{ "id": "eudr", "url": "https://coffearium.org/entries/eudr/", "license": "CC-BY-4.0", "title": "EU Deforestation Regulation (EUDR)", "summary": "The EU rule that lets coffee be sold in or exported from the EU only if it is deforestation-free, legally produced and covered by due diligence; as of October 2026 it applies from 30 December 2026.", "domain": "sustainability", "kind": "Regulation", "stage": "trade", "topics": [ "sustainability" ], "topicSections": { "sustainability": { "id": "forests-producers-and-costs", "label": "Forests, producers and costs" } }, "lang": "en", "status": "verified", "reviewer": "Coffearium verification pass", "lastVerified": "2026-10-14T00:00:00.000Z", "updated": "2026-10-14T00:00:00.000Z", "added": "2026-10-13T00:00:00.000Z", "brief": [ "The EU Deforestation Regulation (EUDR) admits coffee to the EU market, or its export, only if it is deforestation-free, legally produced and covered by a due diligence statement or simplified declaration.1,3", "Deforestation-free means grown on land not deforested after 31 December 2020. The plots must be geolocated, with polygons for plots of more than four hectares.1", "Green, roasted and decaffeinated coffee, husks and skins are covered (Harmonized System heading 0901). Soluble coffee (2101 11 00) is added from 30 December 2027.4,14", "As of October 2026, the main obligations apply from 30 December 2026, and from 30 June 2027 for micro and small operators.3,7", "The EUDR does not apply in Switzerland, but Swiss companies selling covered coffee into the EU must meet it.12,13" ], "quickFacts": [ { "label": "Legal text", "value": "Regulation (EU) 2023/1115 of 31 May 2023, amended by Regulations (EU) 2024/3234 and 2025/2650 and Delegated Regulation (EU) 2026/2102" }, { "label": "Cut-off date", "value": "31 December 2020" }, { "label": "Coffee covered", "value": "HS heading 0901; soluble coffee (HS 2101 11 00) from 30 December 2027" }, { "label": "Applies from (as of Oct 2026)", "value": "30 December 2026 (large and medium operators, all downstream operators and traders); 30 June 2027 (micro and small operators)" }, { "label": "Geolocation", "value": "Every plot; polygon above 4 ha; at least six decimal digits" }, { "label": "Records kept", "value": "At least 5 years" }, { "label": "Country risk categories", "value": "Low, standard, high; e.g. Vietnam and Kenya low, Brazil and Colombia standard, Myanmar high" }, { "label": "Switzerland", "value": "Not an EU member; classified low risk; Swiss sellers into the EU are covered" } ], "aka": [ "EUDR", "EU Deforestation Regulation", "Regulation (EU) 2023/1115", "Deforestation-free products regulation" ], "linkTerms": [ "EUDR", "EU deforestation regulation", "deforestation regulation", "due diligence statement", "deforestation-free" ], "related": [ "deforestation-and-coffee", "sustainability-in-coffee", "certifications-and-labels", "sustainability-claims", "living-income", "shade-and-agroforestry", "climate-change-and-coffee", "harvest-calendars" ], "contested": [ "Who has until 30 June 2027: the amending regulation defers the date for operators that are natural persons, micro or small enterprises, if established as such by 31 December 2024 (timber products under the old Timber Regulation excepted)3, and the Commission's EUDR page says \"micro and small operators\"7; a Commission trade-portal news item of 28 January 2026 lists only natural persons and micro-enterprises in its table of dates.11 The legal text includes small enterprises.", "Effect on smallholder producers: the Commission reports a very simplified regime for micro or small primary operators and estimates that simplification cuts annual compliance costs by about 75%10; a 2022 commentary and a 2025 review warn that the rules may exclude or disproportionately burden smallholders.15,16 No source opened for this entry measured the effect after application." ], "corrections": [], "sources": [ { "id": "s1", "title": "Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation", "authors": "European Parliament and Council of the European Union", "year": 2023, "publisher": "Official Journal of the European Union, L 150 (EUR-Lex)", "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX%3A32023R1115", "tier": "A", "tierNote": "Original text as published; the amendments are sources 2–4. Article 29 was read in the consolidated documentation copy 02023R1115 of 26.12.2025 (FAOLEX), because the EUR-Lex text was cut off for the reading tool.", "quote": "‘deforestation’ means the conversion of forest to agricultural use, whether human-induced or not;", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s2", "title": "Reglamento (UE) 2024/3234 del Parlamento Europeo y del Consejo de 19 de diciembre de 2024 por el que se modifica el Reglamento (UE) 2023/1115 en lo que respecta a las disposiciones relativas a la fecha de aplicación (Regulation (EU) 2024/3234, Spanish edition)", "authors": "European Parliament and Council of the European Union", "year": 2024, "publisher": "Official Journal of the European Union, Series L, 23.12.2024 (copy published by the Boletín Oficial del Estado, Spain)", "url": "https://www.boe.es/doue/2024/3234/L00001-00003.pdf", "tier": "A", "quote": "La mayoría de las disposiciones de dicho Reglamento han de aplicarse a partir del 30 de diciembre de 2024.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s3", "title": "Regulation (EU) 2025/2650 of the European Parliament and of the Council of 19 December 2025 amending Regulation (EU) 2023/1115", "authors": "European Parliament and Council of the European Union", "year": 2025, "publisher": "Official Journal of the European Union, L series, 23 December 2025 (EUR-Lex)", "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202502650", "tier": "A", "quote": "shall apply from 30 December 2026.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s4", "title": "Reglamento Delegado (UE) 2026/2102 de la Comisión de 13 de julio de 2026 por el que se modifica el Reglamento (UE) 2023/1115 en lo que respecta a la lista de materias primas pertinentes y productos pertinentes (Delegated Regulation (EU) 2026/2102, Spanish edition)", "authors": "European Commission", "year": 2026, "publisher": "Official Journal of the European Union, Series L, 17.9.2026 (copy published by the Boletín Oficial del Estado, Spain)", "url": "https://www.boe.es/doue/2026/2102/L00001-00014.pdf", "tier": "A", "quote": "Esta disposición será aplicable a partir del 30 de diciembre de 2027", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s5", "title": "Reglamento de Ejecución (UE) 2025/1093 de la Comisión de 22 de mayo de 2025 por el que se establecen disposiciones de aplicación del Reglamento (UE) 2023/1115 en lo que respecta a una lista de países que presentan un riesgo bajo o alto (Implementing Regulation (EU) 2025/1093, Spanish edition)", "authors": "European Commission", "year": 2025, "publisher": "Official Journal of the European Union, Series L, 23.5.2025 (copy published by the Boletín Oficial del Estado, Spain)", "url": "https://www.boe.es/doue/2025/1093/L00001-00003.pdf", "tier": "A", "quote": "Los países que presentan un riesgo bajo o alto serán los enumerados en el anexo.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s6", "title": "Annex to the Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2023/1115 as regards a list of countries that present a low or high risk, C(2025) 3279 final", "authors": "European Commission", "year": 2025, "publisher": "European Commission, Brussels", "url": "https://ec.europa.eu/transparency/documents-register/api/files/C(2025)3279_1/090166e51d1b7b5f?rendition=false", "tier": "A", "quote": "Belarus, Democratic People's Republic of Korea, Myanmar, Russian Federation.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s7", "title": "Regulation on deforestation-free products", "authors": "European Commission, Directorate-General for Environment", "year": 2026, "publisher": "European Commission", "url": "https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en", "tier": "A", "tierNote": "A for what the Commission states; the regulation's text prevails.", "quote": "This includes soluble coffee, certain palm oil derivatives and frozen cattle tongues.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s8", "title": "Roles and responsibilities (EUDR implementation)", "authors": "European Commission", "year": 2026, "publisher": "European Commission, Green Forum", "url": "https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/roles-and-responsibilities_en", "tier": "A", "tierNote": "A for what the Commission states; the regulation's text prevails.", "quote": "This is because there must always be at least one upstream operator in the supply chain who is established in the EU.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s9", "title": "Information System for the Deforestation Regulation", "authors": "European Commission", "year": 2026, "publisher": "European Commission, Green Forum", "url": "https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/information-system-deforestation-regulation_en", "tier": "A", "quote": "Coordinates can be provided in bulk in a file using the GeoJSON standard format.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s10", "title": "Simplification review on the Regulation (EU) 2023/1115 on deforestation-free products (EUDR), COM(2026) 191 final", "authors": "European Commission", "year": 2026, "publisher": "European Commission, Brussels (4 May 2026)", "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A52026DC0191", "tier": "A", "tierNote": "A for what the Commission states and for the Commission's own estimates.", "quote": "the Commission does not consider it appropriate to propose further amendments to the basic legal text", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s11", "title": "Delay until December 2026 and other developments in the implementation of the EUDR Regulation", "authors": "European Commission, Access2Markets", "year": 2026, "publisher": "European Commission, 28 January 2026", "url": "https://trade.ec.europa.eu/access-to-markets/en/news/delay-until-december-2026-and-other-developments-implementation-eudr-regulation", "tier": "A", "tierNote": "A for what the Commission states; the legal text prevails where they differ.", "quote": "Operators who are natural persons and micro-enterprises for the rest of EUDR products", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s12", "title": "EU-Verordnung für entwaldungsfreie Produkte (EUDR) – zentrale Elemente (Faktenblatt)", "authors": "Bundesamt für Umwelt (BAFU)", "year": 2026, "publisher": "Swiss Federal Office for the Environment, Bern, 14 July 2026", "url": "https://www.bafu.admin.ch/dam/de/sd-web/ZynkpVVkvdwe/faktenblatt_zentrale_elemente_der_eu-regulierung_eudr.pdf", "tier": "A", "tierNote": "A for what the Swiss federal administration states; it notes that it cannot give binding information on how the EU enforces the EUDR.", "quote": "Schweizer Unternehmen, die relevante Rohstoffe oder Erzeugnisse gemäss EUDR in die EU exportieren, sind von der EUDR betroffen.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s13", "title": "EU-Verordnung für entwaldungsfreie Produkte (EUDR)", "authors": "Bundesamt für Umwelt (BAFU)", "year": 2025, "publisher": "Swiss Federal Office for the Environment", "url": "https://www.bafu.admin.ch/de/eu-verordnung-fuer-entwaldungsfreie-produkte-eudr", "tier": "A", "quote": "Die EUDR gilt nicht in der Schweiz.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s14", "title": "Harmonized System Nomenclature 2022, heading 09.01", "authors": "World Customs Organization", "year": 2022, "publisher": "World Customs Organization, WCO Trade Tools", "url": "https://www.wcotradetools.org/fr/harmonized-system/2022/en/020901?q=coffee+", "tier": "A", "quote": "Coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee in any proportion.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s15", "title": "Potential impacts of the proposed EU regulation on deforestation-free supply chains on smallholders, indigenous peoples, and local communities in producer countries outside the EU", "authors": "Zhunusova, E.; Ahimbisibwe, V.; Sen, L. T. H.; Sadeghi, A.; Toledo-Aceves, T.; Kabwe, G.; Günter, S.", "year": 2022, "publisher": "Forest Policy and Economics 143, 102817", "url": "https://www.openagrar.de/receive/openagrar_mods_00088269", "doi": "10.1016/j.forpol.2022.102817", "tier": "A", "quote": "Such impacts could comprise exclusion of smallholders and IPLCs from high-value supply chains", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s16", "title": "Ethiopian coffee: Production systems, geographical origin traceability, and European Union deforestation regulation directive compliance", "authors": "Urugo, M. M.; Worku, M.; Tola, Y. B.; Gemede, H. F.", "year": 2025, "publisher": "Journal of Agriculture and Food Research 19, 101695", "url": "https://agris.fao.org/search/en/providers/122436/records/67dabf9c677d8be0233ba83a", "doi": "10.1016/j.jafr.2025.101695", "tier": "A", "quote": "The stringent requirements of the EUDR may disproportionately affect smallholder farmers who rely on this sustainable agroforestry practice.", "abstractOnly": true, "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s17", "title": "Insights from EUDR preparedness exercise in the coffee sector", "authors": "European Forest Institute (EFI), EU Technical Facility on Deforestation-Free Value Chains", "year": 2025, "publisher": "European Forest Institute", "url": "https://efi.int/sites/default/files/2026-01/insights_eudr-exercise_coffee.pdf", "tier": "B", "quote": "The rush to gather polygon data at scale often leads to geometric errors and inaccuracies.", "accessed": "2026-10-13T00:00:00.000Z" }, { "id": "s18", "title": "The UK’s approach to deforestation regulations", "authors": "Department for Environment, Food & Rural Affairs (Defra)", "year": 2026, "publisher": "GOV.UK, first published 23 June 2026, updated 2 September 2026", "url": "https://www.gov.uk/government/publications/the-uks-approach-to-deforestation-regulations/the-uks-approach-to-deforestation-regulations", "tier": "A", "tierNote": "A for what the UK government states; it describes planned legislation, not law in force.", "quote": "It is expected that legislation to implement this regime in Great Britain should be delivered in 2027.", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s19", "title": "Moving, exporting or placing deforestation-free products on the market in Northern Ireland", "authors": "UK Government", "year": 2026, "publisher": "GOV.UK, published 17 July 2026, updated 27 August 2026", "url": "https://www.gov.uk/guidance/moving-exporting-or-placing-deforestation-free-products-on-the-market-in-northern-ireland", "tier": "A", "quote": "EUDR (EU regulation on deforestation-free products) will not apply in Great Britain (England, Scotland and Wales).", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s20", "title": "Environment Act 2021, Explanatory Notes – Schedule 17: Use of forest risk commodities in commercial activity", "authors": "UK Parliament; Department for Environment, Food & Rural Affairs", "year": 2021, "publisher": "legislation.gov.uk", "url": "https://www.legislation.gov.uk/ukpga/2021/30/notes/division/23/index.htm", "tier": "A", "tierNote": "Explanatory notes, not the operative text of the Act; they state that commodities will be brought into scope later by secondary legislation.", "quote": "The Secretary of State will have the power to make regulations specifying the commodities", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s21", "title": "Bundesrat führt Aussprache zur Entwaldungsverordnung der EU (EUDR)", "authors": "Der Bundesrat (Swiss Federal Council)", "year": 2024, "publisher": "admin.ch, media release, 14 February 2024", "url": "https://admin.ch/gov/de/start/dokumentation/medienmitteilungen/bundesrat.msg-id-100021.html", "tier": "A", "quote": "Der Bundesrat sieht vorderhand keine Anpassung des Schweizer Rechts vor.", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s22", "title": "H.R. 8744 (IH), Trade Responsibly for Environmental Emissions Act (TREE Act), 119th Congress", "authors": "United States House of Representatives", "year": 2026, "publisher": "U.S. Government Publishing Office, govinfo (introduced 12 May 2026)", "url": "https://www.govinfo.gov/bulkdata/BILLS/119/2/hr/BILLS-119hr8744ih.xml", "tier": "A", "tierNote": "A bill as introduced; not law.", "quote": "Beginning on January 1, 2029, it shall be unlawful for any operator or trader—", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s23", "title": "S. 3371, FOREST Act of 2023, 118th Congress – bill status", "authors": "United States Senate", "year": 2023, "publisher": "U.S. Government Publishing Office, govinfo (bill status data)", "url": "https://www.govinfo.gov/bulkdata/BILLSTATUS/118/s/BILLSTATUS-118s3371.xml", "tier": "A", "quote": "Read twice and referred to the Committee on Finance.", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s24", "title": "Importers (illegal logging laws)", "authors": "Department of Agriculture, Fisheries and Forestry (DAFF), Australian Government", "year": 2025, "publisher": "agriculture.gov.au", "url": "https://www.agriculture.gov.au/agriculture-land/forestry/policies/illegal-logging/importers", "tier": "A", "quote": "As of 3 March 2025, Australia's illegal logging laws have changed.", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s25", "title": "About the Clean Wood Act", "authors": "Forestry Agency (Rinya-cho), Ministry of Agriculture, Forestry and Fisheries of Japan", "year": 2017, "publisher": "rinya.maff.go.jp", "url": "https://www.rinya.maff.go.jp/j/riyou/goho/english/english-index.html", "tier": "A", "quote": "The Act on Promotion of Use and Distribution of Legally-harvested Wood and Wood Products (the Clean Wood Act) went into force on 20 May 2017.", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s26", "title": "Lei nº 12.651, de 25 de maio de 2012 (Código Florestal), texto compilado", "authors": "Presidência da República, Brazil", "year": 2012, "publisher": "Planalto, legislação federal", "url": "https://www.planalto.gov.br/ccivil_03/_ato2011-2014/2012/lei/l12651compilado.htm", "tier": "A", "quote": "registro público eletrônico de âmbito nacional, obrigatório para todos os imóveis rurais", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s27", "title": "Gerar declaração na Plataforma Parque Cafeeiro", "authors": "Companhia Nacional de Abastecimento (Conab), Brazil", "year": 2026, "publisher": "gov.br, service page, updated 20 March 2026", "url": "https://www.gov.br/pt-br/servicos/gerar-declaracao-na-plataforma-parque-cafeeiro", "tier": "A", "quote": "Este serviço é gratuito para o cidadão.", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s28", "title": "Xây dựng dữ liệu rừng và vùng trồng cà phê tuân thủ EUDR (Building forest and coffee-growing-area data for EUDR compliance)", "authors": "Báo Điện tử Chính phủ (Government News, Vietnam)", "year": 2024, "publisher": "baochinhphu.vn, 17 December 2024", "url": "https://baochinhphu.vn/xay-dung-du-lieu-rung-va-vung-trong-ca-phe-tuan-thu-eudr-102241217184201362.htm", "tier": "A", "tierNote": "A for what the government's official news outlet reports on the ministry's work.", "quote": "Hệ thống cơ sở dữ liệu rừng và vùng trồng cà phê tuân thủ EUDR tại 4 huyện thí điểm", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s29", "title": "Ethiopia Accelerates Efforts to Ensure EU Deforestation Regulation Compliance for Coffee Exports", "authors": "Ministry of Finance, Ethiopia", "year": 2025, "publisher": "mofed.gov.et, 13 August 2025", "url": "https://www.mofed.gov.et/blog/ethiopia-accelerates-efforts-to-ensure-eu-deforestation-regulation-compliance-for-coffee-exports/", "tier": "A", "quote": "A unified national platform has now been established to track coffee from the farm all the way to export", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s30", "title": "Terms of reference for consultancy for the second phase of coffee/cocoa farmer registration and mapping of 1,200,000 coffee farms and 200,000 cocoa farms to comply with traceability and European Union Deforestation Regulation (EUDR)", "authors": "Ministry of Agriculture, Animal Industry and Fisheries (MAAIF), Uganda", "year": 2026, "publisher": "agriculture.go.ug", "url": "https://www.agriculture.go.ug/wp-content/uploads/2026/03/TORs-for-Mapping-of-Coffee-and-cocoa-farms-for-EUDR-Compliance.pdf", "tier": "A", "tierNote": "The title gives 1,200,000 coffee farms; one deliverable gives a registry of 1,000,000 coffee farms. No issue date beyond © 2026.", "quote": "establishing a National Coffee/cocoa Traceability System in compliance with the EUDR", "accessed": "2026-10-14T00:00:00.000Z" }, { "id": "s31", "title": "Honduras avanza en el proceso de adopción del Reglamento", "authors": "Instituto Nacional de Conservación y Desarrollo Forestal, Áreas Protegidas y Vida Silvestre (ICF), Honduras", "year": 2024, "publisher": "icf.gob.hn, September 2024", "url": "https://icf.gob.hn/wp-content/uploads/2024/10/Honduras-avanza-en-el-proceso-de-adopcion-del-Reglamento.pdf", "tier": "A", "quote": "el IHCAFE ha desarrollado una aplicación móvil, como una alternativa más", "accessed": "2026-10-14T00:00:00.000Z" } ], "markdown": "## What the EUDR is\n\nThe EU Deforestation Regulation (EUDR) is Regulation (EU) 2023/1115, adopted on 31 May 2023.1 It entered into force on 29 June 2023.12 It covers seven commodities: cattle, cocoa, coffee, palm oil, rubber, soy and wood, and products made from them.7,12\n\nThe rule applies when coffee enters or leaves the EU market. A company that places covered coffee on the EU market, or exports it from the EU, must first show that it complies.1,8 Its obligations have been postponed twice and simplified once (see When it applies).2,3\n\nThis entry describes what the legal texts and the official guidance say, as of October 2026. It is not legal advice.\n\n## Three conditions for coffee\n\nArticle 3 of the regulation sets three conditions. Covered coffee may be placed on the EU market, made available on it or exported only if all three are met:1\n\n- **Deforestation-free.** The coffee was grown on land that has not been deforested after 31 December 2020, the cut-off date.1 Deforestation means converting forest to agricultural use, whether caused by people or not.1\n- **Legal.** It was produced in line with the relevant laws of the country of production.1 These include land use rights, environmental protection, labour rights, human rights, free, prior and informed consent, tax, anti-corruption, trade and customs.1\n- **Covered by a statement.** It is covered by a due diligence statement, or by a simplified declaration for the smallest producers in low-risk countries.1,3\n\n**Due diligence** is the check a company makes before it sells. In the regulation it has three parts: collecting information, assessing risk and mitigating risk.1 The **due diligence statement** is the company's declaration that it has done this and found no more than negligible risk.1,8 It is submitted in the EU's online **Information System**.8,9\n\n**Geolocation** ties a lot of coffee to the land it came from. The statement must give the location of every plot where the coffee was grown, with the date or time range of production.1 A plot is described by latitude and longitude with at least six decimal digits.1 For plots of more than four hectares, a polygon must trace the plot's boundary.1 Coordinates can be uploaded in bulk as a GeoJSON file.9\n\n## Which coffee products are covered\n\nAnnex I of the regulation lists the products by their customs codes in the Harmonized System (HS), the international product nomenclature.4,14 For coffee, the annex lists heading 0901.4 That heading covers coffee, whether or not roasted or decaffeinated, coffee husks and skins, and coffee substitutes containing coffee in any proportion.14 Green, roasted and decaffeinated coffee therefore all fall under it.14\n\nSoluble coffee was not covered at first. A delegated regulation of 13 July 2026 adds code 2101 11 00, “extracts, essences and concentrates of coffee”, to the annex.4 Its recitals say that soluble coffee was outside the product definition despite its contribution to deforestation and forest degradation.4 The addition applies from 30 December 2027.4,7 Coffee substitutes fall under the heading only if they contain coffee.14\n\n## Who must do what\n\nThe original text knew operators and traders; the amendment of December 2025 added two further roles.1,3 What a company must do depends on its role and its size.3,8\n\n- **Operator.** Places a covered product on the EU market for the first time, or exports it from the EU.1,8 The operator carries out due diligence and submits the due diligence statement.1,8 The Commission's guidance calls this role the upstream operator.8\n- **Downstream operator.** Makes new covered products from covered products that already have a statement, and sells or exports them.3 The Commission describes downstream operators as usually those who process products into other covered products.8\n- **Trader.** Anyone else in the chain who sells covered products on the EU market.1,8\n- **Micro or small primary operator.** A natural person or micro or small enterprise in a low-risk country.3 It sells coffee it grew on its own plots there.3 It submits a one-off simplified declaration instead of due diligence statements.3,8\n\nDownstream operators and traders do not carry out due diligence or submit statements.8 The first buyer from an operator collects the statement's reference number and keeps it for at least five years.8 It does not need to pass the number on to its own buyers.8 All downstream operators and traders keep certain information on their suppliers and buyers for at least five years.8 They must tell their buyers and the authorities if they learn that a product may not comply.8\n\nSize matters for the downstream roles. Large downstream operators and traders must register in the Information System.3,8 Micro, small and medium-sized ones do not.3,8\n\n
\n
\n
    \n
  1. Plot of land. Every plot is geolocated; above four hectares, by a polygon around its boundary.1
    2. \n
  2. Operator. Places the green coffee on the EU market, carries out due diligence and submits a due diligence statement.1,8
    3. \n
  3. Information System. Receives statements and simplified declarations; each statement has a reference number.8,9
    4. \n
  4. Downstream operator. A roaster making roasted coffee from green coffee with a statement; as first buyer it collects the reference number and keeps it for five years.3,8
    5. \n
  5. Trader. Sells the roasted coffee on; keeps information on suppliers and buyers for five years.8
    6. \n
\n
Roles along a coffee chain in the EU under the regulation as amended in December 2025, as described by the Commission. Schematic, not to scale.
\n
\n\n**What this means for a roaster in the EU.** The table applies the roles to common cases, as the Commission's guidance describes them.8 The company's own facts decide its role.\n\n| Case | Role | Main duties |\n|---|---|---|\n| Buys green coffee from an EU importer and roasts it | Downstream operator3,8 | As first buyer, collect and keep the reference numbers; keep supplier and buyer information for five years; register if large8 |\n| Imports green coffee from a producing country itself | Operator1,8 | Due diligence, geolocation of the plots, due diligence statement before placing on the market1 |\n| Exports coffee from the EU | Operator or downstream operator3,8 | Export is covered like placing on the market1 |\n| Shop or retailer selling bags of roasted coffee | Trader1,8 | Keep supplier and buyer information; register if large8 |\n| Micro or small producer in a low-risk country selling its own coffee | Micro or small primary operator3 | One-off simplified declaration3,8 |\n\n## When it applies\n\nAs of October 2026, most obligations of the regulation apply from 30 December 2026.3 For operators that are natural persons or micro or small enterprises, they apply from 30 June 2027.3,7 Those operators must have been established as such by 31 December 2024.3 Downstream operators and traders of all sizes apply the rules from 30 December 2026, according to the Commission.11 For soluble coffee, the date is 30 December 2027.4,7\n\nThe dates have moved twice. The original text applied most provisions from 30 December 2024.2 A regulation of 19 December 2024 postponed them by twelve months, to 30 December 2025.2 A regulation of 19 December 2025 postponed them again and simplified the obligations.3\n\n
\n
\n

Legal acts

\n
    \n
  1. Cut-off date, 31 December 2020. Coffee from land deforested after this date is not deforestation-free.1
    2. \n
  2. Regulation (EU) 2023/1115. Adopted 31 May 2023, published 9 June 2023, in force 29 June 2023.1,12
    3. \n
  3. Regulation (EU) 2024/3234, 19 December 2024. Postpones application by twelve months.2
    4. \n
  4. Implementing Regulation (EU) 2025/1093, 22 May 2025. The list of low-risk and high-risk countries.5
    5. \n
  5. Regulation (EU) 2025/2650, 19 December 2025. Postpones application again; adds downstream operators and the simplified declaration.3
    6. \n
  6. Delegated Regulation (EU) 2026/2102, 13 July 2026. Adds soluble coffee; published 17 September 2026.4
    7. \n
\n

Dates of application

\n
    \n
  1. Superseded. 30 December 2024 in the original text, then 30 December 2025.2
    2. \n
  2. 30 December 2026. Large and medium operators; downstream operators and traders.3,11
    3. \n
  3. 30 June 2027. Operators that are natural persons or micro or small enterprises.3,7
    4. \n
  4. 30 December 2027. Soluble coffee (HS 2101 11 00).4,7
    5. \n
\n
Adoption, amendments and dates of application of the EU Deforestation Regulation, as of October 2026. Dates to scale; the axis is broken in 2021–2022.
\n
\n\n## Switzerland and the EUDR\n\nSwitzerland is not an EU member, and the EUDR does not apply there.13 According to the Swiss Federal Office for the Environment (FOEN, German BAFU), it does affect Swiss companies that export covered goods into the EU.12 From 30 December 2026 large companies, and from 30 June 2027 small ones, may place such goods on the EU market only if they comply.12\n\nThe regulation addresses sellers from outside the EU in Article 7.1 A company established outside the EU may place coffee on the EU market.1 Then the first person established in the EU who makes it available counts as an operator.1 In the Commission's words, there must always be at least one upstream operator established in the EU.8 According to the FOEN, a Swiss company without an EU establishment can submit its own due diligence statement.12 It needs an EORI number for this.12\n\nA due diligence statement gives the geolocation of all plots where the coffee a product contains was grown.1 This holds for coffee roasted in Switzerland and then sold into the EU.1,12 The European Commission has classified Switzerland itself as low risk.6,12 Risk categories refer to the country where a commodity is produced, so the coffee's origin decides its category.1,5\n\nFor Swiss law, the FOEN names the Timber Trade Ordinance (Holzhandelsverordnung, HHV) for wood on the Swiss market.12,13 No Swiss source opened for this entry describes a Swiss rule on deforestation for coffee.\n\n## Around the world\n\nOutside the EU and Northern Ireland, where the EUDR applies, no law found for this entry requires coffee to be deforestation-free, as of October 2026. The United Kingdom plans such a regime, including coffee, for Great Britain.18 A United States bill would ban deforestation-linked imports but does not list coffee.22 Timber-only laws are noted where an official source was opened; they do not cover coffee. “No comparable rule found” means a search of official legislation and government sites found no law, bill or official proposal on deforestation-linked commodities. As with the rest of this entry, the table is not legal advice.\n\n| Jurisdiction | Rule | What it requires | Since / status (October 2026) |\n|---|---|---|---|\n| European Union | Regulation (EU) 2023/1115, as amended1,3 | Coffee covered; deforestation-free, legal, due diligence statement (see the sections above)1,3 | Applies from 30 December 2026; 30 June 2027 for micro and small operators3 |\n| Switzerland | No deforestation rule for coffee; Timber Trade Ordinance (Holzhandelsverordnung, HHV) for wood12,13 | EUDR does not apply in Switzerland; Swiss companies selling covered coffee into the EU must meet it12,13 | Federal Council, 14 February 2024: no adaptation of Swiss law for the time being21 |\n| United Kingdom | Great Britain: Environment Act 2021, Schedule 17; planned forest risk commodity regime18,20. Northern Ireland: EUDR19 | Schedule 17: no use of forest risk commodities not produced under relevant local laws; applies only to commodities named in later regulations20. The planned regime lists coffee18 | Great Britain: plan of 23 June 2026 (not law), consultation to follow, legislation expected in 202718. Northern Ireland: EUDR dates apply19 |\n| United States (federal) | No federal law found. Bill: TREE Act, H.R. 874422 | Would ban imports and interstate sale of goods from land deforested on or after 31 December 2020; lists cattle, cocoa, palm oil, rubber, soy and wood, not coffee22 | Bill introduced 12 May 2026, not law; prohibitions from 1 January 2029 if enacted22. FOREST Act bill of 2023 not passed23 |\n| Canada | No comparable rule found | – | – |\n| Australia | No rule for coffee found; Illegal Logging Prohibition Act 2012 (timber only)24 | Importers of regulated timber products must assess and mitigate the risk of illegally logged timber24 | Amended rules in force since 3 March 202524 |\n| Japan | No rule for coffee found; Clean Wood Act (Act on Promotion of Use and Distribution of Legally-harvested Wood and Wood Products)25 | Promotes legally harvested wood and wood products; coffee not covered25 | In force since 20 May 201725 |\n| China | No comparable rule found | – | – |\n| Taiwan | No comparable rule found | – | – |\n| South Korea | No comparable rule found | – | – |\n\n**Producing countries.** Brazil's Forest Code, Law 12.651 of 25 May 2012, requires rural properties to keep part of their native vegetation as a Legal Reserve.26 The share is 80% for forest land in the Legal Amazon and 20% outside the Legal Amazon.26 The code also set up the Rural Environmental Registry (CAR), a national electronic register compulsory for all rural properties.26 The EUDR treats legality and deforestation as separate conditions.1 Clearing allowed under national law after 31 December 2020 therefore still fails the deforestation-free condition.1\n\nSeveral origins have set up official tools for the EUDR, as of October 2026:\n\n- **Brazil.** The National Supply Company (Conab) runs the Parque Cafeeiro platform. With a property's CAR number or a Gov.br login, it generates a free declaration of no deforestation after 31 December 2020.27\n- **Vietnam.** The agriculture ministry and the Dutch organisation IDH piloted a database of forests and coffee-growing areas in four districts of Đắk Lắk and Lâm Đồng.28 It is to be linked to the ministry's national crop database.28\n- **Ethiopia.** In August 2025 the finance ministry reported a unified national platform that tracks coffee from farm to export.29 Geolocation data are to be held in the system of the Ethiopian Coffee and Tea Authority (ECTA).29\n- **Uganda.** In 2026 the agriculture ministry (MAAIF) issued terms of reference for a consultancy to register and map 1,200,000 coffee farms for a national traceability system in line with the EUDR.30\n- **Honduras.** The national forest institute (ICF) reported in 2024 that the coffee institute IHCAFE developed a mobile app to georeference coffee farms.31\n\n## Forests, producers and costs\n\nThe regulation's subject is deforestation and forest degradation linked to products sold in or exported from the EU.1 Its definitions decide what counts. A forest is land of more than 0.5 hectares with trees over 5 metres and canopy cover above 10%.1 Land mainly in agricultural use is excluded.1 Agroforestry systems, where crops grow under tree cover, count as agricultural plantations and are excluded from forest.1 Shade-grown coffee in agroforestry systems therefore counts as an agricultural plantation, not as forest.1 How complex agroforestry systems fit is discussed under Open questions.\n\nConcerns about producers were raised before and after adoption. A 2022 commentary on the proposal warned that it could exclude smallholders, indigenous peoples and local communities from high-value supply chains.15 It also named price premiums too low to cover compliance costs and more land conflicts as possible effects.15 A 2025 review of Ethiopian coffee argued that the requirements may disproportionately affect smallholders in agroforestry systems.16 It added that traceability costs could threaten producers' livelihoods.16\n\nA 2025 EU-funded preparedness exercise in the coffee sector reported that the number of producers makes geolocation hard to collect.17 It also reported that gathering polygons at scale often produced geometric inaccuracies.17\n\nThe Commission estimates that the simplifications cut companies' annual compliance costs by about 75%.10 In its estimate, they fall from EUR 8.1 billion per year under the 2023 text to EUR 2.0 billion per year.10 It describes the regime for micro or small primary operators as very simplified.10 These are the Commission's own estimates; no source opened for this entry measured costs or effects on producers after application (see Contested).\n\n\n\n## Key terms in the text\n\nThe definitions in Article 2 decide how the rules apply to a coffee farm.1\n\n| Term | Definition in the regulation (paraphrased) |\n|---|---|\n| Deforestation | Conversion of forest to agricultural use, whether human-induced or not1 |\n| Deforestation-free | Produced on land not subject to deforestation after 31 December 20201 |\n| Forest | More than 0.5 ha, trees higher than 5 m, canopy cover above 10% (or trees able to reach these in situ); excludes land predominantly under agricultural or urban use1 |\n| Agricultural plantation | Tree stands in agricultural production, including agroforestry systems with crops under tree cover; excluded from forest1 |\n| Plot of land | Land within a single real-estate property, as recognised by national law, with conditions homogeneous enough to assess the deforestation risk1 |\n| Geolocation | Latitude and longitude with at least six decimal digits; polygons for plots of more than four hectares (other than for cattle)1 |\n| Negligible risk | The level of risk at which, after a full assessment, products show no cause for concern about non-compliance1 |\n| Relevant legislation | Laws of the country of production on land use rights, environmental protection, third parties' rights, labour rights, human rights, free, prior and informed consent, tax, anti-corruption, trade and customs1 |\n| Downstream operator | Places on the market or exports covered products made from covered products that already have a statement or simplified declaration3 |\n| Micro or small primary operator | Natural person or micro or small enterprise in a low-risk country, selling products it grew on its own plots in that country3 |\n\n## Due diligence step by step\n\nOperators exercise due diligence before placing products on the market or exporting them, to prove compliance with Article 3.1 Article 8 sets three elements.1\n\n1. **Information.** Collect the information, data and documents set out in Article 9, including the geolocation of every plot and the date or time range of production.1\n2. **Risk assessment.** Take risk assessment measures (Article 10).1\n3. **Risk mitigation.** Take risk mitigation measures (Article 11).1\n\nOperators keep all documentation on due diligence for at least five years.1 **Simplified due diligence** applies under Article 13. Where all commodities come from low-risk countries or parts of them, operators need not carry out risk assessment and mitigation.1 Information collection still applies.1\n\nThe Information System is part of the Commission's TRACES platform.9 It opened on 4 December 2024.7 In its May 2026 report, the Commission planned to reopen it in June 2026.10 As of October 2026, its page states that online training for operators resumed after the reopening.9\n\n## Country benchmarking and coffee origins\n\nArticle 29 sets up three risk categories: low, standard and high.1 On 29 June 2023 every country was assigned standard risk.1 The Commission classifies countries mainly by the rate of deforestation and forest degradation, the expansion of agricultural land for the commodities, and production trends.1 Implementing Regulation (EU) 2025/1093 of 22 May 2025 lists the low-risk and high-risk countries; every country not listed stays standard risk.1,5\n\nThe category changes the work, not the conditions. Low-risk origins allow simplified due diligence and, for the smallest producers, the simplified declaration.1,3 The category also sets the minimum share of companies the authorities check (see Checks and penalties).1 The Commission reported in May 2026 that more countries were classified low risk than its initial impact assessment had anticipated.10\n\n| Category | Coffee origins (selection) |\n|---|---|\n| High risk | Myanmar (the other high-risk countries are Belarus, the Democratic People's Republic of Korea and the Russian Federation)6 |\n| Low risk | Vietnam, India, China, Lao People's Democratic Republic, Papua New Guinea, Philippines, Thailand, Timor-Leste, Yemen, Kenya, Rwanda, Burundi, Madagascar, Togo, Costa Rica, Jamaica, Dominican Republic, Cuba, United States6 |\n| Standard risk (not listed) | Brazil, Colombia, Ethiopia, Honduras, Uganda, Indonesia, Peru, Mexico, Guatemala, Nicaragua, El Salvador, Panama, Bolivia, Ecuador, Tanzania, Côte d’Ivoire5,6 |\n\nThe list is the version adopted in May 2025; the regulation provides for reviews.1,5 No later amendment to it was found for this entry as of October 2026.\n\n## Checks and penalties\n\nMember States' competent authorities carry out annual checks.1 The minimum coverage depends on the risk category of the origin.1,3\n\n| Origin | Minimum annual checks | Basis |\n|---|---|---|\n| Low risk | 1% of operators, non-SME downstream operators and non-SME traders1,3 | Article 16(10) |\n| Standard risk | 3% of the same groups1,3 | Article 16(8) |\n| High risk | 9% of the same groups, and 9% of the quantity of each product1,3 | Article 16(9) |\n\nSME stands for small and medium-sized enterprise. For legal persons, the maximum fine must be at least 4% of the company's total annual Union-wide turnover in the preceding financial year.1\n\n## The amendments in detail\n\n| Act | Date | What it changes for coffee |\n|---|---|---|\n| Regulation (EU) 2023/1115 | 31 May 2023; in force 29 June 2023 | The base text: three conditions, due diligence, geolocation, benchmarking1,12 |\n| Regulation (EU) 2024/3234 | 19 December 2024 | Application postponed by twelve months, to 30 December 2025; country list due by 30 June 20252 |\n| Implementing Regulation (EU) 2025/1093 | 22 May 2025 | List of low-risk and high-risk countries5 |\n| Regulation (EU) 2025/2650 | 19 December 2025 | Application from 30 December 2026 and 30 June 2027; new roles (downstream operator, micro or small primary operator); statement only by the operator; simplified declaration; simplification review by 30 April 2026; general review by 30 June 20303 |\n| Simplification review, COM(2026) 191 | 4 May 2026 | Commission sees no need for further amendments to the legal text10 |\n| Delegated Regulation (EU) 2026/2102 | 13 July 2026; published 17 September 2026 | Adds coffee extracts, essences and concentrates (HS 2101 11 00) from 30 December 20274 |\n\n## Open questions\n\n- A 2025 review of Ethiopian coffee argues that the complexity of agroforestry systems challenges the regulation's definition of deforestation.16 No guidance opened for this entry settles it for coffee.\n- Whether the simplifications reach the Commission's estimated cost savings in practice is not yet measured; the figure is a Commission estimate from May 2026.10\n- The effect on smallholder access to the EU market after 30 December 2026 is not established (see Contested).15,16\n\n## Key studies\n\n
\n

Zhunusova et al., 2022 – Smallholders and the proposed regulation. A commentary on the Commission's proposal, covering six commodities including coffee. It lists possible unintended effects on smallholders, indigenous peoples and local communities, from exclusion from high-value chains to land conflicts, and recommends support for an inclusive transition and regular impact assessments.

\n

Forest Policy and Economics 143, 102817 · doi:10.1016/j.forpol.2022.102817

\n
\n\n
\n

Urugo et al., 2025 – Ethiopian coffee and EUDR compliance. A review of Ethiopian coffee production systems and origin traceability against the regulation. It argues that agroforestry systems challenge the regulation's definitions and that traceability costs may weigh most on smallholders, and it discusses analytical methods for origin traceability.

\n

Journal of Agriculture and Food Research 19, 101695 · doi:10.1016/j.jafr.2025.101695

\n
\n\n
\n

European Forest Institute, 2025 – Preparedness exercise in coffee. Two national competent authorities ran a simulated check of one Belgian coffee operator and four shipments from Uganda, Vietnam, Brazil and Honduras. The report describes geolocation from many producers and polygon accuracy as practical problems; it predates the December 2025 amendment.

\n

European Forest Institute, EU Technical Facility on Deforestation-Free Value Chains · PDF

\n
" }