EUDR for coffee importers: what you must collect from every farm

Green coffee is already an EUDR commodity, so every consignment needs geolocation for the plot it was grown on, evidence it was produced legally and after 31 December 2020 without deforestation, and — unless you're the one filing — the due diligence statement reference number from whoever is. Cooperative and blended lots need this for every contributing plot, not just the exporter's address.

What "coffee" covers under the EUDR

Coffee sits under CN heading 0901: green coffee, roasted coffee, decaffeinated coffee, coffee husks and skins, and coffee substitutes containing coffee. All of it has been in scope since the regulation entered into force, and it is due under the main application dates like every other original commodity.

One coffee product is not on the same timetable. Soluble coffee, and coffee extracts, essences and concentrates (CN 2101 11), were added to Annex I by Commission Delegated Regulation (EU) 2026/2102, which entered into force in September 2026. Those apply from 30 December 2027, a year after everything else — see what changed in Annex I under 2026/2102 for the full list of additions and removals. If you import both roasted beans and an instant coffee line, you are now running two dates against the same supplier relationship. Keep the distinction in your own records.

Coffee was never within the EU Timber Regulation, so the trap that catches small furniture and paper importers does not apply here. A micro or small coffee operator gets the full extension to 30 June 2027 on non-soluble products, without needing to check an EUTR carve-out.

The geolocation data you need from every plot

This is where most coffee due diligence files fail. Article 9 requires the geographic coordinates of every plot of land where the coffee was produced:

• Polygons for any plot larger than 4 hectares.
• A single point for plots at or below 4 hectares — which covers most smallholder coffee farms.

Coffee's structural problem is that very little of it moves from a single farm to your warehouse. A washing station or cooperative lot routinely blends cherry from dozens or hundreds of smallholders before it is ever sold on. The regulation does not let you geolocate the cooperative's address and call it done — every plot that could have contributed to that lot needs its own coordinates. That is a fundamentally different data structure from what most importers have ever asked an exporter for, and it is the single most common reason a due diligence statement gets stuck.

In practice this means asking your exporter or cooperative for a plot-level register, not a supplier list: farmer or plot identifier, coordinates or polygon, area, and which lots or shipments that plot's coffee went into. Some origin countries and certification schemes (Rainforest Alliance, Fairtrade) are building this into their existing traceability systems, which is worth checking before you build a parallel data collection process from scratch.

What else Article 9 requires beyond coordinates

Geolocation gets the attention, but it is one part of the information set. For each consignment you also need:

Requirement	What it means for coffee
Description and quantity	Product, CN code, net weight
Country of production	Not country of export — the two are routinely different for coffee that transits through a blending or roasting hub
Supplier and customer details	Name and address at each stage of your own chain
Deforestation-free evidence	Documentation that the plot was not deforested or degraded after 31 December 2020
Legal production evidence	Evidence of compliance with the producing country's land use, labour, tax and other relevant laws

The legality evidence is easy to under-collect because it is not one document. It typically means land tenure or use rights, and confirmation the plot was not operating in breach of local environmental, labour or tax law — not a single certificate that ticks every box at once.

Why coffee usually needs full due diligence, not the simplified route

The regulation gives micro and small primary operators a lighter path — a single simplified declaration instead of a per-consignment statement, and postal codes instead of precise coordinates — but only if every origin country you source from is benchmarked low risk. For coffee, that is harder to reach than it sounds.

Origin	Typical role	Risk tier
Vietnam	Largest robusta producer	Low
India	Robusta and arabica	Low
Brazil	Largest producer overall	Standard
Colombia	Washed arabica	Standard
Indonesia	Robusta and specialty arabica	Standard
Ethiopia	Origin of arabica, smallholder-dominated	Standard
Honduras	Arabica, Central America's largest producer	Standard
Guatemala	Arabica	Standard
Peru	Arabica, high organic share	Standard
Uganda	Robusta	Standard

Under Commission Implementing Regulation (EU) 2025/1093, Vietnam and India are currently the only major coffee origins benchmarked low risk; every other significant producing country sits at standard risk, and none are high risk. An importer sourcing only from Vietnam, or only from Vietnam and India, can genuinely reach the simplified route. Almost everyone blending in Brazilian, Colombian, Central American or East African origin cannot, and needs the full risk assessment and mitigation steps — documented, reviewed annually, and produced to the competent authority on request — for every consignment.

This benchmarking is reviewed periodically, so a country's tier is not fixed. Confirm it against the current list rather than a green coffee guide written when the first classification came out in May 2025.

Building the data request you send upstream

The request that actually gets a usable answer back is narrower and more specific than "send us your EUDR data":

1. Plot or farm identifier, matched to whichever unit the exporter already tracks internally.
2. Coordinates or polygon, in a format you can validate before it reaches TRACES — malformed geolocation is the most common reason a due diligence statement is rejected.
3. Area, to confirm whether a point or a polygon is the correct format.
4. Harvest or production period, so you can tie the plot to the specific lot or shipment.
5. Land tenure or use-right evidence, even where informal — a village or cooperative attestation is often what exists in practice.
6. Confirmation of no known deforestation or degradation after 31 December 2020.

Send this before you need it for a specific shipment. Response times from smallholder-heavy origins run to weeks or months, and a supplier who cannot answer is one you need to replace — which is a sourcing decision, not a paperwork one, and needs the runway a last-minute request does not leave.

Does certification cover this already?

No, not on its own. Rainforest Alliance, Fairtrade, UTZ-legacy and organic certification were built around different standards — social, environmental, agronomic — and none of them was designed to produce Article 9 geolocation or to make a deforestation-free determination against the EUDR's specific 31 December 2020 cut-off. Certification bodies have been adding EUDR-aligned data modules to their existing traceability platforms, and where a certifier already holds plot coordinates for your supply base, that is a genuine head start on collection. It is not a substitute for the due diligence statement itself, and a certified lot still needs its own risk assessment unless every origin in it is low risk. Ask your certifier directly whether their current data export includes plot-level coordinates in a format TRACES will accept — many are still mid-migration.

Who actually files the statement

Since Regulation (EU) 2025/2650, the due diligence statement is filed once, by whoever first places the coffee on the EU market — typically the importer of record, not the roaster or retailer buying from them within the EU. If you buy already-imported green or roasted coffee from another EU business, you are downstream: you do not file your own statement, but you must collect and retain the upstream reference number for five years and be ready to produce it.

If you are a non-EU roaster or trader selling into the EU, the obligation legally sits with your EU customer, but you hold the data they cannot file without. Settling in writing who is responsible for what — and by when — avoids the situation where both sides assume the other has it covered.

Deadlines that apply to a coffee business

Business	Application date
Large or medium operator or trader, any coffee product already in Annex I	30 December 2026
Micro or small operator or trader, non-soluble coffee	30 June 2027
Any size, soluble coffee and coffee extracts (CN 2101 11)	30 December 2027

See which application date applies to your business for how size is worked out under Directive 2013/34/EU, and for the EU Timber Regulation trap that does not apply to coffee but does to timber and packaging in the same shipment.

Records and penalties

Whatever your role, due diligence records — geolocation, legality evidence, risk assessments, and statement reference numbers — must be kept for five years from the date the coffee was placed on, made available on, or exported from the EU market. Penalties for getting this wrong include fines of at least 4% of EU-wide annual turnover, confiscation of the coffee and any revenue from it, exclusion from public procurement for up to 12 months, and publication of the infringing company's name.

Where to start

Map every coffee line you buy against its CN code and country of production, confirm whether any of it is soluble coffee running on the later date, and check your origin mix against the current country benchmarking before assuming you need the full risk assessment route. Check what the EUDR requires for your specific coffee business and get a dated plan counted back from your deadline.