Papua New Guinea’s “low-risk” rating makes EU deforestation compliance simpler. It does not make it optional, and it does not make it permanent. The exporters who keep their place in European markets will be the ones who can prove, plot by plot, where their products come from.
Eywa Systems PNG
On 30 December 2026, the European Union Deforestation Regulation (EUDR) finally applies. After two postponements, a targeted revision and more than two years of debate, the question facing producers and exporters is no longer whether the rules will bite, but whether their data will be ready when they do.
For Papua New Guinea, the stakes are unusually specific. Coffee, cocoa, palm oil and timber are all covered by the regulation, and all of them sustain rural livelihoods across the country. PNG also holds a status that many exporting nations would envy: the European Commission has classified it as a low-risk country.
That classification is genuinely helpful. It is also widely misunderstood. This article explains what the EUDR requires, what “low risk” does and does not change, and what PNG’s producers, exporters and institutions can do in the time that remains.
The deadline is real this time
The EUDR (Regulation (EU) 2023/1115) entered into force in June 2023 and was originally meant to apply from the end of 2024. It was pushed back once to December 2025, and then again through Regulation (EU) 2025/2650, published in December 2025.
The current dates are now fixed in law:
- 30 December 2026 for large and medium-sized operators and traders
- 30 June 2027 for micro and small operators
There is little appetite in Brussels for a third delay. In May 2026, the Commission published its mandated simplification review alongside updated guidance and FAQs, and made clear it would not reopen the text of the regulation. Instead, it has focused on practical fixes: fine-tuning the list of in-scope products (finalised in July 2026, with items such as cattle hides and retreaded tyres removed) and upgrading the EU Information System that receives due diligence statements. The Commission estimates the combined simplifications will cut annual compliance costs for affected companies by around three-quarters.
Simpler, yes. Cancelled, no. The core obligations remain intact.
What the EUDR actually asks for
The regulation covers seven commodities — cattle, cocoa, coffee, oil palm, rubber, soy and wood — along with many products made from them. Before any of these can be placed on the EU market, the company placing them there must be able to show three things:
- Deforestation-free. The product was grown or harvested on land that has not been deforested or, in the case of wood, degraded after 31 December 2020.
- Legally produced. The product complies with the relevant laws of the country of production, covering areas such as land-use rights, environmental protection, forestry rules, labour and human rights, the rights of third parties including free, prior and informed consent, and tax and trade rules.
- Documented. The first operator placing the product on the EU market submits a due diligence statement to the EU Information System, backed by supporting information.
At the heart of that information is geolocation: the precise location of every plot of land where the commodity was produced. For plots larger than four hectares (other than for cattle), a single GPS point is not enough; the full boundary must be mapped as a polygon.
The consequences of getting it wrong are significant. Member States must be able to impose fines of at least 4% of a company’s annual EU turnover, confiscate goods and exclude offenders from public procurement. In practice, that means European buyers will simply not accept products they cannot trace.
Where Papua New Guinea stands
In May 2025, the Commission published its first country benchmarking, sorting countries into low, standard and high risk. Papua New Guinea was placed in the low-risk category.
For operators sourcing from PNG, this means simplified due diligence. They must still collect the required information, including plot geolocation and evidence of legality, but they are generally not required to carry out the full risk assessment and risk mitigation steps that apply to standard-risk origins. The December 2025 revision added further relief: micro and small primary producers in low-risk countries can meet their obligations through a streamlined, one-off declaration rather than repeated filings.
This is a real advantage. It lowers costs, reduces paperwork and should make PNG an attractive origin for European buyers looking to manage their compliance burden.
Why “low risk” is not a safe harbour
It would be a mistake, however, to treat the classification as a pass. There are four reasons for caution.
Simplified is not the same as exempt. The information requirements — including geolocation — still apply. A low-risk rating reduces the analysis operators must do with the data. It does not remove the need to have the data in the first place.
The rating is contested. PNG’s classification drew criticism from environmental organisations as soon as it was published. In June 2026, Forest Trends pointed to two of PNG’s own official documents — a 2025 money-laundering risk assessment of the forestry sector and a March 2026 parliamentary inquiry into log export monitoring — as evidence of governance risks that the benchmarking methodology does not capture. The Commission has indicated that benchmarks will be reviewed. A country’s classification can change, and supply chains built on the assumption that it won’t are fragile.
Buyers carry the liability, so buyers set the bar. The European importer, roaster or manufacturer is the party exposed to fines. Many will ask for plot-level data from every supplier regardless of country rating, because it protects them. Certification schemes help, but they do not replace verifiable geolocation and legality evidence.
New information changes the obligation. If an operator becomes aware of information suggesting that a product may not be compliant, simplified due diligence is no longer sufficient. A single credible allegation against a supply chain can trigger full scrutiny overnight.
The practical conclusion is straightforward: PNG’s exporters should prepare as if the rating could change tomorrow, and use the low-risk status as a head start rather than a shortcut.
The real bottleneck is data, not regulation
PNG’s challenge is not understanding the rules. It is producing trustworthy evidence under conditions that make data hard to collect.
Around 97% of land in Papua New Guinea is held under customary tenure. Much of the country’s coffee and cocoa is grown by smallholders on plots that have never been formally surveyed. Farms are often remote, connectivity is patchy, and produce frequently passes through several buyers before it reaches an exporter, mixing along the way. Demonstrating legality where land rights rest with clans rather than titles requires documentation that most supply chains have never had to assemble.
None of this is insurmountable. Fairtrade’s producer network in the Asia-Pacific region has already been training PNG cocoa and coffee cooperatives to collect and manage farm geolocation data. The lesson from that work, and from similar efforts worldwide, is consistent: the technology is available; the difficulty lies in collecting data once, keeping it accurate, and connecting it across the supply chain.
What good preparation looks like
Based on our work building land, forest and environmental information systems in Papua New Guinea, we see five foundations that separate EUDR-ready supply chains from the rest.
- Map once, maintain continuously. Register every producer and map every plot using mobile tools that work offline in the field, capturing polygons wherever plots exceed four hectares. Treat the resulting registry as living infrastructure, not a one-time survey.
- Verify against the 2020 baseline. Check each mapped plot against satellite-based forest cover data for the 31 December 2020 cut-off, and keep a record of the analysis. Where national forest monitoring data exists, use it alongside global datasets.
- Connect plots to shipments. Build a chain of custody that links each consignment back to the plots that supplied it, using batch identifiers and clear segregation rules at collection points, fermenteries, mills and warehouses.
- Evidence legality in a way customary tenure can support. Assemble the documents that demonstrate lawful production — land-use agreements, landowner group records, permits and approvals — and store them digitally against the plots they relate to.
- Make data portable. European buyers need information in formats the EU Information System accepts, such as GeoJSON. Systems should export clean, validated data packages on request, and should be able to exchange information with the national agencies that hold land, forest and permitting records.
Beyond compliance: data as a national asset
It is tempting to see the EUDR as one more external burden on a developing economy. There is another way to look at it.
The same foundations the regulation demands — reliable land information, credible forest monitoring, transparent supply chains — are the foundations PNG needs for carbon markets, REDD+ results-based payments, safeguards reporting and sound land-use planning. A farm registry built for coffee traceability can inform agricultural extension services. Forest-change analysis done for cocoa exporters strengthens national monitoring. Well-governed legality evidence reduces the governance risks that critics of the benchmarking have highlighted.
Countries and companies that invest in this data now will do more than protect market access. They will be able to show buyers, investors and development partners, with evidence rather than assurances, that their products are responsibly produced. In a market increasingly defined by proof, that is a competitive advantage.
How Eywa Systems can help
Eywa Systems designs and builds digital systems for climate, land and environmental governance, with a strong track record in Papua New Guinea, including registry systems, safeguards information management and forest monitoring. We apply user-centred design throughout, working with producers, exporters and government agencies to build tools that work in real field conditions.
For EUDR, we support organisations with readiness assessments, farm and plot mapping solutions, GIS-based deforestation checks, traceability and chain-of-custody systems, and data integration with national information systems.
With the deadline weeks away, the best time to start was yesterday. The second-best time is now. If you are an exporter, cooperative, industry body or government agency preparing for the EUDR, we would welcome a conversation.
Contact Eywa Systems at https://eywasystems.com/