessed anytime.
From onboarding a new farmer to validating a shipment, everything is traceable—down to the coordinates.
Creating a compliant Due Diligence Statement (DDS) manually? Time-consuming. Prone to error. Risky.
With TraceX:
This isn’t just a tool—it’s your DDS factory.
Don’t just declare a farm—evaluate it.
TraceX uses integrated satellite data, land-use history, and deforestation alerts to:
You’ll always know:
It’s like having a compliance radar guiding your sourcing team.
When you’re managing a complex, multi-origin supply chain with over a thousand farmers, staying EUDR-compliant can feel daunting. That’s exactly where TraceX comes in. The platform centralizes GPS mapping and documentation capture, making it easy to onboard and verify large farmer networks. Instead of struggling with manual DDS creation, TraceX auto-generates compliant Due Diligence Statements and streamlines submission to the EU system. Concerned about the risk of mixed-batch rejection? TraceX’s real-time plot-level risk scoring helps you identify and mitigate potential red flags before they become compliance issues. And when it’s time for an audit, you won’t be digging through emails or paper files—the platform keeps everything organized in a structured, audit-ready data vault. With TraceX, EUDR compliance becomes smart, scalable, and stress-free.
In a perfect world, every bean, bunch, or bale would be traceable to a single plot. But real-world sourcing—especially in smallholder-heavy supply chains—isn’t that simple. Aggregated traceability under EUDR offers a grounded, regulation-backed way to stay compliant without tearing apart your operational model. It gives exporters, traders, and cooperatives the flexibility to mix, the clarity to declare, and the tools to defend their compliance—as long as they do the work upfront.
The key takeaway? You don’t have to segregate your entire supply chain—just secure it. With the right digital tools and responsible declarations, aggregated traceability becomes not just a loophole, but a long-term strategy for EUDR success.
Yes, you can—but only if all contributing farms are known, verified, and compliant.
EUDR allows aggregated traceability, which means you can mix commodities (like cocoa, rubber, or palm) from different farms as long as:
You cannot mix product from unknown or unverifiable origins. Every declared plot must be traceable, legal, and EUDR-compliant.
A declaration in excess is when you list more plots of land than may have directly contributed to a shipment—because you can’t precisely match each item to a farm.
Example: If you bulk cocoa beans from 100 farms in a silo and export a batch, you declare all 100 farms as possible sources—even if only 40 farms’ beans made it into that shipment.
This is accepted under EUDR as long as all declared plots are compliant, and you assume full responsibility for verifying each one.
To prove compliance for mixed batches, you must:
