EUDR and Coffee: A Practical Guide for Exporters and Importers

Coffee is among the commodities most affected by the EU Deforestation Regulation (EUDR). With 12.5 million coffee farms worldwide —85% of which are smallholders farming plots of just a few hectares— achieving EUDR compliance for coffee is an unprecedented logistical challenge. From 30 December 2026, any operator placing coffee on the EU market must prove, with verifiable evidence, that it does not originate from land deforested after 31 December 2020. For Latin American exporters and European importers alike, understanding what this regulation demands and how to prepare is no longer optional —it is an operational priority.

Why EUDR Hits the Coffee Sector Hardest

Coffee occupies a unique position among the seven commodities regulated by the EUDR (alongside cocoa, soy, palm oil, rubber, timber, and cattle). Three factors make it particularly exposed:

1. Extreme supply chain fragmentation. Roughly 60% of the world’s coffee comes from smallholder farmers. In countries like Colombia, Peru, Honduras, or Ethiopia, a single export shipment may aggregate coffee from hundreds or thousands of individual farms. Tracing each lot back to its specific plot of origin is a challenge the industry has never faced at this scale.
2. Informal land tenure. Many smallholder coffee growers in Latin America, Africa, and Asia farm on land without formal property titles, digital cadastral records, or mapping tools. The EUDR requires GPS coordinates or georeferenced polygons for every production plot —something that simply does not exist yet for millions of producers.
3. Trade volume to the EU. Europe is the world’s largest coffee importing market. Losing access due to non-compliance is not a remote possibility; it is a real commercial risk that is already reshaping relationships between exporters and buyers across the supply chain.

What EUDR Requires for Coffee: Three Core Pillars

The regulation establishes three fundamental requirements that apply across the entire coffee chain, from farm to cup in Europe:

1. Geolocation of Production Plots

Every coffee lot must be linked to a specific farm with verifiable coordinates:

• Plots smaller than 4 hectares: a single GPS point (latitude and longitude) is sufficient.
• Plots larger than 4 hectares: a georeferenced polygon describing the full perimeter of the production area is required.

This requirement generates the most operational friction. Industry data shows that over 10% of coffee farm polygons submitted to date contain errors: overlapping boundaries, mislocated coordinates, or perimeters that do not match the actual terrain. Fixing these issues takes time and requires proper tools.

2. Full Supply Chain Traceability

EUDR demands the ability to reconstruct coffee’s journey from the production plot to the point of entry into the EU. This includes:

• Identification of the producer and farm of origin
• Verified harvest dates
• Documentation for every intermediate link (aggregators, cooperatives, exporters)
• Volumes and lots linked to each origin

For supply chains with multiple intermediaries —common in coffee— this requires a level of digitisation and coordination that many companies have not yet implemented.

3. Due Diligence Statement (DDS)

Operators placing coffee on the EU market must submit a Due Diligence Statement (DDS) through the European Commission’s TRACES NT system. This statement certifies that:

• All required information about the product’s origin has been collected
• A deforestation and legality risk assessment has been conducted
• Risk has been mitigated to a negligible level

Following the December 2025 reform, only primary operators (those first placing coffee on the EU market) are required to submit a full DDS. Downstream operators and traders have reduced obligations: retaining DDS reference numbers and supporting documentation for five years.

Key Challenges for Latin American Exporters

Latin America produces over 55% of the coffee that reaches Europe. Countries like Brazil, Colombia, Honduras, Peru, and Guatemala are strategic suppliers. But EUDR compliance presents specific obstacles for the region’s exporters:

Farm mapping at scale. Colombia’s coffee registry alone includes over 540,000 farms. In Peru, coffee accounts for 12% of EU-bound exports affected by the EUDR. Obtaining precise geolocations for thousands of plots —many in remote rural areas— is a task that demands planning, technology investment, and time.

Producer training. Smallholder coffee growers need to understand what information is being requested, why, and how to provide it. Without clear training programmes, the risk of supply chain exclusion is real: if a producer cannot demonstrate compliance, their coffee will not enter Europe.

Coordination with importers. Although the obligation to submit the DDS falls on the European operator, that operator depends entirely on information provided by the exporter. Fluid communication between both parties is not optional —it is a condition for market access.

Legal documentation from the country of origin. Beyond proving the absence of deforestation, the EUDR requires that products comply with local legislation in the country of production: land-use rights, environmental regulations, labour rights, and applicable tax rules. For many exporters, compiling and verifying this documentation is a complex process.

What European Importers Must Do

Importers acting as primary operators bear direct regulatory responsibility. These are the key actions:

• Map the supplier chain. Identify every exporter, cooperative, and producer linked to each coffee lot. Knowing only the direct exporter is not enough: traceability must reach back to the farm.
• Verify geolocations. Confirm that GPS coordinates or polygons provided by exporters are accurate, complete, and meet EUDR technical requirements. Satellite analysis tools can cross-check this information against forest cover imagery.
• Assess risk by country and supplier. The EU’s benchmarking system classifies countries into three risk levels: low, standard, and high. Currently, 140 countries are classified as low risk (including all EU Member States), and only four as high risk (Belarus, Myanmar, North Korea, and Russia). Inspection rates vary accordingly: 9% of operators sourcing from high-risk countries will be inspected, compared to 3% for standard risk and 1% for low risk.
• Set up the DDS submission system. Register on TRACES NT, familiarise yourself with the declaration submission process, and ensure internal systems can generate the required information in the correct format.
• Establish protocols with suppliers. Clearly define what information is needed, in what format, and how often. Importers who set these protocols early will hold a significant competitive advantage.

Practical Roadmap: Steps Before December 2026

Less than 11 months remain before the regulation takes effect. Here is an indicative timeline:

February – April 2026:

• Internal supply chain audit: how many farms does your coffee come from? What geolocation data exists?
• Gap identification: which producers lack coordinates, polygons, or legal documentation?
• Evaluation of technology platforms for EUDR data management [LINK:eudr-tools]

May – July 2026:

• Geolocation collection campaign with producers and cooperatives
• Satellite deforestation analysis for registered plots
• Test DDS submissions in the TRACES NT system

August – October 2026:

• Cross-verification of all documentation
• Resolution of issues with polygons, documents, or traceability gaps
• Internal team training on the declaration process

November – December 2026:

• First operational DDS submissions
• Continuous monitoring and adjustments based on TRACES feedback

Key Takeaways

• Coffee is one of the commodities most affected by the EUDR due to its fragmented supply chain and the prevalence of smallholder producers.
• Geolocation of every production plot is mandatory: GPS points for plots under 4 ha, polygons for plots over 4 ha.
• Over 10% of coffee farm polygons contain errors, making a verification process essential before the deadline.
• Latin American exporters are not directly required to submit a DDS, but without their data, European importers cannot comply.
• After the December 2025 reform, only primary operators must submit a full DDS. Downstream operators and traders have simplified obligations.
• The European Commission will publish a simplification review by 30 April 2026, which may introduce further changes.
• The deadline is 30 December 2026 for large and medium operators, and 30 June 2027 for micro and small enterprises.

How to Prepare Now

EUDR is not a regulation that can be solved in the final weeks. Collecting geolocations, running satellite verification, and building traceability systems require months of coordinated work between exporters and importers. Companies that start now will reach the deadline with margin; those that wait risk real commercial disruptions.

Platforms like Coolx allow you to centralise supplier management, automate deforestation analysis with satellite imagery, verify legal documentation, and generate DDS ready for TRACES submission —all within a single system that connects exporters and importers. If coffee is part of your supply chain and you need a comprehensive solution for EUDR compliance, visit coolx.earth or get in touch with the team.