EUDR & Traceability

Deforestation-Free Coffee

The phrase "deforestation-free" is easy to write and hard to substantiate. This page covers what would actually be needed to support it, and what East African coffee landscapes look like in practice.

Updated September 20263 min read

Quick answer

Under 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.

Scope of this section

This page summarises Regulation (EU) 2023/1115 as amended by Regulations (EU) 2024/3234 and 2025/2650, checked on 16 September 2026, and describes what an origin supplier can provide to support an operator’s due diligence. It is not legal advice; confirm your obligations against the official text.

What the claim requires

1Location. Where the coffee was produced, at plot level — see geolocation.
2The cut-off date. 31 December 2020 under the EUDR: land converted from forest to agricultural use after that date does not qualify.
3Forest cover analysis. An assessment of whether the land at that location was forest before that date and was converted after it.
4Chain of custody. Evidence that the coffee in the consignment actually came from those plots — see traceability. The EUDR does not accept mass balance.
5Records. All of the above retained and retrievable per consignment.

Every one of those five is required. A supply chain with excellent traceability but no plot coordinates cannot support the claim; nor can one with complete geolocation but no evidence linking those plots to the coffee in the container.

East African coffee landscapes

It is worth understanding what these production systems actually look like, because the generic image of commodity-driven forest clearance fits some agricultural sectors far better than it fits East African coffee.

Production systems across the six origins
Origin	Predominant system	Relationship to forest
Ethiopia	Garden coffee, semi-forest and forest coffee systems	Some production occurs within forest systems, which makes the definitional question — what counts as forest, and what counts as conversion — unusually important here
Kenya	Smallholder plots and estates in long-established agricultural landscapes	Coffee areas have been under cultivation for many decades; land pressure is largely towards urbanisation and subdivision
Rwanda	Smallholder plots on terraced hillsides	Densely settled agricultural landscape; very little remaining forest adjacent to coffee areas
Burundi	Smallholder plots on collines	As Rwanda — long-cultivated, densely populated hillsides
Tanzania	Smallholder plots and some estates in both northern and southern highlands	Mixed; the southern belt has seen agricultural expansion, which is where analysis matters most
Uganda	Smallholder Robusta in the lake basin; Arabica on Elgon and western highlands	Highland Arabica areas border protected areas, which makes plot-level location data particularly consequential

This is landscape context, not evidence. Nothing in this table substitutes for plot-level analysis of a specific supply base.

Landscape context is not evidence

The fact that a region has been farmed for a century does not establish that a particular plot was not converted last year. It changes the prior probability; it does not discharge the analysis. Any supplier using landscape generalities in place of plot data is substituting a story for evidence.

The definitions that decide it

Regulation (EU) 2023/1115, Article 2

Forest — 2(4): Land of more than 0.5 hectares with trees higher than 5 metres and canopy cover above 10%, or trees able to reach those thresholds in situ
Agricultural plantation — 2(5): Land with tree stands in agricultural production systems, including agroforestry systems
Deforestation — 2(3): Conversion of forest to agricultural use, whether human-induced or not
Deforestation-free — 2(13): Produced on land that has not been subject to deforestation after 31 December 2020

Two consequences matter for coffee. Established shade coffee and agroforestry are agricultural land, not forest, so continuing to farm them is not deforestation. But converting forest into coffee after the cut-off is deforestation even if shade trees are kept — which is why forest and semi-forest coffee systems, as found in parts of Ethiopia, need careful plot-level analysis rather than an assumption either way. Other frameworks, such as certification schemes, may use different definitions.

How we handle the claim

We do not make deforestation-free claims about lots on this website. What we do is supply the data an operator needs to reach its own conclusion, and describe the supply chain accurately.

What we provide: Supply chain mapping, lot traceability, and plot geolocation where a collection programme exists
What we state: What data exists, for which part of the supply base, collected when and how
What we do not state: That a lot is deforestation-free, or that any consignment satisfies a regulatory test
Where coverage is partial: We say so, with the denominator stated

Build the evidence base early

If a deforestation-free claim matters to your programme, the data collection has to be arranged before the crop. Talk to us about scoping it.

Discuss a programme

Frequently asked questions

Is East African coffee deforestation-free?

That is not a question that can be answered at country level. A deforestation-free claim requires plot-level location data cross-referenced against forest cover analysis, plus chain of custody evidence linking those plots to the consignment. Landscape context changes the prior probability; it does not substitute for the analysis.

What counts as forest under the EUDR?

Land of more than half a hectare with trees higher than five metres and canopy cover above 10 per cent, or trees able to reach those thresholds. Agricultural plantations, including agroforestry systems, are defined separately. Certification schemes and other frameworks may use different definitions, so establish which one your process relies on.

Does shade-grown coffee count as deforestation?

Farming established shade coffee or agroforestry is not deforestation under the EUDR, because that land is already in agricultural use. Converting forest into shade coffee after 31 December 2020 is. What matters is what the land was at the cut-off date, which is what plot-level analysis establishes — the Ethiopian forest-coffee case is where that question is hardest.

Will you certify that a lot is deforestation-free?

No. We provide supply chain mapping, lot traceability and — where a collection programme exists — plot geolocation, and we state accurately what data exists. The claim and the conclusion belong to the operator.

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

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