EUDR by commodity
EUDR for Coffee
Coffee is one of the seven commodities covered by the EU Deforestation Regulation (EUDR), so green, roasted and most processed coffee must be proven deforestation-free and legally produced before it is sold in or exported from the EU. The hardest part for coffee is collecting plot geolocation from large numbers of smallholder farms. This page explains what is covered and what to do.
TL;DR
- Coffee is in scope, listed in Annex I under customs heading 0901 (coffee, whether or not roasted or decaffeinated).
- You must show coffee is deforestation-free (no clearing after 31 December 2020) and legally produced, backed by a Due Diligence Statement.
- Deadlines: 30 December 2026 for large and medium companies, 30 June 2027 for micro and small ones.
- The biggest job is gathering geolocation for every plot, which for coffee usually means many smallholders.
In scope
What the EUDR covers for coffee
- Coffee, whether or not roasted or decaffeinated (CN heading 0901), which covers green beans and roasted beans.
- Coffee husks and skins, and substitutes containing coffee, where they fall under heading 0901.
- Coffee extracts, essences and concentrates, such as instant and soluble coffee, where listed in Annex I.
Annex I lists each product by its CN/HS customs code, so you confirm scope by matching your product code, not just the word "coffee".
These products are listed in Annex I of Regulation (EU) 2023/1115 by their CN/HS customs code, so you confirm scope by matching your product code, not the product name alone.
The hard part
The hard part for coffee
- Smallholder geolocation: coffee is grown by millions of small farms, so collecting latitude and longitude (and polygons for plots over 4 hectares) for every plot is the single biggest burden.
- Many origins are co-operative or aggregated supply, where lots are mixed before export and tracing each bag back to a plot is hard.
- Roasters and importers often buy through several intermediaries, so reference numbers and origin data must flow cleanly down the chain.
- Matching quantities to plots when blends combine beans from different farms and even different countries.
The dual test applies throughout: an in-scope product must be both deforestation-free, meaning no clearing after 31 December 2020, and legally produced. Art. 3
Origins and risk
Where it comes from and the risk tiers
Common origins for coffee and their current EUDR risk tier. The tier decides how much due diligence applies, with low-risk origins allowing simplified due diligence. Country benchmarking (2025/1093)
- BrazilStandard risk
- VietnamLow risk
- ColombiaLow risk
- EthiopiaLow risk
- IndonesiaStandard risk
A country’s tier sets how much due diligence applies. Low-risk origins allow simplified due diligence; standard-risk origins need the full process. Always check the current tier, as the list is reviewed in 2026.
What to do
What to do for coffee
- Confirm scope by matching your coffee products against the CN/HS codes in Annex I.
- Map your supply chain back to the farm or plot level, including any co-operatives and intermediaries.
- Collect geolocation for every plot, plus country of production, quantities and supplier details.
- Check the risk tier of each country of production and run risk assessment and mitigation where the origin is standard or high risk.
- File a Due Diligence Statement in the EU Information System and pass the reference number down the chain.
For the full obligations and the due-diligence process, see the EUDR obligations guide, and for collecting data from suppliers see the supplier data guide.
Proposed Annex I change for coffee, not yet law
FAQ
Coffee and the EUDR: common questions
- Is roasted coffee covered by the EUDR?
- Yes. CN heading 0901 covers coffee whether or not roasted or decaffeinated, so both green and roasted coffee are in scope. You confirm the exact products by matching your customs codes against Annex I.
- Is decaffeinated coffee in scope?
- Yes. Decaffeinated coffee falls under the same heading 0901 as regular coffee, so it is treated the same way under the EUDR.
- Is instant or soluble coffee covered?
- Coffee extracts, essences and concentrates are addressed in Annex I, and a draft change proposed on 4 May 2026 would explicitly add soluble (instant) coffee. Check your specific CN code against the current Annex I, since the draft is not yet law.
- When do coffee importers have to comply with the EUDR?
- Large and medium operators and traders must comply from 30 December 2026, and micro and small enterprises from 30 June 2027. The later date only applies to firms already established as micro or small by 31 December 2024.
- How do I get geolocation from smallholder coffee farms?
- You collect latitude and longitude for each plot, with polygons required for plots over 4 hectares, usually working through exporters or co-operatives. For micro and small primary producers in low-risk countries, a simplified declaration and even a postal address may apply in some cases.
Get ready for the EUDR
Work through the EUDR Readiness Checklist, then explore the tools and guides built for your role.
This is guidance, not legal advice
Sources
- [1]Regulation (EU) 2023/1115, consolidated text including Annex I (EUR-Lex)retrieved 4 Jun 2026
- [2]European Commission: Regulation on deforestation-free productsretrieved 4 Jun 2026
- [3]European Commission Green Forum: EUDR implementationretrieved 4 Jun 2026
- [4]First country benchmarking list under the EUDR (2025/1093)retrieved 4 Jun 2026
- [5]Council of the EU: targeted revision (second delay and simplification)retrieved 4 Jun 2026
- [6]Commission simplification review of 4 May 2026 (draft Annex I changes)retrieved 4 Jun 2026
The EUDR Brief
Subscribe to The EUDR Brief
We watch Brussels so you don't. Plain-English EUDR updates, free.
No spam. Unsubscribe anytime.