EUDR & Traceability

Due Diligence Data for Coffee

This page is deliberately practical: who files what under the regulation as amended, what data exists at origin, in what form, and how it is exchanged.

Updated September 20264 min read

Quick answer

The 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.

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.

Who submits what

Roles under Regulation (EU) 2023/1115 as amended

Operator: Whoever first places the coffee on the EU market or exports it from the EU. Carries out due diligence and submits the due diligence statement in the EU Information System, which issues a reference number and a verification number. By submitting it, the operator assumes responsibility for the product’s compliance.
Downstream operators and traders: Since Regulation (EU) 2025/2650 they do not submit statements of their own. They keep supplier and customer records; the first downstream buyer keeps the statement reference numbers. A roaster buying imported green coffee is the Commission’s own example of a downstream operator.
Exporter at origin: Has no direct obligation under the regulation unless it places the coffee on the EU market itself. Its role is to supply accurate data to the operator.
Micro or small primary operator: A producer in a low-risk country placing coffee it grew itself on the EU market may use a one-time simplified declaration. Not relevant to exporter-traded coffee.

A single due diligence statement can cover several shipments for up to a year. The option to reference an upstream statement inside a new one was removed by the 2025 amendment, so there is no statement for a supplier to “pass on” — what passes along the chain is data.

The information set

Data an origin supplier can typically provide
Category	Contents	Source
Consignment identity	Contract reference, lot identifiers, bag count, container and seal numbers	Exporter records
Supply chain map	Which producer groups and stations contributed to the lot, and the transfers between them	Station and mill records
Producer group records	Cooperative, AMCOS or station registration and membership records	Producer organisation
Plot geolocation	Point or polygon data with farmer and plot identifiers	Field collection programme, where arranged
Legality documentation	Registration, licensing and export authorisation records applicable at the origin	Producer organisation and exporter
Processing and milling records	Delivery, fermentation, drying, milling batch and warehouse records	Station and dry mill
Shipment documentation	The standard export document set — see shipping documents	Exporter and carrier

Formats and exchange

The practical friction in due diligence data is rarely whether the information exists — it is whether it arrives in a form the receiving system can use. Agreeing the format at contract stage removes almost all of it.

Structured over documents. A CSV or JSON export of geolocation and supply chain data is far more usable than the same information in a PDF.
Stable identifiers. Lot, farmer and plot identifiers must be consistent between the data file and the shipping documents.
Coordinate format. Decimal degrees with a stated datum, not mixed formats.
Delivery timing. Whether data accompanies the offer, the contract or the shipping documents.
Update mechanism. How corrections are issued and tracked after the first transfer.

Retention

Records need to be kept for a defined period and to remain retrievable and linked. In practice that means the exporter, the dry mill and the producer organisation all need retention arrangements, because a record held only by one party breaks if that relationship ends.

What is retained: Consignment records, supply chain map, geolocation data, legality documentation, correspondence
Retention period: At least five years, the period the regulation sets for due diligence records, unless the contract sets longer
Retrievability: Indexed by lot and contract reference so a consignment can be reconstructed
Where held: Exporter records, with the producer organisation retaining its own originals
Data protection: Personal data handled under defined consent and retention terms

Being honest about limits

What a supplier cannot do

An origin supplier cannot make your due diligence decision, cannot certify a consignment as compliant, and cannot warrant a legal outcome in a jurisdiction it does not operate in. What it can do is provide accurate data, say clearly what is and is not available, and not overstate coverage. Treat any supplier claim that goes further than that with caution.

Where geolocation data does not exist for part of a supply base, we say so rather than extrapolating.
Where a coverage figure is quoted, we state the denominator it is calculated against.
Where a record is held by a third party, we identify the holder rather than presenting it as ours.
Where a requirement cannot be met for a given origin or crop, we say that at the enquiry stage.

Tell us what your process needs

Send us your data specification with your enquiry and we will tell you, origin by origin, what is available for the current crop and what would need to be built.

Request Current Crop Offer

Frequently asked questions

What due diligence information can an exporter provide?

Consignment identity, a supply chain map, producer group records, processing and milling records, legality documentation and — where a collection programme exists — plot geolocation. The exporter supplies data; the operator carries out the due diligence.

What format should geolocation data be in?

Structured and machine-readable — CSV or JSON — with decimal degree coordinates, a stated datum, and identifiers that match the shipping documents. Agree the format at contract stage rather than after shipment.

How long should records be retained?

At least five years, which is the period the regulation sets for due diligence records, or longer where the contract says so. What matters as much as the duration is that records remain indexed by lot and contract reference so a consignment can actually be reconstructed.

Do you submit the due diligence statement for us?

No. The statement is submitted by the operator placing the coffee on the EU market, in the EU Information System. We supply the data your statement relies on. We are not established in the EU and cannot act as an authorised representative.

What if geolocation data is not available for part of a supply base?

Then we say so. Partial coverage stated accurately is more useful to an operator than a coverage claim that cannot be substantiated, and it lets you decide whether to proceed, to restrict the supply base, or to fund collection ahead of the next crop.

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

Tell us the coffee you need

Lots can be specified by origin, region, process, grade, screen, moisture, defect tolerance, crop year and packaging. Send what you know and we will confirm what each origin realistically supports.