EU Deforestation Regulation (EUDR)

What the EUDR is#

The 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

The 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

This entry describes what the legal texts and the official guidance say, as of October 2026. It is not legal advice.

Three conditions for coffee#

Article 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

• 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
• 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
• 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

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

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

Which coffee products are covered#

Annex 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

Soluble 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

Who must do what#

The 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

• 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
• 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
• Trader. Anyone else in the chain who sells covered products on the EU market.^1,8
• 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

Downstream 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

Size 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

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.

When it applies#

As 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

The 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

Switzerland and the EUDR#

Switzerland 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

The 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

A 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

For 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.

Around the world#

Outside 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.

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

Several origins have set up official tools for the EUDR, as of October 2026:

• 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
• 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
• 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
• 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
• Honduras. The national forest institute (ICF) reported in 2024 that the coffee institute IHCAFE developed a mobile app to georeference coffee farms.³¹

Forests, producers and costs#

The 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.

Concerns 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

A 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

The 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).