The 31 December 2020 cutoff, and why tree-cover loss is not deforestation

The EUDR defines deforestation-free as produced on land that has not been subject to deforestation after 31 December 2020 (Art. 2). The date is a fixed baseline: what mattered before it does not disqualify a plot; conversion of forest to agricultural use after it does.

Tree-cover loss is a signal, not a conclusion

Global datasets such as Hansen Global Forest Change, the EU Forest Observatory, RADD and GLAD alerts report tree-cover loss. Over a coffee plot, loss can come from pruning, shade-tree management, replanting, storm damage, or commission error in the data, none of which is deforestation in the EUDR sense.

EU policy is explicit that tree-cover loss is not equivalent to deforestation. A post-cutoff loss signal means a human should review the parcel boundary and pre-2020 land use before drawing a conclusion.

How Sylva reads the signal

Sylva uses WHISP (the Open Foris / FAO whisp.openforis.org service) as the authoritative screen and weighs its perennial-crop verdict first. A plot lands in one of three states:

• Deforestation-free: no post-cutoff loss on land that was forest at the cutoff, and a low commodity-risk verdict.
• Inconclusive: a post-cutoff loss signal on forest, or a more-information-needed verdict; the operator reviews it against the boundary and pre-2020 imagery before concluding.
• Deforestation detected: a high commodity-risk verdict or a new post-cutoff plantation; the batch cannot proceed without resolution.

The discriminator is the 2020 forest baseline. An ambiguous signal on forest is sent for review rather than auto-failing the plot, which is what coffee needs, while genuine post-cutoff conversion of forest is never waved through. A loss reading on land that was not forest in 2020 reads low, kept as a noted flag, since it is not the conversion of forest the Regulation defines as deforestation (Art. 2(3)).