The European Union Deforestation Regulation (EUDR) has dominated conversations within the global coffee industry for the past two years. The landmark legislation is one of the most significant to affect agricultural commodity trade in recent history. 

What began as a well-intentioned initiative to combat deforestation has evolved into a complex regulatory framework that has fundamentally altered how coffee businesses must approach supply chain management and compliance.

Then, EUDR was delayed by a year, granting industry professionals more time to comply with the rules and guidelines. A recent announcement provided further simplifications, seeking to reduce the administrative burden and facilitate implementation by 30%, according to the European Commission. 

I spoke with Holger Preibisch of the German Coffee Association, Giovanna Tobar at Cumbres, Kristin Lipps at 4C Services, Louisa Sutton at DRWakefield, and Mark Furniss at Enveritas to learn what coffee businesses need to know.

You may also like our article on why UK importers and roasters need to be prepared for EUDR.

The challenges of EUDR

The EUDR marks a significant turning point in international trade and environmental governance. It goes far beyond the traditional due diligence frameworks and introduces a whole new level of legal and logistical complexity. 

“EUDR is a paradigmatic shift in compliance architecture. Given the EU market’s size and influence, the legislation is likely to set a precedent, encouraging similar legislations in other jurisdictions, and pushing global supply chains towards greater transparency,” says Holger Preibisch, the CEO and General Secretary of the German Coffee Association.

The administrative burden imposed by the EUDR represents an unprecedented challenge for every level of the coffee supply chain. Producers, exporters, importers, and roasters face compliance requirements that demand extensive documentation, technological infrastructure, and financial resources that many in the industry lack. 

The regulation requires businesses to maintain comprehensive due diligence systems that collect detailed information about every aspect of their supply chains, from the precise geolocation of farming plots to evidence of legal production practices. 

Against the backdrop of persistently high coffee prices, rising operational costs, and the continuous threat of increased tariffs, the EUDR is a major challenge that could potentially destabilise already fragile profit margins across the coffee value chain. 

However, new measures could help suppliers, buyers, and roasters by reducing their administrative burden, amount of required paperwork, and costs.

New simplifications reduce the administrative burden

Under the new simplification measures, companies can submit annual due diligence statements, rather than submitting separate statements for each shipment or batch placed on the EU market. 

Large companies can reuse due diligence statements when goods that have previously been on the EU market are reimported, thereby reducing the amount of new information that must be submitted. Members of company groups can also appoint representatives to submit the due diligence reports on their behalf. 

“For exporters like us, this change is a big relief. Submitting a due diligence report with each shipment would have been operationally intensive and potentially very expensive,” says Giovanna Tobar, Sales Coordinator for Europe at Cumbres. “Now, with an annual statement, we can focus on maintaining solid internal systems and accurate geolocation data rather than drowning in paperwork.

“It also gives roasters and importers more predictability when planning purchases and logistics,” she adds.

Previously, each shipment required individual due diligence statements, resulting in exponential increases in administrative workload for companies handling multiple origins and frequent shipments. The shift to annual reporting allows businesses to consolidate compliance activities, streamline documentation processes, and reduce the per-transaction costs associated with EUDR compliance.

The timing of this administrative relief proves particularly significant given the current trade environment. With discussions of potential tariffs affecting various sectors and ongoing concerns about protectionist trade policies, any reduction in administrative burden provides welcome relief for businesses already navigating complex international trade requirements. 

The EU can play a crucial role by supporting coffee-producing countries in collecting geodata and establishing robust databases. Ensuring that producers maintain ownership of their data is essential for fostering trust and enabling the effective implementation of deforestation-free practices. 

“Further guidance and clarification on how compliance can be proven and how implementation is expected would help reduce uncertainties in the market,” says Kristin Lipps, the Senior Sustainability Manager at 4C Services.

“The reduced administrative burden can especially benefit downstream operators, located within the EU, who can now make easier use of previously submitted due diligence statements for goods that have already entered the EU market,” she adds.

Implications for the coffee value chain

The development raises critical questions about what lies ahead for the coffee industry as it continues to navigate the EUDR landscape. While the administrative simplifications represent positive progress, business operators must consider whether these changes truly make compliance easier for all participants in the coffee value chain, particularly those in producing countries who face the greatest challenges in meeting EUDR requirements.

For coffee roasters, the annual reporting system offers significant operational advantages. Instead of managing due diligence documentation for each shipment arrival, they can now develop comprehensive annual compliance reports that cover their entire sourcing portfolio. 

This approach enables more strategic planning, more effective resource allocation, and lower administrative overhead. However, roasters must ensure that annual reporting does not compromise the thoroughness of due diligence processes or create gaps in supply chain monitoring.

Traders and importers benefit substantially from reduced administrative burden, as these businesses typically handle high volumes of transactions across multiple origins. The ability to consolidate compliance reporting reduces both direct costs and the complexity of managing multiple simultaneous compliance processes. 

However, business operators still face complications.

“Since each consignment would still need to be accompanied by the due diligence material, the timing of submitting this to TRACES is of little relevance now. In some ways, an annual cadence complicates things. If there are discrepancies, it will be long after the event, which will make reconciliation more difficult,” says Mark Furniss, the Senior Director of Partnerships at Enveritas.

“Those importing beans to the EU should be very aware of their obligations. They must be able to trace all products back to the plots of production and be confident that the coffee is in compliance with the regulations. Failure to do so could result in significant fines,” he adds.

Coffee professionals in producing countries

The implications for coffee producers, particularly smallholder farmers, remain complex despite administrative simplifications. While reduced reporting frequency may lower the administrative burden on producer organisations, the fundamental challenges of implementing traceability systems, obtaining geolocation data, and documenting legal compliance persist. 

Coffee buyers and exporters in producing countries face mixed implications from these changes. Reduced administrative costs may lower the overall expense of EUDR compliance, potentially making European market access more financially viable for smaller operators. 

However, the core requirements for supply chain mapping, risk assessment, and mitigation measures remain unchanged, indicating that significant investments in compliance infrastructure are still necessary.

“The transition remains difficult across the entire value chain. Producers, particularly smallholders, continue to struggle with limited access to technology and the necessary digital expertise,” Holger explains. “Traders are in the middle, facing pressure from both suppliers and buyers to ensure compliance.

“Roasters and importers may benefit from increased supply chain transparency, but they, like all other actors, have to absorb significant upfront costs. These include investments in new systems, training, and legal adaptation,” he adds. “Importantly, this cost burden is not limited to roasters alone. Producers, cooperatives, exporters, and traders are all incurring similar expenses to meet regulatory requirements.”

For coffee consumers, these administrative changes should theoretically result in lower compliance costs at the end of the supply chain, potentially moderating price increases related to EUDR implementation. However, the extent to which administrative savings benefits consumers depends on competitive dynamics and market structures throughout the coffee value chain.

Persistent challenges and future considerations for the EUDR

Despite the welcome administrative simplifications, numerous challenges persist in EUDR implementation. The fundamental requirement for comprehensive supply chain mapping remains one of the most significant obstacles, particularly for businesses sourcing from regions with limited technological infrastructure. 

Business operators must obtain precise geolocation data for all farming plots, implement polygon mapping for areas exceeding four hectares, and maintain documentation proving legal production practices.

“Access to digital tools in rural areas, gaps in understanding at the farm level, and the cost of implementing traceability systems remain major hurdles, especially for smallholders,” says Giovanna.

“Another challenge is the lack of global alignment. While the EU is moving forward, other markets are not necessarily aligned, which creates tension for producers trying to meet multiple requirements,” he adds.

While administrative simplifications reduce paperwork burden, they do not address the underlying challenges of implementing traceability technology in remote farming communities or building the institutional capacity necessary for comprehensive compliance systems.

“Roasters exporting to the EU should begin collecting detailed location data now,” says Louisa Sutton, the compliance manager at DRWakefield. “Registration with the EU information portal and use of their training is also recommended.”

Financial barriers to compliance remain substantial despite reduced administrative costs. 

The initial investments in traceability technology, supply chain mapping, and risk assessment systems represent significant capital expenditures that many businesses, particularly smaller operators, struggle to accommodate.

The risk-based approach underlying EUDR compliance continues to pose challenges for businesses operating in regions classified as high-risk for deforestation. These classifications, while based on environmental data, may not accurately reflect the sustainability practices of individual producers or the progress made in forest conservation efforts.

“The coffee supply chain is long, complex, and unstable. The regulation imagines a short, simple, and stable supply chain. These two competing views are at the heart of the difficulties being encountered by the sector,” Mark says.

Looking forward, the coffee industry must continue advocating for practical implementation approaches that achieve environmental objectives without creating insurmountable barriers for sustainable producers. The administrative simplifications represent positive progress, but they constitute only one element of the comprehensive changes needed to ensure that EUDR implementation serves both environmental protection and equitable trade objectives.

The success of EUDR implementation ultimately depends on the coffee industry’s ability to develop collaborative approaches that support compliance while maintaining viable business models throughout the coffee value chain. 

Administrative simplifications provide valuable relief, but they must be complemented by continued investment in technology transfer, capacity building, and support for sustainable farming practices in producing countries.

As business operators navigate this evolving regulatory landscape, the key lies in viewing EUDR compliance not merely as a regulatory obligation but as an opportunity to strengthen supply chain sustainability, improve traceability systems, and build competitive advantages through verified environmental credentials. 

Enjoyed this? Then read our article on why roasters can’t be complacent about EUDR.

Photo credits: Cumbres, DRWakefield

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