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Jber Coffee LimitedGreen Coffee · Origin Supply

EUDR & traceability

EUDR and Coffee

The EU Deforestation Regulation places due diligence obligations on the operator placing coffee on the EU market. An origin supplier supports that with data — lot traceability, supply chain records and plot geolocation — in a form the operator’s process can use.

The regulation

What applies to coffee, and from when

Summarised from the official text as amended. Not legal advice — the sources are listed at the foot of the page.

Regulation (EU) 2023/1115 as it applies to coffee — checked 16 September 2026

Applies from
30 December 2026 for large and medium operators; 30 June 2027 for micro and small undertakings established as such by 31 December 2024 (Regulation (EU) 2025/2650)
Products in scope
HS 0901: coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee. Green and roasted coffee are both in scope
Conditions
Deforestation-free (no conversion of forest to agriculture after 31 December 2020), produced in accordance with the relevant laws of the country of production, and covered by a due diligence statement
Who files
The operator first placing the coffee on the EU market, in the EU Information System. Downstream operators and traders no longer file their own statements
Geolocation
Every plot of land, to at least six decimal places; a polygon for plots over 4 hectares. Mass balance is not accepted
Country risk
Kenya, Rwanda and Burundi: low risk. Uganda, Tanzania and Ethiopia: standard risk (Implementing Regulation (EU) 2025/1093). Low risk simplifies due diligence; geolocation is still required
Pending
A Commission delegated act adopted on 13 July 2026 would add soluble coffee extracts (CN 2101 11 00) from 30 December 2027. It was under Parliament and Council scrutiny when checked

On “EUDR compliant” coffee

There is no official EUDR certificate, label or register of compliant suppliers. By submitting a due diligence statement, the operator assumes responsibility for the product meeting the regulation. Certification schemes can inform an operator’s risk assessment, but they do not replace due diligence. We therefore do not describe any lot as “EUDR compliant”.

At origin

What the regulation means for an origin supplier

Where responsibility sits

The obligations fall on the operator placing coffee on the EU market. An exporter at origin that sells to an EU importer is not that operator and has no direct obligation under the regulation. What the exporter can do is supply the information the operator needs for its own due diligence — a supporting role, and describing it as anything more would be misleading.

The three data pillars

What the data covers and where the difficulty lies
PillarWhat it meansPractical challenge at origin
GeolocationCoordinates of every plot the coffee was produced onSmallholder farms are numerous, small and often unmapped. Collection is a per-farmer field exercise.
Deforestation-free productionNo conversion of forest to agricultural use after 31 December 2020Requires the plot data above, cross-referenced against forest cover analysis.
LegalityCompliance with the producing country’s relevant laws — land use, environment, labour, human rights, tax, trade and customsDepends on national land tenure, licensing and cooperative registration records.

Why smallholder origins are the hard case

A single container of East African coffee can represent cherry from hundreds or thousands of smallholdings, aggregated at a washing station. That aggregation is what makes the coffee commercially viable, and what makes the data exercise substantial.

  • Farms are frequently under a hectare, sometimes fragmented across several plots.
  • Farmer lists change between seasons as deliveries shift between stations.
  • Plot boundaries are often not formally recorded — though points are enough for plots under 4 hectares.
  • Collection is a field exercise requiring devices, training and repeat visits, a real cost that has to be carried somewhere.
  • Farmer-level data is personal data and needs handling accordingly.

None of this makes the exercise impossible. It does mean that a supplier claiming effortless full coverage across a large smallholder base should be asked how, and asked to show the records. How identity is kept — or lost — between plot and container is set out under coffee traceability.

  1. Step 1

    Farm / plot

    Producer identity, plot geolocation

  2. Step 2

    Wet mill / station

    Delivery record, day lot

  3. Step 3

    Dry mill

    Outturn or milling batch number

  4. Step 4

    Warehouse

    Lot identity, storage conditions

  5. Step 5

    Container

    Bag count, seal number, stuffing record

The chain the data has to survive: plot to container.

What we can supply

Origin data, stated accurately

Availability differs by origin and by lot. We would rather say that than promise uniform coverage.

Lot-level traceability
Station or factory identity, delivery period and milling batch — available across all six origins.
Producer group identity
Cooperative, AMCOS or washing station catchment, with registration records.
Plot geolocation
Where the producer organisation holds it, or where collection has been arranged for the programme ahead of the harvest.
Supply chain documentation
The chain of custody records linking plot, station, mill, warehouse and container.
Legality documentation
Registration and licensing records held by the producer organisation and the exporter.
Structured data export
GeoJSON, CSV or JSON in the format your due diligence system requires, agreed at contract stage.

Raise traceability requirements before the harvest

Plot-level geolocation is a field exercise, and it cannot be reconstructed after cherry has been aggregated at a washing station. If a programme needs plot data, that has to be agreed ahead of the crop it applies to — not when the container is being booked.

Questions

EUDR questions buyers ask

When does the EUDR apply to coffee?
From 30 December 2026 for large and medium operators, and from 30 June 2027 for micro and small undertakings established as such by 31 December 2024, under Regulation (EU) 2025/2650. Both dates were checked in September 2026; the regulation has been amended twice, so confirm against the official text.
Is your coffee EUDR compliant?
There is no official EUDR compliance certificate for a lot or a supplier. The operator placing coffee on the EU market carries out due diligence and, by submitting its statement, takes responsibility for the product. We supply the underlying data: lot traceability, producer group identity, supply chain and legality records and, where collected, plot geolocation.
Does coffee from a low-risk country need geolocation?
Yes. Kenya, Rwanda and Burundi are classified low risk, which lets an operator skip the risk assessment and mitigation steps, but the Commission’s guidance is explicit that there is no exception from geolocation.
When do traceability requirements need to be raised?
Before the harvest they apply to. Plot-level collection is a field exercise that cannot be reconstructed after cherry has been aggregated at a washing station.

Sources and references

  1. Regulation (EU) 2023/1115, consolidated text of 26 December 2025 (EUR-Lex) — Definitions (Article 2), scope (Annex I), geolocation
  2. Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115 — Application dates of 30 December 2026 and 30 June 2027; downstream operators and traders
  3. Commission Implementing Regulation (EU) 2025/1093 — country benchmarking — Low, standard and high risk classification
  4. European Commission — EUDR frequently asked questions — Non-binding guidance; geolocation, low-risk origins, mass balance
  5. European Commission — Regulation on deforestation-free products