EUDR Compliance for Coffee & Cocoa Exporters

Coffee and cocoa are the EUDR commodities with the most fragmented supply chains: millions of smallholder plots feeding a few exporters. EUDR requires you to trace beans back to individual farms. Here is how to get there.

1. What exactly is in scope

CommodityIn-scope products (Annex I)
CoffeeHS 0901: coffee beans (roasted and unroasted), coffee husks and skins, coffee substitutes containing coffee
CocoaHS 1801–1805: cocoa beans, cocoa paste, cocoa butter, cocoa powder, chocolate and preparations

Note the breadth: not just raw beans — roasted coffee, cocoa butter and finished chocolate placed on the EU market all need a Due Diligence Statement linking back to plots of origin.

2. The three requirements — and why coffee/cocoa feel them hardest

① Plot-level geolocation for every farm

Every plot of production must be geo-located in WGS-84. Plots over 4 hectares need polygons. A cooperative with 2,000 member farmers needs 2,000 valid plot records — this is the single biggest workload in the entire regulation, and the Commission's own impact estimates put smallholder data collection at the top of compliance costs.

② Deforestation-free after 31 December 2020

Farms established on land that was forest after the cut-off date are excluded. Satellite analysis per plot is the accepted evidence. Old farms under continuous cultivation are normally safe — but shade-grown systems that expanded into forest, or farms with unclear land tenure, need scrutiny.

③ Legality of production

Compliance with land-use rights, environmental and labour law of the producing country. In many origins, formal land titles for smallholders are rare — we help you build a legally defensible evidence file using the documents that do exist.

Mixed-origin lots: blending beans from many farms into one export lot is still allowed, but every plot in the blend must be documented and the DDS must declare all of them. Unmapped blending is over.

3. Practical roadmap for exporters and cooperatives

  1. Farm mapping campaign. Enumerate member farms, collect polygon or point coordinates (smartphone apps work; offline collection matters in rural areas), verify in WGS-84.
  2. Deforestation screening. Run satellite-based checks per plot against the 2020 cut-off; flag and remediate high-risk plots (this can exclude a farm from EU lots rather than lose the whole co-op).
  3. Legality file per plot or per member. Land documents, permits, labour compliance — proportionate to local reality.
  4. Traceability system. Link farmer ID → plot → harvest → lot → container. Segregation or mass-balance bookkeeping must be auditable for 5 years.
  5. DDS submission workflow. Who in your organisation submits the Due Diligence Statement, when, and how the reference number reaches your EU buyer.
Good news: if your supply chain is already certified (Rainforest Alliance, Fairtrade, organic with GPS data), you have a head start — but certification alone is not EUDR compliance. Certifications are one input to risk assessment; the DDS and plot data remain your legal responsibility.

4. How we help — from origin to EU customs

ServiceWhat you get
Gap analysis & scopingWhich of your products/HS codes are covered, current readiness score, cost-effective action plan
Farm geolocation programme designData templates, app selection advice, collection SOPs, quality checks, polygon rules
Due diligence systemSOP set covering risk assessment, mitigation, record keeping and DDS workflow
TrainingCooperative managers, exporters and field staff — remote, in English or Chinese
Ongoing advisoryUpdates as Commission guidance and country benchmarking evolve

Start with a scoping call

Tell us your origin, volumes and buyer requirements — get a solution proposal within three business days.

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