EUDR & Traceability

EUDR and Coffee

Coffee is within the scope of the EU Deforestation Regulation, and the practical consequence at origin is a substantial data-collection exercise. This page sets out what that data is, who is responsible for what, and what we can supply.

Last reviewed August 20263 min read

Quick answer

The EU Deforestation Regulation places due diligence obligations on the operator placing coffee on the EU market — not on the exporter. What an origin supplier can do is provide the underlying data: plot geolocation, supply chain documentation and lot traceability, in a form the operator can use in its own due diligence statement.

Scope of this section

This page describes what an origin supplier can provide to support an operator’s due diligence. It is not legal advice and it is not a statement of your obligations. The regulation, its guidance and its application timeline have been amended; confirm the current requirements from the official text and your own advisers.

Where responsibility sits

This is the single most important thing to be clear about, and it is frequently muddled in supplier marketing. The regulation places its obligations on operators — the entities placing the relevant commodity on the EU market — and, in a more limited way, on traders further down the chain.

An exporter at origin is not the operator. What the exporter can do is supply the information the operator needs in order to carry out its own due diligence and make its own statement. That is a supporting role, and describing it as anything else would be misleading.

What we do not claim

We do not claim that any lot is "EUDR compliant", because that is not a property a lot can have — compliance is a property of an operator’s due diligence process. Any supplier offering you "certified EUDR compliant coffee" is describing something that does not exist.

The three data pillars

Broadly, the information an operator needs about a consignment falls into three categories. Each has a different collection challenge at smallholder-dominated East African origins.

What the data covers and where the difficulty lies
Pillar	What it means	Practical challenge at origin
Geolocation	Coordinates of the plots where the commodity was produced	Smallholder farms are numerous, small and often unmapped. Collection is a per-farmer field exercise.
Deforestation-free production	Evidence the land was not deforested after the applicable cut-off	Requires the plot data above, cross-referenced against forest cover analysis.
Legality	Evidence of compliance with the producing country’s relevant laws	Depends on national land tenure, licensing and cooperative registration records.

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

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

Why smallholder origins are the hard case

A single container of East African coffee can represent cherry from hundreds or thousands of individual 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; point coordinates are easier to collect than polygons.
Data collection is a field exercise requiring devices, training and repeat visits — a real cost that has to be carried somewhere.
Data protection matters: farmer-level data is personal data and needs handling accordingly.

None of this makes the exercise impossible. It does mean that any supplier claiming effortless full-polygon traceability across a large smallholder base should be asked how, and asked to show the underlying records.

What we can supply

What is realistically available differs by origin and by lot, and we would rather say so than promise uniformly. In general terms:

Lot-level traceability: Station or factory identity, delivery period and milling batch — available across our origins
Producer group identity: Cooperative, AMCOS or washing station catchment — available across our origins
Plot geolocation: Where the producer organisation or station holds it, or where collection has been arranged for the programme
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
Data format: Structured export in the format your due diligence system requires, agreed at contract stage

Discuss a traceable programme

Tell us the data your due diligence process needs and the origins involved. We will tell you what is available now and what would need to be built for the coming crop.

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Frequently asked questions

Is your coffee EUDR compliant?

Compliance is not a property a lot can carry — the regulation places due diligence obligations on the operator placing goods on the EU market. What we can do is supply the underlying data: lot traceability, producer group identity, supply chain documentation and, where available, plot geolocation, in a form your process can use.

Who is responsible for EUDR due diligence?

The operator placing the relevant commodity on the EU market, with more limited obligations on traders further down the chain. An origin exporter supports that process with data; it does not discharge it.

Can you provide farm polygons for smallholder coffee?

It depends on the origin, the producer organisation and whether collection has been arranged for that programme. Point coordinates are more commonly available than polygons across a large smallholder base. We will tell you what exists for a given supply chain rather than promise uniformly.

When do I need to raise traceability requirements?

Before the harvest they apply to. Plot-level data collection is a field exercise that cannot be reconstructed after cherry has been aggregated at a washing station.

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.