EUDR and coffee: A comprehensive guide to the EU Regulation on Deforestation

The entry into force of the EUDR — the European Union Regulation on Deforestation — introduces a new dimension to the way coffee supply chains are managed.

The aim of the EUDR is to reduce the impact of the European Union’s trade on deforestation and forest degradation worldwide. To this end, the Regulation stipulates that certain raw materials and products that are traded, made available on the European Union market or exported must be able to demonstrate that they meet requirements relating to their origin, traceability, legality and the absence of deforestation.

For coffee, this means that information on origin takes on much greater significance. Traceability is no longer merely a commercial or quality-assurance tool; it has become part of the mechanisms used to demonstrate compliance with a regulatory obligation.

This does not mean that all actors in the chain have to do the same. The obligations depend on the position each company occupies within the supply chain and the type of operation it carries out.

The EUDR is the Regulation (EU) 2023/1115 of the European Union on raw materials and products associated with deforestation and forest degradation, including coffee.

The Regulation prohibits the marketing, making available on the European Union market and export of certain relevant products where they do not comply with the conditions laid down in the Regulation.

The EUDR defines a ‘relevant product’ as certain raw materials and products falling within its scope. To identify them, Annex I to the Regulation sets out a list of products classified according to the European Union’s Combined Nomenclature (CN) codes. This classification makes it possible to determine which goods are subject to the requirements of the EUDR.

In the case of coffee, the Regulation includes products classified under code 0901, which covers coffee, whether or not roasted or decaffeinated, as well as coffee husks and skins and coffee substitutes containing coffee.

For a product falling within the scope of application to be placed on the market, made available or exported, it must cumulatively meet three conditions:

In the case of agricultural raw materials, they must come from land that has not been subject to deforestation after 31 December 2020.

The concept of legality is broad and includes, amongst other elements, the land rights of indigenous peoples, environmental and forestry legislation where applicable, labour and human rights, and certain tax, trade and anti-corruption obligations.

Depending on the type of operator and the specific situation, this is achieved through a Due Diligence Statement (DDS) guaranteeing the above or, in the cases provided for by the Regulation, through a simplified declaration.

The reform introduced by Regulation (EU) 2025/2650 has significantly altered the obligations of downstream actors in the supply chain, meaning that not all of them are currently required to submit their own DDS. The DDS must be submitted to the EUDR Information System (TRACES) prior to the product being placed on the market, made available or exported.

One of the key reference dates under the EUDR is 31 December 2020, the date from which the Regulation stipulates that no conversion of forest to agricultural use may have taken place on the plots from which the coffee originates.

In other words, for coffee to be considered deforestation-free for the purposes of the EUDR, the plots where the raw material was produced must not have undergone such a conversion after that date.

This date does not mean that the plot must have been registered in a European system since 2020, nor that the producer was required to carry out any EUDR-related procedures at that time. It means that the land’s status with regard to deforestation is assessed using that date as a reference point.

This introduces a significant difference from the traditional way of identifying the origin of coffee. In the specialty coffee sector, it is common to refer to:

• country of origin;
• region;
• department or province;
• municipality;
• farm;
• co-operative;
• producer;
• micro-lot;
• export lot.

These data remain relevant, but the EUDR introduces an additional level of traceability: where required by the Regulation, it must be possible to link the product to the plots of land where the raw material was produced and to the information necessary to verify compliance with its requirements.

For this reason, geographical traceability takes on particular importance: it enables the coffee being marketed to be linked to a specific location and the corresponding land use to be assessed.

Due Diligence is the process by which the operator determines whether a relevant product complies with the requirements of the EUDR. In simple terms, it can be understood as comprising three stages:

1. Gathering information

The operator must obtain the necessary information about the product, its origin and the circumstances of its production. In the case of coffee, this may include:

• a description and quantity of the product;
• country of production;
• information on operators and suppliers;
• traceability data;
• geolocation of plots where required;
• information relating to the legality of production.

2. Assessing risk

Where a risk assessment is required, the operator must consider factors such as the risk level of the country of production, the complexity of the supply chain, the risk of mixing, the possibility of circumvention and other relevant information.

The EUDR establishes a classification of countries based on their risk level.

In countries classified as low-risk, a simplified due diligence process applies. This does not mean that all information requirements are waived: specific obligations regarding the collection of information and other checks provided for in the Regulation still apply.

For countries classified as standard or high risk, the operator must carry out a full risk assessment and, where necessary, implement mitigation measures until a negligible level of risk is achieved.

3. Mitigating risk where necessary

If the assessment identifies a risk of non-compliance that cannot be considered negligible, appropriate mitigation measures must be taken. These may include requesting additional information, supplementary documentation, or more in-depth verifications or checks on the supply chain.

Traceability is particularly important because the EUDR does not permit a mixture to make it impossible to demonstrate the origin and compliance of the products it comprises.

For example, if a raw material whose compliance with the EUDR is certified is mixed with another whose origin or compliance cannot be demonstrated, and it is subsequently impossible to identify which part corresponds to each, the company may not be in a position to demonstrate that the product placed on the market complies with the requirements of the Regulation.

For this reason, the EUDR should not be understood simply as a ban on the mass balance model. What is important is that the traceability system used allows the origin and compliance of the relevant product to be demonstrated, and that mixtures do not make it impossible to maintain that traceability.

Not all actors in the coffee supply chain have the same obligations. This is probably one of the most important issues for understanding the practical application of the Regulation. Following the 2025 reform, the Regulation clearly distinguishes between operators, downstream operators and traders, each with different obligations.

Operator (or upstream operator)

Put simply, this is the party who first places a relevant product on the Union market or who exports it.

This is the party generally responsible for carrying out due diligence on the product they place within the regulated area and for submitting the Due Diligence Declaration to be uploaded to the EU Information System (TRACES).

For example: as XORXIOS® are the parties placing the goods into the single customs territory, we are considered an upstream operator.

Downstream operator

Introduced specifically by the 2025 reform, this is an operator who manufactures or transforms a product subject to the EUDR from another product that has already complied with due diligence obligations, and subsequently places it on the market in the EU or exports it.

A clear example of a downstream operator would be a ‘bean-to-bar’ chocolatier. This operator purchases cocoa, code 1801, from an upstream operator and processes it into chocolate, code 1806. Both codes are listed separately in Annex 1 of the EUDR, meaning that this company would be considered a downstream operator.

Trader

A trader is a person in the supply chain, other than the operator or downstream operator, who, in the course of a commercial activity, makes a relevant product available on the market. A distinction is made between large traders and SMEs, which have different obligations.

A roaster would be a clear example of a trader: they purchase green coffee from an operator and roast it. In this process, green coffee, code 0901 11, becomes roasted coffee, code 0901 12. The TARIC code changes, but if we refer to Annex 1 of the EUDR, we see that both green coffee and roasted coffee fall under the common code 0901, and no further distinction is made. By grouping green and roasted coffee together, Annex 1 indicates that, for practical purposes, roasting coffee does not constitute a relevant transformation under the EUDR; consequently, the roaster neither naturalises goods within the EU (they are not an operator) nor transforms them in a relevant manner (they are not a downstream operator).

Authorised representative

May act on behalf of an operator or trader in relation to certain actions provided for in the Regulation. Such representation does not relieve the operator of its responsibility for the compliance of the product.

End consumer

No obligations under the EUDR.

In a coffee supply chain originating in a third country, the importer may play a central role because placing the product on the European market triggers the obligations incumbent on the operator.

Generally speaking, the operator must be able to demonstrate that the product complies with the requirements of the EUDR. This involves working with information on:

• the product;
• the country of production;
• the plots;
• traceability;
• the legality of production;
• identified risks;
• mitigation measures where necessary.

The downstream operator is a category introduced and redefined by the 2025 reform of the Regulation.

A downstream operator is an operator who, without necessarily importing the goods from outside the EU, substantially transforms them to create a new relevant product (e.g. cocoa into chocolate). Their obligations are as follows (Article 5; Reg. (EU) 2025/2650):

For all downstream operators:

• To retain, for at least 5 years, the reference numbers of the DDSs covering the goods.
• To identify their suppliers and customers that are businesses (not the end consumer).

For medium-sized and large companies (additional requirements):

• Register with the EUDR Information System (TRACES).
• Verify the validity of the DDSs for purchased products where there are justified concerns.
• Provide the competent authorities with the DDS reference number and the batch traceability documentation.

Transformation: when does a company’s role change?

The transformation of a key product can determine a company’s position within the supply chain. There is a distinction here that is particularly useful for understanding the case of coffee.

A trader is any person in the supply chain who is neither an operator nor a downstream operator (i.e. who does not import or substantially process a relevant product) and who makes a relevant product available on the market.

Their role is primarily one of traceability and information provision.

Downstream operators and traders must collect and retain information on their suppliers and on the businesses to which they supply the product. Where the supplier is an operator, they must also retain the reference numbers of the due diligence statements or the identifiers of the relevant statements.

This information must be retained for at least five years. Traders and downstream operators who obtain relevant information indicating a possible breach must act in accordance with the notification obligations set out in the Regulation.

In the case of downstream operators and traders that are not SMEs, there are also specific obligations where, prior to placing a product on the market or exporting it, they obtain information indicating that a product may not comply with the Regulation. If there are justified concerns, they must verify that due diligence has been exercised and that there is no more than a negligible risk before proceeding with the transaction.

The EUDR establishes a system of penalties to ensure that the various actors in the supply chain comply with their obligations. Article 25 sets out various measures that Member States may apply depending on the nature and severity of each breach.

It is important to put these provisions into context: the Regulation does not impose an automatic penalty for every breach, nor does it assign the same level of responsibility to all participants in the chain. The obligations of an operator, a subsequent operator and a trader differ, and therefore so does the scope of their responsibilities.

The measures provided for in the Regulation include:

Sustainability certifications can provide useful information for a supply chain, but should not automatically be equated with compliance with the EUDR.

A certification may cover aspects relating to:

• agricultural practices;
• sustainability;
• social conditions;
• traceability;
• environmental management;
• chain of custody.

However, compliance with the Regulation depends on the requirements set out by the EUDR itself. Therefore, holding a certification does not automatically mean that a company is exempt from its relevant obligations.

At the same time, certain existing certifications, traceability systems and information tools can facilitate the collection of data that may subsequently prove useful for compliance.

The EUDR has undergone significant changes since its initial adoption. Following Regulation (EU) 2025/2650, the key implementation dates are:

• 30 December 2026: general implementation for large and medium-sized enterprises.
• 30 June 2027: implementation for micro and small enterprises covered by this extended period.

The practical application of the EUDR may give rise to situations in which the same company occupies different positions within the supply chain, or in which it is necessary to take the transitional period into account.

These are some of the scenarios that may arise.

A medium-sized or large company purchasing goods from a micro or small operator during the transitional period

It may be the case that a medium-sized or large company purchases products from a micro or small operator during the period in which the transitional arrangements for such operators are still in force.

Coffee imported by an upstream operator during the transitional period is exempt from the requirement to submit a DDS and from risk analysis procedures under the EUDR. This exemption extends to the subsequent links in the supply chain, provided it can be demonstrated that the coffee was released for free circulation during the transitional period by a company covered by that regime.

Upstream operator who also processes the raw material

A company may occupy more than one position within the supply chain.

For example, it may introduce a relevant raw material into the EU and subsequently process it to obtain another relevant product. In this case, it may act as an upstream operator in relation to the first operation and as a downstream operator in relation to the second.

The specific obligations must be analysed on the basis of the relevant products involved and the traceability rules applicable to them. However, having the information relating to its position as an upstream operator may facilitate compliance with its obligations as a downstream operator.

Importing a relevant raw material and purchasing another raw material to manufacture a product

It may also be the case that a company directly imports a relevant raw material and, at the same time, purchases another relevant raw material from another operator in order to manufacture a subsequent product.

In this situation, different positions and obligations may coexist within the same company. The company must therefore analyse the following separately:

• the product it imports directly;
• the product it purchases from another operator;
• the resulting product;
• the associated declarations or identifiers;
• the traceability required to demonstrate compliance.

Producer at origin who places the goods directly on the EU market

The obligation does not depend solely on a company being a producer.

If the producer located at origin is the one placing the goods on the European market, they may directly assume the obligations incumbent on the operator. In that case, they must analyse the administrative and operational requirements necessary to act as an operator, including those relating to the information system and, where applicable, customs identification.

For a specialty coffee roaster, the EUDR does not necessarily mean assuming the obligations that fall to the operator placing the coffee on the European Union market. As we have seen previously, its impact depends first and foremost on the role the roaster plays within the supply chain.

However, the EUDR does introduce a significant change in the way coffee’s origin is managed. Much of the data that already forms part of standard traceability for specialty coffee — the country of origin, region, farm, cooperative, producer, micro-lot or export lot — takes on a new dimension when it must also be used to demonstrate compliance with regulations.

This makes it particularly important to distinguish between commercial traceability and regulatory traceability.

A coffee may be perfectly traceable from a commercial perspective and yet still require additional information to meet the requirements of the EUDR. For example, knowing that a coffee comes from:

Colombia → Huila → Grower/co-operative

may be sufficient to explain its origin and differentiate it commercially. However, this information does not necessarily equate to having the geographical data required by the EUDR for the plots on which the coffee was produced.

The difference is significant: commercial traceability aims to explain where a coffee comes from and what makes it different; the traceability required by the EUDR must also make it possible to demonstrate that the product complies with the requirements set out in the Regulation.

For the roaster, this means that it is not enough to have a good understanding of the coffee from a commercial perspective. They must also understand what information they need to receive from their suppliers and what obligations they actually have, depending on their position in the supply chain.

In this regard, the EUDR may reinforce a trend that was already present in the speciality coffee sector: gaining a more precise understanding of where the coffee comes from and improving transparency throughout the supply chain.

How can a roaster prepare?

Preparing for the EUDR does not necessarily involve creating new, complex procedures. For a roaster, it may be sufficient simply to be clear about who supplies their coffee, what role that supplier plays in the chain, and what information must accompany the product at each stage.

It is also advisable for the company to be able to link the information received to the coffees and batches it purchases, and to know how to act if it subsequently receives information that may indicate a potential breach.

To maintain traceability and ensure EUDR compliance, the roaster should avoid making the following mistakes:

• Mixing batches without proper control.
• Losing track of the origin.
• Separating the product from its documentation.
• Declaring an origin other than that received.
• Altering EUDR information.

Is knowing the country of origin sufficient to comply with the EUDR?

Not necessarily. The country of origin is a first layer of information, but the EUDR may require much more precise information on where the raw material was produced, including the geolocation of the plots where applicable.

Do all actors in the supply chain need to have the same information?

No. The obligations and the information required depend on each company’s position in the supply chain, the product and the operation carried out. That is why it is important to distinguish between the information used to describe a coffee commercially and the information required to comply with the EUDR.

In this process, the importer plays a particularly important role, acting as a link between the supply chains of origin and the European market. The quality and reliability of the information they receive, verify and make available to the rest of the chain will be crucial in facilitating compliance with the Regulation.

For specialty coffee, the EUDR further reinforces a trend that the sector had already begun: origin is no longer just part of the story we tell about a coffee, but has also become an essential part of the information that demonstrates how it has been produced and traced.

The EUDR does not make every player in the supply chain responsible for everything.

It sets out different responsibilities and makes having reliable information on the origin, traceability and legality of production increasingly important.