Persistent cloud cover over tropical timber-producing regions is forcing EUDR compliance assessments to rely on satellite image mosaics compiled over several months, creating verification gaps in medium- and high-risk zones. That is according to Georgios Raptakis, product manager for TradeAware at geospatial software company LiveEO, who said cloud and shadow can reduce confidence levels and delay due diligence assessments for operators whose supply chains run through West Africa, Southeast Asia, and Latin America.
And the exposure is unevenly distributed, with the monitoring deficit concentrated where the EUDR’s traceability demands are most acute. “The problem hits hardest precisely where the EUDR is most focused,” according to Marc Loubad, CEO of information services company Veridian Geospatial, pointing to the structural mismatch between where the regulation demands plot-level verification and where surface visibility is most routinely compromised.
And with large and medium operators required to file verified due diligence statements through the EU’s TRACES NT portal from 30 December 2026, the burden of closing cloud-related verification gaps falls entirely on operators and the platforms they procure. The portal is a submission system, not a compliance tool — it does not store supplier data between filings, provide satellite imagery, or perform risk assessments.
“The key issue is whether cloud and shadow prevent a reliable reading of the land surface across enough observations within the relevant time window,” Raptakis said, adding that in persistently cloudy regions, operators may need image mosaics spanning several months before any defensible picture of the land surface can be assembled.
And whilst Raptakis acknowledged “a trade-off between timeliness, cost, and certainty in very cloudy regions,” Patrick Houdry, Starling manager at Airbus Defence and Space, offered a more measured assessment of the exposure: “Cloud cover may create temporary verification gaps, but deforestation and land-use change are generally analysed over relatively long periods — on a monthly or annual scale — which increases the chances of obtaining cloud-free images in the case of optical imagery,” Houdry said.
Houdry characterised cloud obstruction as “a temporary uncertainty rather than a permanent inability to assess deforestation monitoring,” arguing there is “no sense of urgency in the EUDR to observe changes on a daily basis, since deforestation and crop cycles are phenomena observable primarily on monthly or yearly scales.” Airbus’s compliance architecture addresses the problem by building land cover maps from long time series of images accumulated over months, constructing a complete surface picture without dependence on any single observation window.
Synthetic aperture radar satellites provide a more direct technical response to the cloud problem, operating on a mechanism that does not rely on surface visibility. “SAR systems emit their own radio waves, allowing them to capture highly detailed images through clouds, smoke and darkness,” Houdry said — a capability that makes them particularly suited to the tropical zones where optical monitoring is most constrained.
SAR data, however, is not without its own limitations and is rarely deployed alone. “SAR data is not an optical imagery that non-expert users can easily interpret,” said Alison Goddard, media relations for the UK and Ireland at the European Space Agency, noting that its high sensitivity also generates false positives that require cross-referencing against optical feeds to resolve.
The European Commission is mandated to complete a formal simplification review of the EUDR by 30 April 2026, and whether persistently cloud-affected sourcing regions attract differentiated compliance treatment — through extended mosaic windows or adjusted confidence thresholds — is a question Raptakis said the industry has not yet resolved.
