EUDR for coffee exporters: what the regulation requires
Coffee is one of the commodities covered by the EU Deforestation Regulation. This is what the regulation requires, when it applies, and what the data obligations mean in practice for an exporter.
- Published
- 6 October 2026
- Reading time
- 9 min
What the regulation is
Regulation (EU) 2023/1115 on deforestation-free products — the EUDR — covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. It applies to products placed on the EU market, made available on it, or exported from it.
For coffee, the obligation falls on operators and traders in the supply chain. The coffee must be deforestation-free, produced in accordance with the relevant legislation of the country of production, and covered by a due diligence statement.
This page is a factual summary written for orientation. It is not legal advice, and it is not a substitute for the official text and guidance. Verify your own obligations against the regulation and the Commission's guidance.
When it applies
The entry into application was postponed twice. Following Regulation (EU) 2024/3234 and then Regulation (EU) 2025/2650, the Commission's published position is:
| Operator category | Entry into application |
|---|---|
| Large and medium operators | 30 December 2026 |
| Micro and small operators | 30 June 2027 |
| Micro and small operators already covered by the EU Timber Regulation | 30 December 2026 |
The three substantive requirements
Before a relevant product can be placed on the EU market, it must satisfy all three:
- Deforestation-free — produced on land not subject to deforestation or forest degradation after 31 December 2020
- Legally produced — in accordance with the relevant legislation of the country of production
- Covered by a due diligence statement — submitted through the EU information system
The geolocation obligation
The due diligence process requires the geolocation of the plots of land where the commodity was produced. For plots above a certain size, a polygon is required; for smaller plots, a point with sufficient precision. This is the obligation that reaches furthest back into the supply chain, because it requires knowing the physical origin of the coffee, not just the supplier it was bought from.
In practice this is where exporters do the most work, because it means collecting coordinates from producers and plots — often smallholders — and keeping them attached to the lots those plots produced.
What changed in the December 2025 amendments
The Commission's December 2025 political agreement introduced simplification measures, estimated to reduce administrative costs substantially. Two changes are worth understanding because they alter who does what:
- Downstream operators and traders no longer need to submit due diligence statements, and no longer pass reference numbers further down the chain
- Only the first actor downstream of the primary operator collects a due diligence reference number
- A simplified one-off declaration was introduced for micro and small primary operators from low-risk countries
What this means for an exporter's records
The regulation is a documentation obligation, and documentation obligations are only as good as the underlying records. Whatever a due diligence statement eventually asserts, it is assembled from data about plots, producers, purchases and lots.
Realistically, an exporter preparing for this needs the following to be reliably attached to each lot:
- The producer, with identification details
- The plot or plots the coffee came from, with coordinates and, where required, polygon area
- The purchase that brought it in, with weights and dates
- The lot that resulted, linked back to that purchase and those plots
- The shipment the lot left in, so the chain is answerable in both directions
Where the difficulty actually is
The regulation is not conceptually complicated. The difficulty is operational: collecting and maintaining plot-level data across many smallholder suppliers, in locations with intermittent connectivity, in a way that stays attached to the physical coffee as it is processed and blended into lots.
That is a records problem before it is a compliance problem. If the chain from plot to lot to shipment is held as linked records, producing a statement is a query. If it is reconstructed from paper at the point of an audit, it is a project.
Common questions
No, and no software can. It provides EUDR-ready workflows — deforestation-free traceability statements per shipment and plot geolocation export as GeoJSON — to support the submissions you file. Compliance depends on your business, your markets and your own due diligence.
See it against your own operation.
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