The EUDR for coffee and cocoa: what importers, roasters, grinders and chocolate makers must do by 30 December 2026

In brief

Coffee and cocoa are the commodities where the EUDR reaches deepest into the supply chain. At the start are millions of smallholders with plots of one or two hectares, in between cooperatives, collectors and exporters, and at the end an importer in Hamburg or Antwerp who must know, for every batch, which plots it comes from. Covered are green coffee, roasted coffee, decaffeinated coffee, coffee husks and skins and coffee substitutes containing coffee under heading 0901, and the whole cocoa chain from bean to chocolate, headings 1801 to 1806. Soluble coffee is added on 30 December 2027. For cocoa the amendment of Annex I added nothing and only excluded cocoa shells and cocoa waste insofar as they are waste within the meaning of the Waste Framework Directive.

Due diligence lies with the importer, that is, whoever appears as importer in the customs declaration. For most origins it must be exercised in full: Brazil, Colombia, Ethiopia, Honduras, Peru, Côte d'Ivoire and Ecuador are standard risk. Vietnam, India, Ghana, Costa Rica and Kenya are low risk, where simplified due diligence without risk assessment is enough if the check of the supply chain shows only a negligible risk of circumvention or mixing.

Anyone who buys duty-paid green coffee from a supplier established in the EU and roasts it is, according to the Commission FAQ, a trader, not a downstream operator, because roasting does not leave the four-digit heading 0901. The cocoa chain is different: liquor, butter, powder and chocolate each have their own heading, so whoever makes something new from them is downstream. Neither role submits a statement. In chocolate only the cocoa counts; the palm fat in it needs no due diligence.

The deadlines contain a trap. Large and medium importers are due on 30 December 2026, micro and small enterprises that import themselves and were established as such by 31 December 2024 on 30 June 2027. But the deferral only applies to operators. The small roaster buying from an importer is a trader and has 30 December 2026, with few obligations, but without deferral.

What needs doing now: sort origins by country risk, request plot lists per batch from exporters and cooperatives, put segregation into contracts, record stock in customs warehouses and apply for information system access. Obtaining data from the countries of origin takes longer than anything else.

Which products are covered

Since 18 September 2026 Annex I applies in the version of Delegated Regulation (EU) 2026/2102. For coffee and cocoa the list is short, which is exactly why the edges deserve a look.

Coffee, heading 0901. Covered are coffee, whether or not roasted or decaffeinated, coffee husks and skins, and coffee substitutes containing coffee in any proportion. That includes green coffee (0901 11 and 0901 12), roasted coffee as beans or ground (0901 21 and 0901 22), and with it capsules and pods containing roasted coffee, coffee husks and skins, and coffee blends with chicory or cereals if they contain coffee.

New from 30 December 2027: 2101 11 00. Extracts, essences and concentrates of coffee, that is, soluble coffee and coffee extract. Preparations with a basis of such extracts (2101 12, such as three-in-one mixes) were not added, nor were coffee beverages of heading 2202.

Cocoa, headings 1801 to 1806. Cocoa beans raw or roasted (1801), cocoa shells and skins (1802), cocoa paste (1803), cocoa butter, fat and oil (1804), cocoa powder without added sugar (1805), and chocolate and other food preparations containing cocoa (1806). Since 18 September 2026 cocoa shells and cocoa waste are excluded insofar as they are waste within the meaning of the Waste Framework Directive.

What is not covered. Bakery products with cocoa or chocolate coating (1905), ice cream (2105), coffee beverages, coffee liqueur and all products whose CN code is not in Annex I, even if they contain coffee or cocoa. The Commission expressly names bread, cakes and biscuits with cocoa and coffee beverages as examples outside the scope in its FAQ. Also not covered are samples for sensory evaluation: anyone importing a small lot of green coffee from a new region for cupping and using it up completely in the testing to decide on a larger order is outside the Regulation under note 5(b) to Annex I, inserted by Delegated Regulation (EU) 2026/2102.

Composite products. A chocolate bar contains cocoa liquor, cocoa butter, often palm fat or other vegetable fats and sometimes soy lecithin. The Commission settled the question in FAQ 1.3: due diligence and information requirements extend only to the commodity under which the product is listed in Annex I, so for chocolate of heading 1806 to the cocoa. The palm fat in the chocolate does not have to be traced. Anyone who buys and imports palm oil as such, however, has the obligations of an operator for palm oil.

How the new Annex I is structured overall and how to check your own articles against it is in E4 Annex I and CN codes.

The four-digit rule: why the roaster stays a trader

Under the EUDR the role depends on whether a company places on the market a product it made from products already declared. In FAQ 3.1.1 the Commission specified when such a new product arises: only if the digits of the CN code that are listed in Annex I change. Annex I lists coffee as the four-digit heading 0901. Green coffee (0901 11) and roasted coffee (0901 21) share those four digits.

The FAQ uses exactly this example: company A imports unroasted coffee and is an operator. Company B roasts it in the EU and sells the roasted coffee. B is a trader, not a downstream operator, because the four-digit heading stays the same. The same applies to decaffeinating and grinding.

In the cocoa chain the heading changes with almost every processing step. The bean (1801) becomes liquor (1803), the liquor butter (1804) and powder (1805), and from those chocolate (1806). Whoever carries out one of these steps with already declared goods is a downstream operator. The FAQ names the chocolate manufacturer who buys cocoa beans in the EU and makes bars as an example.

Whoever stays within 1806 stays a trader: the confectioner who buys couverture (1806 20) and makes pralines or bars from it (1806 31, 1806 32, 1806 90) does not change the four-digit heading. Whoever turns couverture into cakes or biscuits makes a product outside Annex I and has no role under the Regulation for those products. The FAQ describes the same case for coffee: a company that buys green coffee, roasts it and uses it only for coffee pastry has no obligations under the EUDR.

In practice the distinction between trader and downstream operator changes little, since Regulation (EU) 2025/2650 treats both alike: no statement of their own, collecting details of suppliers and of customers that are themselves traders or downstream operators and keeping them for five years, and for non-SMEs additionally registration in the information system and verification on reasoned concern. For exports there is one exception to the rule: whoever exports goods that someone else placed on the market is, under FAQ 5.6.1, always a downstream operator, because traders by definition only make available. The roaster delivering to Great Britain is therefore downstream at export.

The deadlines: three dates and a trap

30 December 2026 applies to large and medium-sized companies importing coffee or cocoa, to small importers not yet established as such by 31 December 2024, and to all downstream operators and traders regardless of their size.

30 June 2027 applies to operators that are natural persons, micro or small enterprises and were established as such by 31 December 2024. The exception for EUTR-annex timber plays no role for coffee and cocoa; the small specialty roaster importing its own green coffee therefore has six more months.

30 December 2027 applies to soluble coffee and coffee extracts of subheading 2101 11 (CN code 2101 11 00), for all companies.

The trap. Article 38(3) grants the deferral expressly to "operators", and under Article 2(15) and (17) operators are neither downstream operators nor traders. The small roaster buying from the Hamburg importer therefore has 30 December 2026, even with eight staff. Its obligations are manageable: it records its supplier's name and address, the reference numbers of the statements and the details of customers that are traders or downstream operators, and keeps them for five years. But it has to do so from 30 December 2026.

Conversely, a small importer's deferral relieves its customers. If a micro or small enterprise established as such by 31 December 2024 imports green coffee before 30 June 2027, the obligation of all subsequent traders and downstream operators is limited to proving that the goods were placed on the market in that transitional period. For imported goods the customs declaration suffices as evidence (FAQ, section 9).

Existing stock. For coffee and cocoa released for free circulation before the date applying to the importer, that is before 30 December 2026 or, for small importers, before 30 June 2027, the Commission guidelines limit the obligations to evidence, even if they are sold or processed later; goods placed on the market later and mixed in are subject to the full obligations. For imported goods the customs declaration is the evidence. Goods harvested before 29 June 2023 are never covered; on import they are declared with code Y132.

Customs warehouses. Green coffee and cocoa beans often sit for months uncleared in customs warehouses in the big ports. As long as the goods are there, they have not been placed on the market. If they are released for free circulation on or after 30 December 2026 (by small importers established as such by 31 December 2024: on or after 30 June 2027), they need a due diligence statement, even if they landed in 2025, provided they were harvested on or after 29 June 2023. Anyone with stock in a customs warehouse today should release it by 29 December 2026 at the latest or obtain the data for the statement now. A coffee tax warehouse under German excise law is not a customs warehouse: coffee in it is already in free circulation under customs law, and the tax suspension changes nothing for the EUDR.

The roles in the coffee chain

The importer. The operator is whoever appears as importer in the customs declaration, regardless of when ownership passes. Full or simplified due diligence applies depending on the country of production, the statement before release for free circulation, passing the reference number to customers that are traders or downstream operators (the verification number voluntarily) and keeping records for five years. Every operator needs the due diligence system under Article 12 with annual review; as a non-SME, a compliance officer at management level, an independent audit function and the public annual report are added.

Buying in bond. Many trading houses sell green coffee uncleared ex warehouse. If the buyer declares the goods for release itself, it is the importer and therefore the operator, with all obligations, even if it only takes one container a year. Anyone wanting to avoid this buys duty-paid from a supplier established in the EU; anyone buying in bond must get the plot data for the batch from the seller.

The roaster. If it buys duty-paid green coffee from a supplier established in the EU, it is a trader; if a company not established in the EU imported the goods, the roaster is deemed an operator under Article 7. If it imports itself, it is an operator. Many roasters hold both roles depending on origin: direct trade with a cooperative in Colombia through its own import, standard qualities through an importer.

The toll processor. Decaffeination and toll roasting often happen on behalf of others without ownership passing. Service providers without ownership rights in the product are, according to the guidelines, neither operators nor traders. The obligations stay with the principal.

The soluble coffee manufacturer. Before 30 December 2027 soluble coffee is not a relevant product; whoever buys green coffee in the EU and extracts it has no obligations for the extract. From 30 December 2027 it is a downstream operator, because 0901 becomes 2101 11. Whoever imports soluble coffee is an operator from that day, with due diligence for the plots of the green coffee from which the extract was made.

Retail, hospitality and e-commerce. Supermarkets, specialist retailers and online shops are traders; non-SMEs among them register and verify on reasoned concern. Whoever has own brands roasted at origin and imports them is an operator for those. The café serving coffee drinks does not make a relevant product available; if it sells beans in bags, including to consumers, it is a trader for those. Pods, incidentally, are also subject to the PPWR, which requires them to be industrially compostable from 12 February 2028, see P13 PPWR deadlines.

The roles in the cocoa chain

The grinder. It imports cocoa beans and processes them into liquor, butter and powder. For the import it is an operator and submits the due diligence statement. When selling the semi-finished products it is at the same time, under FAQ 3.8, the first downstream operator, because it sells products made from beans already declared. In this dual role it does not have to pass the reference number of its import statement on to its customers; it keeps it available for inspections itself.

Processing at origin. Côte d'Ivoire, Ghana, Ecuador and Indonesia grind a growing share of their harvest themselves. Whoever imports cocoa butter or powder is an operator for a product containing cocoa from many plots. Geolocation refers to the plots of the beans contained in the batch of butter. That requires segregation from the processor at origin, which in mills with several supply chains is a project of its own.

The chocolate maker. If it buys liquor, butter and powder from an EU grinder, it is a downstream operator. It collects the identity of its suppliers and customers and, where its supplier is an operator for the goods delivered, the reference numbers. As a non-SME it registers and verifies on reasoned concern. If it imports beans or semi-finished products itself, it is an operator for those. Several processing steps in-house only trigger obligations for the product last placed on the market, under FAQ 2.11.

The confectioner. Couverture becomes pralines: trader, because 1806 remains. Couverture becomes cakes: no role, because bakery products are not covered.

Retail and own brands. Supermarkets are traders for chocolate. The own brand produced by a German manufacturer is placed on the market by the manufacturer; the retailer is a trader. If the retailer sources own-brand chocolate from Switzerland, it is an operator as importer, with due diligence for the cocoa plots, not for Switzerland as the country of manufacture. If it sources it from Belgium, the Belgian manufacturer placed it on the market and the retailer remains a trader.

Geolocation for smallholders and cooperatives

For importers, geolocation is the part everything hinges on. Required are the coordinates of all plots on which the coffee or cocoa of a batch was grown, with latitude and longitude to at least six decimal places, plus the harvest period. For plots under four hectares a point is enough, above that a polygon is mandatory (FAQ 1.8). The smallholder structure of coffee and cocoa is, for once, an advantage here: in Vietnam, Ethiopia, Uganda, Côte d'Ivoire and Ghana most plots are under four hectares, so points suffice. In Brazil many coffee farms are larger; there, farms often supply their boundaries from the rural environmental registry CAR, in which registered properties are georeferenced.

What is not required from the farmer. The Commission clarifies in FAQ 1.10 that no personal data of farmers are required as long as they are not the importer's direct suppliers; the geolocation of the plot is enough. A land register entry or title is not required if national law does not require it for growing and selling. Who supplies the data, whether cooperative, exporter, certifier or a national system, does not matter; responsibility for its accuracy remains with the importer under FAQ 1.11.

Where the data come from. Cooperatives increasingly map their members with smartphone apps, exporters keep plot lists per lot, certification schemes have farm maps, and the cocoa authorities in Côte d'Ivoire and Ghana are building national traceability systems with farmer registration and plot mapping. For importers that means: the data often exist, but in different formats, with gaps and duplicates. Before they go into a statement they must be converted to GeoJSON, checked for plausibility (points in the sea, overlapping polygons, plots over 4 hectares given as a point) and checked against satellite imagery.

Segregation, not mass balance. The Commission rules out mass balance models in FAQ 1.4: goods whose plots are known and deforestation-free may not be mixed with goods of unknown origin at any stage. Full identity preservation per plot is not needed. An exporter may therefore blend coffee from 800 mapped plots into one lot, provided all 800 are in the statement and nothing else goes in. If a part is non-compliant and can no longer be separated, the whole batch cannot be placed on the market under FAQ 1.5.

Declare more plots as a precaution? The FAQ allows listing all plots that may have contributed to a lot, but only where fully mapped goods were mixed in a warehouse, a ship or a mill and only part of them goes to the EU. Anyone who does so, however, takes responsibility for all of them: any deforestation on one of the listed plots makes the whole product non-marketable. An entire membership list only belongs in the statement if coffee or cocoa from all those plots entered the stock from which the lot comes; otherwise it is generally not permitted under FAQ 1.18.

Agroforestry is not forest. Coffee under shade trees and cocoa in agroforestry systems do not count as forest under the definition of agricultural plantation (FAQ 4.14). An existing agroforestry plot is therefore not forest land that may not be used. Conversely, converting forest into cocoa agroforestry after 31 December 2020 is deforestation. The Commission's global forest map GFC 2020 expressly does not show coffee and cocoa plantations as forest; it is an aid, not a binding basis.

File size. A statement including geodata may not exceed 25 megabytes (FAQ 1.7). For lots with thousands of plots as polygons that is a practical limit; points for small plots, simplified polygons and splitting across several statements that can be bundled in an aggregated statement solve it.

Country risk of the main origins

The Commission classified the countries with Implementing Regulation (EU) 2025/1093; the list names the low-risk and high-risk countries, all others are standard risk. For coffee and cocoa the picture surprises many, because it cuts across the volumes.

Low risk: Vietnam, India, Ghana, Costa Rica, Kenya, Rwanda, Papua New Guinea, Laos, the Dominican Republic, Jamaica, the Philippines and Yemen. For goods from there, simplified due diligence under Article 13 applies: collect information and geolocation, assess and document the supply chain and the risk of circumvention and mixing, submit the statement, but no risk assessment under Article 10 and no risk mitigation. Authority control rate: at least one percent of the companies concerned.

Standard risk: Brazil, Colombia, Ethiopia, Honduras, Guatemala, Peru, Mexico, Nicaragua, Indonesia, Côte d'Ivoire, Ecuador, Cameroon and Nigeria. Full due diligence with risk assessment and risk mitigation, control rate at least three percent.

High risk: Myanmar, Russia, Belarus and North Korea. Control rate at least nine percent of companies and nine percent of the quantity.

Two consequences matter for cocoa. First, the two largest origins sit in different categories: Ghana is low risk, Côte d'Ivoire standard risk. Second, the simplification only applies if the goods really come from the low-risk country. Article 13 requires the importer, after assessing the supply chain, to be able to show only a negligible risk of circumvention or of mixing with goods of unknown origin or from standard-risk or high-risk countries; if there are indications of a risk, full due diligence must be exercised and the authority informed. For West African cocoa, where beans are traded across borders depending on price differences, checking the origin therefore belongs in the documentation even for Ghana cocoa. For coffee the same applies at trading hubs where goods of different origins come together.

The classification is reviewed regularly; the version of the implementing regulation in force applies. And it assesses countries, not commodities: there is no "negligible risk" status for coffee or cocoa from a particular country under FAQ 5.11.

Risk assessment and mitigation in practice

For standard-risk origins the importer assesses under Article 10(2), among other things, country and regional risk, forests and indigenous peoples in the growing area, the prevalence of deforestation, corruption and law enforcement, the complexity of the supply chain and the risk of circumvention and mixing. For coffee and cocoa that concretely means:

Deforestation. Every plot is checked against satellite imagery since 31 December 2020. Hits at forest edges and in protected areas need clarification before the batch is declared. In Côte d'Ivoire growing in protected forests is a known pattern; plots located in such areas are to be excluded even if the conversion happened before 2020, because legality is then missing.

Legality. Article 2(40) lists the law of the country of production on land use rights, environmental protection, third parties' rights, labour rights, human rights, the consent of indigenous peoples, taxes, anti-corruption and customs. In West African cocoa production, child labour is a widely documented risk; it belongs in the legality check because labour rights and human rights are part of the relevant legislation. Evidence includes cooperative audits, monitoring and remediation programmes and documentation of working conditions.

Complexity and mixing. The more intermediaries stand between farmer and exporter, the higher the risk that unmapped goods enter a lot. Mitigation here means shorter chains, contracts with a segregation obligation, spot checks at collectors, and matching the quantity delivered against the plausible harvest of the plots listed.

Certification. Rainforest Alliance, Fairtrade, 4C and organic labels are, under FAQ 5.7, an aid in the risk assessment insofar as they cover the necessary information. They replace neither geolocation nor the statement, and certificates on a mass balance basis do not meet the segregation requirement.

Outcome and documentation. Only if the risk is then negligible may the statement be submitted. Assessment and mitigation are documented, reviewed at least annually and kept for five years. How due diligence is structured overall is in E12 EUDR guide.

The due diligence statement for coffee and cocoa

The statement is submitted in the EU information system, before release for free circulation and with lead time, because the authority can reject it until the reference number is issued. It contains the CN code, the description with trade name, the quantity in kilograms of net mass, the country of production and the geolocation of all plots; the importer keeps the harvest period in its records.

Three tools are particularly useful for coffee and cocoa. One statement may cover several shipments of the same product for up to twelve months until the declared quantity is used up; an annual contract with a cooperative can thus be mapped with one statement. The aggregated statement, introduced with Implementing Regulation (EU) 2026/1565, bundles many reference numbers into one for customs and customers. And the web services allow statements to be submitted in large numbers from the company's own system.

After submission the importer receives the reference and verification number and passes the reference number to customers that are traders or downstream operators, the verification number voluntarily, ideally on contract, delivery note and invoice. Everything on the statement is in E2 Due diligence statement, on the number and its passing on in E1 Reference number.

Customs: import, customs warehouse, re-export and export

On import the reference number is stated with document code C716 in the customs declaration, with the ten-digit TARIC code. Goods harvested before 29 June 2023 receive Y132. Without a valid entry, import is not permitted after the check.

If goods stay in a customs warehouse and are exported again from there, such as green coffee from Hamburg to a roaster in Switzerland, that is a re-export under Article 270 of the Union Customs Code. It is not covered by the Regulation, because the goods were never placed on the market. For trading houses that run European warehouses for third-country customers, that is an important relief.

If goods already released are exported, such as roasted coffee to Great Britain or chocolate to Switzerland, the exporter is a downstream operator. Under FAQ 5.6.1 it does not have to state a reference number; the Commission provides a dedicated TARIC certificate code for this. At the editorial deadline it had been announced but not yet published. The suppliers' reference numbers are in the company's records anyway; which code will be used should be agreed with the customs agent before the first export from 30 December 2026. Whoever imported and did not process the goods into a product of another heading, for example only roasted them, remains an operator when exporting and makes its reference number available. All cases with a decision tree are in E6 Export and re-import, the codes in the Glossary TARIC codes.

Six businesses, six answers

The specialty roaster, 8 staff. Imports green coffee directly from Colombia and Ethiopia, plus Kenyan coffee through an importer. For the direct imports an operator with full due diligence, because both countries are standard risk; as a micro enterprise established before 2025, with deadline 30 June 2027. For the Kenyan coffee from the importer a trader with deadline 30 December 2026; obligation: record supplier, reference number and customers that are traders or downstream operators. Cupping samples from new regions are not covered.

The green coffee importer in Hamburg, 45 staff, 80 million euros turnover, 20 million euros balance sheet total. Despite few staff, not a small enterprise: turnover and balance sheet total exceed two of the three small thresholds, so medium-sized and deadline 30 December 2026. Origins Brazil (standard, polygons from CAR), Honduras (standard, points from cooperatives) and Vietnam (low, simplified due diligence). If it sells uncleared ex warehouse, the buyer becomes the operator; if it sells duty-paid, it passes on the reference numbers, and the verification numbers on request.

The large roaster, 400 staff. Buys duty-paid green coffee from several importers, supplies retail in Germany and exports to Switzerland. Domestically a non-SME trader: registration in the information system, supplier and customer data including reference numbers, verification on reasoned concern, no statement of its own. At export a downstream operator without a reference number in the export declaration. Deadline 30 December 2026.

The cocoa grinder, 600 staff. Imports beans from Côte d'Ivoire (standard), Ghana (low) and Ecuador (standard) and sells liquor, butter and powder. Operator at import with a statement per origin; full due diligence for Côte d'Ivoire and Ecuador including checks on protected areas and working conditions, simplified for Ghana with a check on origin. When selling semi-finished products downstream, without an obligation to pass on the import reference numbers. Due diligence system; as a non-SME also compliance officer, independent audit function, annual report. Deadline 30 December 2026.

The chocolate maker, 900 staff. Buys liquor and butter from EU grinders, plus palm fat, milk powder and sugar. Downstream operator for the chocolate; the palm fat in the recipe needs no due diligence (FAQ 1.3). Registration, collecting supplier and customer data, verification on reasoned concern. For exports to Great Britain downstream without a reference number. Deadline 30 December 2026.

The confectioner, 12 staff. Buys couverture, makes pralines and cakes, sells to consumers and to two hotels. For the pralines a trader, because 1806 remains; to be recorded are the supplier and the two hotels as business customers. For the cakes no role. Deadline 30 December 2026, without deferral, because the confectioner does not import itself.

Controls in Germany

For coffee and cocoa, the Federal Office for Agriculture and Food alone is competent in Germany under the draft EntwaldungsMG, because there is no domestic primary production. It checks on a risk basis with the minimum rates from country benchmarking, works with customs and can trigger checks at the border in which release is suspended. What is checked: the due diligence system, the risk assessment, the geodata and their provenance, segregation in the chain, and for traders the completeness of supplier and customer data. Under the draft, fines reach up to four percent of EU-wide annual turnover, placing non-compliant goods on the market, making them available or exporting them intentionally or recklessly is a criminal offence, and sales bans, exclusion from public contracts and funding and a ban on simplified due diligence, each for up to one year, are added.

Roadmap to 30 December 2026

September: sort. Check all articles with CN code against Annex I, note 2101 11 00 for 30 December 2027. Determine the role per sourcing route: import, in-bond purchase, duty-paid purchase, processing. Sort origins by country risk. Record stock in customs warehouses and decide what is released before 30 December.

October: request data. From exporters and cooperatives, request per lot the plot list with coordinates, area, harvest period and legality evidence, with a commitment to segregation. With countries of origin that takes eight to twelve weeks, longer with cooperatives without digital mapping. Apply for information system access.

November: check and document. Convert geodata to GeoJSON, check plausibility and check against satellite imagery. Document the risk assessment per standard-risk origin, define mitigation measures; for low-risk origins document the check under Article 13. Record the due diligence system under Article 12 in writing. Submit test statements, brief the customs agent.

December: declare. Submit statements for all releases from 30 December 2026 with lead time, for annual contracts with validity of up to twelve months. Reference and verification numbers on contracts and invoices. Traders and processors: record supplier and customer data from 30 December 2026.

For small importers with the 30 June 2027 deadline the plan shifts by six months, but the data request to origin should still start now, because the 2026 and 2027 harvests already need to be captured.

Seven misconceptions from the industry

"We only roast, that is downstream, so as a small enterprise we have until June 2027." Roasting makes you a trader, and the deferral only applies to importers. Your deadline is 30 December 2026.

"Our coffee is Rainforest Alliance certified, so the EUDR is covered." Certificates help with the risk assessment but replace neither geodata nor the statement.

"Mass balance is enough." The Commission expressly rules out mass balance. Segregation of goods of known origin is mandatory.

"We also need geodata for the palm fat in our chocolate." No. In chocolate of heading 1806 only the cocoa counts.

"Ghana is West Africa, so full due diligence." Ghana is low risk, Côte d'Ivoire standard risk. The simplification presupposes, however, that the beans really come from Ghana.

"The cooperative sends all members' plots, so we are on the safe side." The reverse: whoever declares more plots is liable for all of them, and plots that cannot have contributed to the lot do not belong in the statement at all.

"What sits in the customs warehouse is old stock." Only what was released for free circulation before 30 December 2026 (for small importers before 30 June 2027). Goods in a customs warehouse are only placed on the market on release.

How Polygon One maps coffee and cocoa chains

Polygon One collects plot data through a supplier portal that exporters and cooperatives use without an account of their own, in any format from an Excel list to a shapefile. Points and polygons are normalised, checked for plausibility and analysed against satellite imagery for deforestation after the cut-off date, with the legal analysis per plot running alongside. Every batch is kept with its plots, harvest period and country risk, so the importer can see where full and where simplified due diligence applies. Statements go out through the connection to the information system, aggregated statements bundle annual contracts, and reference numbers come back to the contract. For roasters and chocolate makers the software keeps suppliers, customers and numbers the way Article 5 requires.

What the software does not do: determine your role in law, judge the legality of a plot or sign the assurance in the statement. If you would like to see what your coffee or cocoa chain looks like in this structure, book a demo or read on at the EUDR module product page.

Download the EUDR Coffee and Cocoa Compass 2026

Four pages for purchasing, quality assurance and compliance: codes and deadlines, roles and the six cases, geolocation with a template for the data request to exporters and cooperatives, country risk of the main origins and a roadmap.

• Download: EUDR Coffee and Cocoa Compass 2026 (PDF)

Frequently asked questions

From when does the EUDR apply to coffee and cocoa?

From 30 December 2026 for large and medium importers and for all traders and downstream operators. Micro and small enterprises that import themselves and were established as such by 31 December 2024 are covered from 30 June 2027. Soluble coffee is added on 30 December 2027.

Is a roaster an operator, a trader or a downstream operator?

If it buys duty-paid green coffee from a supplier established in the EU, it is a trader, because roasting does not change heading 0901. If it imports itself, it is an operator. When exporting goods someone else imported, it is a downstream operator; coffee it imported itself it exports as an operator, even when roasted.

Does a small roaster have to submit a due diligence statement?

Only for coffee it imports itself or buys from an importer not established in the EU (Article 7). For coffee from an importer it records supplier, reference numbers and customers that are traders or downstream operators, from 30 December 2026.

Does chocolate need due diligence for the palm oil it contains?

No. For chocolate of heading 1806 due diligence extends only to the cocoa.

Is soluble coffee covered?

From 30 December 2027: extracts, essences and concentrates of coffee of subheading 2101 11 (CN code 2101 11 00). Preparations based on them and coffee beverages are not covered.

Do I need polygons for every coffee plot?

No. Under four hectares a point is enough; above that a polygon is mandatory.

Do I need farmers' names and IDs?

No. Personal data are only needed for direct suppliers; for farmers the geolocation of the plot is enough.

Is mass balance allowed?

No. Goods of known origin may not be mixed with goods of unknown origin or with non-compliant goods. Blending within mapped plots is allowed if all are in the statement and all are deforestation-free and legal.

Which coffee and cocoa countries are low risk?

Among others Vietnam, India, Ghana, Costa Rica, Kenya, Rwanda, Papua New Guinea and the Dominican Republic. Brazil, Colombia, Ethiopia, Honduras, Peru, Côte d'Ivoire and Ecuador are standard risk.

What applies to goods in a customs warehouse?

They are only placed on the market on release for free circulation. If released on or after 30 December 2026 (small importers: on or after 30 June 2027), they need a statement. Re-export from the customs warehouse is not covered.

Are coffee samples covered?

Not if they are tested and completely used up or destroyed in the process, for example cupping before an order (Annex I, note 5).

Is certification enough?

No. Certificates are an aid in the risk assessment; geolocation, statement and responsibility remain with the importer.

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Articles 1, 2, 3, 4, 5, 7, 9 to 13, 16, 26, 29 and 38, Annex I including note 5 as amended by Delegated Regulation (EU) 2026/2102. Implementing Regulation (EU) 2025/1093 (country benchmarking). Implementing Regulation (EU) 2024/3084 as amended by Implementing Regulation (EU) 2026/1565. Commission guidelines, OJ C/2026/3896. Commission FAQ on the EUDR, 5th edition, questions 1.3 to 1.11, 1.17, 1.18, 2.11, 2.14, 3.1.1, 3.6.1, 3.7, 3.8, 3.14, 4.14, 5.6.1, 5.7, 5.11 and section 9. Draft German EntwaldungsMG (cabinet 12 August 2026, Bundesrat printed paper 438/26). As at 18 September 2026. This article is not legal advice.

Photos: The Manh, Aleksandar Popovski, Diego Catto, all via Unsplash.