EUDR for Coffee and Cocoa Importers: A Practical Guide

Which products are in scope

The CN codes covered by the EUDR for coffee and cocoa are listed in Annex I of Regulation (EU) 2023/1115. For coffee, the scope includes green and roasted coffee beans (CN 0901), coffee husks and skins (0901 90), and coffee substitutes containing coffee (2101 11 and 2101 12). Decaffeinated coffee is also in scope. For cocoa, the scope includes cocoa beans (1801), cocoa paste (1803), cocoa fat and oil (1804), cocoa powder without added sugar (1805), and chocolate and other cocoa preparations (1806).

The scope is intentionally broad. A chocolate manufacturer importing cocoa butter is as much in scope as a roaster importing green coffee beans. An importer of cocoa powder for use as an ingredient falls within the EUDR. The relevant question for any food or beverage company is: does your product or any ingredient within it derive from cocoa or coffee, and do you place that product on the EU market as the first operator in the chain?

Supply chain structure and where the obligation falls

For roasted coffee, the operator is typically the roastery that imports green beans and places roasted coffee on the EU market. If the roastery purchases green beans from a trading company who imported the beans, the trading company is the operator, and the roastery is a downstream trader. The obligation follows the first placement on the EU market.

For cocoa-derived products, the operator is typically the processor or manufacturer who imports cocoa beans or semi-processed cocoa (paste, butter, powder) and uses them in a product placed on the EU market. For companies that both import and process, the operator status is clear. For companies that purchase processed cocoa from an EU-based processor, the EUDR obligation has already been discharged by the processor, and the company acts as a trader, needing only to collect and pass on the DDS reference numbers.

The smallholder traceability challenge

Côte d'Ivoire and Ghana together account for roughly 60 to 65% of global cocoa production. Both countries have agricultural structures dominated by smallholder farmers, many with plots of 1 to 4 hectares. Ethiopia, Colombia, Brazil, Vietnam, and Honduras are among the major coffee origins, with varying proportions of smallholder farming.

Collecting GPS coordinates for each smallholder farm in a supply chain that may aggregate beans from thousands of farmers is the central practical challenge. The data collection infrastructure in the producing country determines whether an importer can comply. Several approaches have emerged in the market:

• Cooperative-level data collection, where farmers register their plots with their cooperative, which aggregates and provides the data to exporters.
• Exporter-led farm mapping programs, where the exporting company sends field teams to GPS-map all farms in their sourcing network.
• Third-party platforms that specialize in farm-level traceability data for EUDR compliance, operating in producing countries and providing data to EU importers.

Importers who source through established trading companies with long-term supplier relationships in producing countries are in a better position than those who buy on spot markets without supply chain visibility. The EUDR has, by design, created a structural advantage for traceable, relationship-based sourcing over anonymous commodity trading.

The 31 December 2020 cut-off date

The regulation's deforestation cut-off date is 31 December 2020. Land that was forested on or before that date and was subsequently converted to agricultural use to grow the commodity is not EUDR-compliant, regardless of when the goods are imported. A coffee farm established in 2022 on land that was forest in 2020 produces non-compliant coffee under the EUDR.

For most established smallholder suppliers, farms that have been in operation for many years present lower risk on this specific point. The risk is higher for new or recently expanded farms in regions with active deforestation. The satellite land cover data needed to verify the 2020 baseline is available through the Commission's monitoring tools and through commercial remote sensing providers. Some trading companies and certification bodies have pre-analyzed their supplier farm polygons against 2020 baseline land cover data and can provide this analysis to EU buyers.

Practical steps for coffee and cocoa importers

The starting point is supply chain mapping: identify every supplier and, for each lot purchased, the origin country, the exporter, and whether the exporter has farm-level GPS data available. Categorize suppliers by data readiness. For suppliers who cannot provide geolocation data, open a data collection project or begin evaluating alternatives. For suppliers who have the data, establish the data format and transmission mechanism for your EUDR-IS submissions.

For sourcing through traders or intermediaries rather than directly from exporters, verify which entity in the chain is the operator and whether they are registered with the EUDR-IS. If they are, collect their DDS reference numbers. If they are not, clarify the compliance responsibility before the next shipment. For the penalty consequences of placing non-compliant goods on the EU market, see our article on EUDR penalties. For the full compliance framework, see our guide on EUDR compliance for EU importers.