Coffee under the EUDR

For three years coffee had the shortest entry in Annex I. One heading, 0901, covering the bean in every form a green trader recognises. It made scoping conversations short and it created a widespread and entirely reasonable belief that if you sold anything more processed than roasted beans, the regulation was somebody else's problem.

That belief stopped being correct on 13 July 2026, when the Commission adopted a delegated act adding extracts, essences and concentrates of coffee to the Annex. Soluble coffee is the largest single category of coffee sold in Europe by volume of servings, and until that act it sat outside the regulation entirely. It now sits inside it, with a compliance date of 30 December 2027 — a year behind everyone else, which is the only concession the act makes.

What is in scope

Two phrases in the 0901 entry do more work than they look like they do. Coffee husks and skins brings cascara and the by-product trade into scope, which surprises businesses that think of themselves as selling a tea. And coffee substitutes containing coffee in any proportion means a chicory blend with a token percentage of real coffee is a relevant product, while the same blend with none is not. There is no de minimis threshold to fall under; "any proportion" is the whole test.

The practical shape of the addition is worth stating plainly. Soluble production runs on blends, and blends run on volume bought across many origins and many crops, often through the spot market where the seller's interest in your traceability requirements is limited. A roaster selling single-origin can trace a bag. A soluble manufacturer buying commodity-grade robusta on price is buying precisely the coffee that is least likely to arrive with plot data attached, which is why the sector was given the extra year and why the extra year is not generous.

Where the deforestation risk actually sits

Coffee's risk profile splits cleanly by species and by altitude, and reading it as one crop produces bad conclusions. Arabica grows high, on slopes, in landscapes that were often cleared generations ago; the marginal hectare of new arabica in Colombia or Ethiopia tends to come from other agriculture rather than from forest. Robusta grows low and hot, in exactly the lowland belt where remaining forest sits, and the expansion of robusta in the Central Highlands of Vietnam and in parts of Indonesia and Uganda is where the sector's genuine exposure is concentrated.

The other structural feature is that coffee is a shade crop that does not have to be. Plantings under retained canopy can look, from ten metres up, a great deal like forest — which cuts both ways. A well-shaded farm can read as forest cover in 2020 and as agriculture now without a tree having been felled, producing a false positive that has to be resolved with imagery and local knowledge rather than with a threshold. Conversely, thinning shade over an existing plantation changes very little in the imagery while changing a good deal on the ground.

This is one of the few places where the EUDR's narrow definition of forest degradation helps rather than complicates. Degradation under the regulation means a structural conversion of primary or naturally regenerating forest into plantation forest or other wooded land, and it applies to wood products. General canopy thinning over a coffee farm is not what the regulation is asking about. The question for coffee is the deforestation one: was this plot forest on 31 December 2020, and is it agricultural now.

The geometry problem

Coffee spans the full range of the four-hectare threshold, and which side a supply base falls on is a function of origin rather than of anything you control. An Ethiopian garden plot is a fraction of a hectare. A Vietnamese smallholding is one to two. A Brazilian estate in Minas Gerais is hundreds, sometimes thousands. The same buyer running all three origins is running point collection at enormous volume in one place and polygon collection over large areas in another, and the two demand completely different field programmes.

The large-estate end is the easy end, and it is worth saying so because it is where a compliance programme should start banking wins. A Brazilian fazenda is a mapped, titled, cadastrally registered property whose boundaries already exist in a file somewhere. Getting a compliant polygon is a data-transfer exercise, not a survey. The hard end is the hundreds of thousands of sub-hectare plots in Ethiopia and the smallholder belt of Vietnam, where the plot may not be individually titled and the household may farm three non-contiguous patches.

The washing station is the end of the line

Coffee loses farm identity earlier than any other commodity in the regulation. Cherry is perishable and has to be processed within hours of picking, so it goes to the nearest wet mill the same day, and the wet mill pulps everything that arrives that day together. What comes out is a day lot: a defensible, well-documented unit that corresponds to a date and a station and to no particular farm.

Everything after that compounds the problem rather than causing it. The dry mill grades and blends across day lots. The exporter assembles containers across dry mills. By the time a bag has an ICO mark on it, the population of farms behind it is a statistical property of a catchment, not a list.

The consequence is that the washing station, not the exporter and not the cooperative, is the control point that matters. A station that registers its delivering farmers and records who delivered into which day lot can produce a defensible plot list for that lot. A station that weighs cherry and pays cash cannot, and no amount of downstream documentation will reconstruct it. When an origin programme is being scoped, the question worth asking first is not how many farmers there are — it is how many stations they deliver to, because that is the number of places where the work actually has to happen.

Vietnam is low risk and Brazil is not

The country benchmarking produced a genuinely counter-intuitive result for coffee. Vietnam, the world's second-largest producer and the source of most of the robusta in Europe's instant coffee, is classified low risk. Brazil, the largest producer of both arabica and robusta, is standard risk. Ethiopia, Colombia, Honduras, Peru, Uganda and Indonesia are all standard risk; India is low.

For a soluble manufacturer this is a materially helpful result, because the robusta base of most instant blends is disproportionately Vietnamese. For a speciality roaster running Ethiopian and Colombian arabica it is the opposite: the whole supply base is standard risk, and the origins with the most fragmented farm structures are also the ones demanding full assessment and mitigation.

It bears repeating, because it is the most expensive misreading in circulation: simplified due diligence removes Articles 10 and 11. It does not touch Article 9. Vietnamese plot geometry is required in exactly the same form, to exactly the same precision, as Brazilian plot geometry. What changes is how much analysis you have to do once you hold it.

Filing the statement

The statement is filed once, by the operator first placing the goods on the EU market — for coffee, typically the importer or the roaster taking delivery of green beans. A café chain buying roasted coffee from a European roaster is downstream: it retains the reference number and does not file.

Two things about coffee statements are worth planning for. The first is payload size: a container of washed arabica assembled across several stations can carry several thousand plot geometries, and the constraint on getting that filed is the Information System's tolerance for large submissions rather than anything in the law. The implementing regulation that came into force in July 2026 added a grouping mechanism specifically to address file-size limits, which is worth knowing about before you discover the limit the hard way.

The second is the 2027 date. A business that handles both roasted coffee and soluble products will have two compliance dates for one supply base — December 2026 for the roasted line and December 2027 for the soluble line. Running two programmes against one green book is a filing and record-keeping problem more than a data problem, but it is one that wants deciding early rather than in the last quarter of 2027.

How ERWAY handles coffee

• Washing stations and cooperatives can be registered as suppliers with their own login, upload GeoJSON or map polygons directly, and be held to the same validation as any other source — which puts the work at the delivery point rather than three steps downstream.
• Thirteen named geometry checks run on every upload, including duplicate detection and plot-to-plot overlap. Duplicates matter more in coffee than elsewhere: a grower who delivers to two stations gets registered twice, and two copies of one farm inflate both your plot count and your risk denominator.
• Risk is scored per plot against the JRC Global Forest Cover 2020 baseline, with Hansen annual loss, GFW Integrated Alerts and OPERA DIST for change since. Alerts are intersected with the forest mask before they count.
• Sentinel-2 imagery for each year from 2020 is pulled per plot, which is the practical answer to coffee's shade-canopy ambiguity — a plot that scores badly on a threshold can be looked at, and shade coffee distinguished from clearance.
• Mitigation is recorded per polygon with documents attached, so a flagged plot resolves into an evidenced decision rather than a dropped supplier.
• Statements are filed to the EU Information System from the platform, with reference and verification numbers retained against the process for five years.

Common questions

Does decaffeination or roasting change whether coffee is in scope?

No. Heading 0901 explicitly covers coffee whether or not roasted or decaffeinated, so processing state does not move a shipment in or out of scope — it only ever changes how far downstream in the value chain the filing operator sits. Green, roasted and decaffeinated coffee are all the same relevant product for these purposes.

Are single-serve capsules and pods covered, and does the July 2026 soluble addition apply to them?

It depends on what is inside the capsule, not the packaging format. A pod filled with roast and ground coffee is 0901 and has been in scope since the original text. A pod filled with a soluble or freeze-dried fill is 2101 11 and only enters scope with the July 2026 addition, applicable from 30 December 2027. Two products that look identical on a supermarket shelf can sit on two different compliance timelines depending on what is inside.

How do I handle a blend combining beans from several countries in one shipment?

You geolocate the plots for each origin represented and, where an exact split is impractical for a blended lot, the due diligence statement allows quantity to be expressed as a percentage estimate rather than a precise figure. What is not available is skipping an origin because it is a minority component — every plot that contributed to the blend is a plot the statement has to cover, in proportion to what it contributed.

Are coffee substitutes like chicory or roasted grain drinks covered?

Only if they contain coffee. The 0901 entry extends to coffee substitutes containing coffee in any proportion, with no minimum threshold specified, so a chicory blend with a small percentage of real coffee is a relevant product and a chicory blend with none is not. The test is presence, not proportion.

Does green coffee traded on a commodity exchange carry the same obligation as a direct farm purchase?

Yes — the obligation attaches to the physical goods placed on the EU market, not to how they were bought. Exchange-traded lots are frequently assembled from multiple certified warehouses and origins precisely because the contract specifies quality rather than provenance, which makes them a harder starting point for plot data than a direct relationship, not an exempt one.

What about coffee that passes through an EU port but is re-exported without entering EU commerce?

Goods moving under customs transit procedures, without being released for free circulation or otherwise made available on the EU market, are generally outside what this regulation calls placing on the market. That is a narrow customs status, not a description of ordinary warehousing or blending — coffee that is stored, reprocessed or repackaged within the EU before onward sale has typically already engaged with the EU market in a way transit goods have not, and the distinction is worth confirming with customs advice rather than assumed.

Does the regulation treat Arabica and Robusta differently?

No — Annex I's coffee entry does not distinguish by species, and both Arabica and Robusta fall under the same 0901 heading with the same obligation. The risk profile differs by growing region, as discussed above, but the scope and filing requirement are identical.

What about coffee cherry husk tea, sold as a separate product from the bean?

It is covered explicitly — the 0901 entry names coffee husks and skins alongside the bean itself, so cascara and similar husk products carry the same obligation as green or roasted coffee, even though it is a by-product rather than the primary crop.

Is coffee grown under agroforestry systems assessed any differently?

Not by the regulation's test itself, which asks whether the plot was forest on 31 December 2020 and is agricultural now — an agroforestry system already established before the cut-off and unchanged since is not newly non-compliant for retaining shade trees. What agroforestry does change is how carefully a risk assessment needs to look at imagery, since dense shade cover can visually resemble forest in a way an open sun-grown farm does not.

What to do before December

1. 1

   Re-run your scope against the July 2026 act

   If you make, buy or private-label soluble coffee, extracts or concentrates, you are in scope from 30 December 2027 and were not before. That is a scope decision to revisit now, not a 2027 problem.

2. 2

   Count stations, not farmers

   The number that determines your programme is how many wet mills your volume passes through, because that is where farm identity is either recorded or lost. Farmer counts tell you the size of the eventual dataset; station counts tell you how many places you have to be.

3. 3

   Take the estate origins first

   Brazilian and other large-estate polygons are usually a file transfer from an existing cadastral record. Bank those, then spend the remaining field budget on the smallholder origins where there is nothing to transfer.

4. 4

   Do not stand down on Vietnam

   Low risk removes assessment and mitigation. It leaves the Article 9 collection duty untouched, and Vietnamese robusta is the base of most European instant coffee — which is the line now facing a 2027 date.

Coffee spent three years looking like one of the simpler commodities to scope, and for green traders it largely was. The July 2026 act ended that by pulling in the most industrial, highest-volume and least traceable end of the sector, then softening the blow with a year. The businesses that use the year to build a plot dataset will be fine. The ones that read it as a reprieve will arrive in December 2027 needing geometry for crops that were bought, blended and spray-dried two years earlier.

Published August 17, 2026 · Last reviewed August 17, 2026 against the sources listed above.