EUDR for coffee: scope, obligations, and how coffee plots are screened

Coffee is one of the seven commodities of Regulation (EU) 2023/1115 (Art. 2(1)). The duty attaches to the products listed in Annex I by HS code: green and roasted coffee under heading 0901 are in scope today, and soluble coffee is added from 30 December 2027 by the delegated act adopted in July 2026.

In scope: Annex I codes for coffee

Commission Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, adds one entry for this commodity, each binding from 30 December 2027.

What the regulation asks of a coffee importer

The obligations apply from 30 December 2026. An operator that is a micro or small undertaking, established as such by 31 December 2024, has until 30 June 2027, except for products that were already covered by the EU Timber Regulation. The amendment is Regulation (EU) 2025/2650.

For every consignment the operator must hold, and the statement must rest on:

• The geolocation of every plot of production, as a polygon where the plot is above four hectares, with the production period (Art. 9(1)(d)).
• Evidence that the products are deforestation-free against the 31 December 2020 cutoff (Art. 9(1)(g)) and were produced in accordance with the country's laws in the eight areas of Art. 2(40) (Art. 9(1)(h)).
• The product description with its HS code, the quantity, the country of production, and who supplied and who bought (Art. 9(1)(a) to (f)).
• A risk assessment on that information (Art. 10), and before placing, a due-diligence statement filed in the Information System, whose reference number goes into the customs declaration (Arts. 4, 26 and 33). Everything is kept for five years (Art. 12).

What is specific about coffee

Two things. The first is scale: a green-coffee contract from a cooperative can stand on hundreds or thousands of smallholder plots, each of which needs a geolocation and a screening. The second is the crop itself. Coffee grows under shade trees, so the plot carries tree cover, and the tree cover is the farm. The regulation's definition of forest excludes land under agricultural use, and agricultural plantations of commodities other than wood are outside it (Art. 2(4) and 2(6)); the Commission's FAQ lists coffee among them. Pruning shade trees or replanting old stock is not deforestation, but every global loss dataset reads it as a loss of tree cover.

The question for a coffee plot is therefore not whether tree cover changed after 2020. It is whether land that was forest on 31 December 2020 was converted to agricultural use. Those are different questions, and a check built for the first will flag established farms all season.

How Konstata screens coffee plots

Every plot is screened in more than one pass. The first runs the plot through WHISP, the open analysis developed under FAO's Open Foris, against the EU's own 2020 forest map, the global loss datasets and the alert layers, joined by national records where a country publishes them. Where that finds loss after the cutoff, a second pass locates it on the ground against the forest map, so a reading on land that was not forest in 2020 is not mistaken for the conversion of forest. Where the plot is still unclear, a third pass reads ten years of monthly satellite greenness for the pattern of an established crop. Each plot ends with a verdict and a written reason, never milder than WHISP's own headline, and a plot the data cannot settle is held for a person, with what to check written next to it.

For coffee the greenness pass matters: an established coffee canopy is evergreen and holds a high, stable reading across the cutoff, and a plot that shows that pattern is separated from one that was cleared. Where a supplier declared a whole property rather than the cultivated area, the screening can also split the plot into cells and locate the loss inside it, which is the case the Commission's FAQ 1.15 addresses. Konstata has run on live coffee supply since June 2026 and carries the deepest production history on this commodity.

Where to start

• Check your own product codes in the HS code lookup and the Annex I browser under /eudr/tools.
• Settle which date binds you with the company size test, and read the benchmark for each country of production in the country risk tool.
• Open a free Konstata workspace with room for three plots, import them, and read the screening on your own data. No card and no sales call.