EUDR & traceability
EUDR and Coffee
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
| Pillar | What it means | Practical challenge at origin |
|---|---|---|
| Geolocation | Coordinates of every plot the coffee was produced on | Smallholder farms are numerous, small and often unmapped. Collection is a per-farmer field exercise. |
| Deforestation-free production | No conversion of forest to agricultural use after 31 December 2020 | Requires the plot data above, cross-referenced against forest cover analysis. |
| Legality | Compliance with the producing country’s relevant laws — land use, environment, labour, human rights, tax, trade and customs | Depends 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.
- Step 1
Farm / plot
Producer identity, plot geolocation
- Step 2
Wet mill / station
Delivery record, day lot
- Step 3
Dry mill
Outturn or milling batch number
- Step 4
Warehouse
Lot identity, storage conditions
- Step 5
Container
Bag count, seal number, stuffing record
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.
Guides
The data in detail
Geolocation, the due diligence data set and the deforestation-free test — each on its own page. How traceability works physically is covered under coffee traceability.
- Coffee Plot GeolocationPlot geolocation records where coffee was produced, as either a point coordinate or a boundary polygon. Collection is a field exercise: someone visits each plot with a GPS-enabled device. Across a smallholder base of hundreds or thousands of farms, that is a substantial programme that must be planned before the harvest.
- Due Diligence Data for CoffeeThe operator that first places coffee on the EU market submits the due diligence statement in the EU Information System; since the December 2025 amendment, downstream operators and traders do not file their own. An origin supplier supports the operator with structured data — supply chain records, lot identity, producer group and legality records and plot geolocation — in a format the operator’s system can ingest.
- Deforestation-Free CoffeeUnder the EU Deforestation Regulation, coffee is deforestation-free if it was produced on land that was not converted from forest to agricultural use after 31 December 2020. Showing that requires plot location data cross-referenced against forest cover analysis — it cannot be asserted on the strength of general practice in a region.
Questions
EUDR questions buyers ask
When does the EUDR apply to coffee?
Is your coffee EUDR compliant?
Does coffee from a low-risk country need geolocation?
When do traceability requirements need to be raised?
Sources and references
- Regulation (EU) 2023/1115, consolidated text of 26 December 2025 (EUR-Lex) — Definitions (Article 2), scope (Annex I), geolocation
- Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115 — Application dates of 30 December 2026 and 30 June 2027; downstream operators and traders
- Commission Implementing Regulation (EU) 2025/1093 — country benchmarking — Low, standard and high risk classification
- European Commission — EUDR frequently asked questions — Non-binding guidance; geolocation, low-risk origins, mass balance
- European Commission — Regulation on deforestation-free products