EUDR for coffee and cocoa: what actually changes for importers

Coffee and cocoa are among the seven commodities covered by the EUDR, and account for a large share of the volumes traded with the European Union. Their supply chains share a feature that makes compliance particularly complicated: a multitude of small family farms, often grouped into cooperatives, with no centralised plot-registration system comparable to that of a large European agricultural country.

The deadline and who files. General application is set for 30 December 2026, with a period until 30 June 2027 for micro and small enterprises outside the timber sector established as such before 31 December 2024. As an importer, you place the product on the Union market for the first time: the due diligence statement is yours. On the other hand, since Regulation (EU) 2025/2650 of 19 December 2025, your downstream customers — roaster, chocolate maker, distributor buying a batch already declared — no longer file a statement: they keep the reference number of yours. That is good commercial news to pass on to them, and one more reason for your own statement to be beyond reproach: the whole downstream chain rests on it.

What sets coffee and cocoa apart from the other EUDR commodities

• A multitude of very small plots — in Côte d'Ivoire and Ghana for cocoa, in Ethiopia or Colombia for coffee, farms of a few hectares dominate, with a history of GPS recording often non-existent before the regulation entered into force.
• Cooperatives as structuring intermediaries — collection frequently goes through a cooperative that aggregates the production of hundreds of farmers, which shifts part of the recording and documentation burden onto this intermediary rather than onto each individual producer.
• Frequent blending downstream — a coffee roaster commonly blends several origins to create a consistent flavour profile, which multiplies the number of upstream statements — and therefore of reference numbers — behind a single finished product.

What an importer must obtain from its suppliers

1. The geographical coordinates of each plot that contributed to the imported batch — via the direct producer if the relationship is direct, via the cooperative if it centralises collection.
2. Proof of no deforestation after 31 December 2020 on each of these plots — often established by cross-checking against publicly available satellite imagery, in the absence of a formal land title in some regions.
3. The traceability chain between the plot and the exported batch — what volume from each farmer went into which container, on which date.

The case of blends: how to stay compliant

It all depends on who placed each origin on the market.

• The roaster buys green coffee that has already been imported and declared: it is a downstream operator. Since Regulation (EU) 2025/2650, it does not file a statement for its blend; it collects and keeps the reference number of the statement for each batch that goes into it. What it must maintain is the link between each number and each roast — otherwise, in an inspection, it will not be able to say which statements cover which product.
• The roaster imports some or all of its green coffee itself: for those batches, it is the operator and files the statement. A statement then cannot aggregate origins to the point of hiding the individual plots. Two workable approaches, detailed in our guide on the due diligence statement: one statement per production batch referencing all the plots that contributed, or a reference statement per supplier reused as long as its plots have not changed; for a blend of several origins in the same roast, the first documents each component best.

What helps in practice, on the ground

• Rely on cooperatives that are already structured — those that already have a system for registering their members (often linked to an existing certification) start with a head start in producing the coordinates required.
• Prioritise recording on the largest volumes rather than aiming for immediate exhaustive coverage — an importer working with hundreds of smallholders can structure its compliance in order of volume purchased.
• Check existing sector initiatives — several coffee and cocoa trade organisations have set up shared coordinate-collection tools for their supply chains, reducing the individual cost of recording.

Common mistakes

• Requiring a smallholder to carry out a survey they do not have the means to carry out alone, without going through the cooperative or a shared scheme that spreads the cost.
• Aggregating several origins under a single statement as soon as blending takes place, thereby losing the individual traceability of each plot.
• Having a roaster that buys already-declared coffee file a statement per batch — since Regulation (EU) 2025/2650, it keeps the upstream reference numbers, it does not file.
• Waiting for the upstream supplier to solve the question alone — in a highly fragmented supply chain, the importer often has more resources than each smallholder to organise data collection.

Checklist

1. Map the supply structure: direct purchase, cooperative, or trading intermediary.
2. Check whether a shared sector initiative already exists for the supply chain and region concerned.
3. Prioritise coordinate recording by volume purchased, not by alphabetical order of supplier.
4. Document separately each origin going into a blend: its plots in your statement if you import it, its reference number if you buy it already declared.