The definitive EUDR guide for coffee importers

Regulation (EU) 2023/1115, known as the EUDR (EU Deforestation Regulation), changes the rules for any company placing coffee on the European Union market. This guide explains, without unnecessary jargon, what you must do if you import or roast coffee in Spain or Portugal: from farm geolocation to submitting the dossier in TRACES.

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1. What the EUDR is and who it applies to

The EUDR bans EU trade in products linked to deforestation or forest degradation after 31 December 2020. It covers seven commodities: coffee, cocoa, timber, rubber, soy, palm oil and cattle, plus their derivatives.

If you are an operator (placing the product on the EU market) or a trader (selling it within the EU), the regulation applies to you. For most small coffee roasters and importers, the relevant role is operator.

Important: the EUDR is not a certificate you buy. It is a due diligence dossier proving your coffee is deforestation-free and legally produced.

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2. Why coffee is the most exposed commodity

Coffee is almost always produced outside the EU (Colombia, Brazil, Ethiopia, Vietnam, Central America…) on small farms scattered across forested regions. That makes plot geolocation the central challenge: thousands of producers, each with their farm, all needing valid coordinates.

Unlike soy or palm oil, where a few large players control the chain, coffee flows through cooperatives, traders and exporters. Traceability down to the specific plot is hard but mandatory.

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3. Plot geolocation: point or polygon

The EUDR requires the geographic coordinates of every plot where the coffee was produced:

• Plots over 4 hectares: require a GeoJSON polygon.
• Plots of 4 ha or less: allow point or polygon.
• Coordinates must have 6 decimal places of precision (≈ 11 cm).

This means you need a way to capture each farm's geometry. The most efficient option for an SME is a mobile supplier portal: the farmer opens a link on their phone, draws the polygon or drops a pin, and the platform validates the area and format automatically.

Practical rules

| Farm size | Geometry | Precision | |---|---|---| | > 4 ha | Polygon required | 6 decimals | | ≤ 4 ha | Point or polygon | 6 decimals |

A valid polygon is a closed ring of at least 4 points (the last equal to the first). Coordinates go in [longitude, latitude] order, not the reverse.

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4. The deforestation-free statement

Each lot must come with a statement that production did not cause deforestation or degradation after 31 December 2020. The cut-off date is fixed and does not move back.

Satellite screening compares your plot geometry against forest-cover layers and flags alerts. But remember: screening is decision support, not automatic legal conformity. Final responsibility sits with the operator.

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5. Due diligence: what the DDS dossier contains

The due diligence dossier (DDS) must include:

1. Operator: name, country, EORI/VAT, type (operator/trader).
2. Product: green coffee, HS 0901.21, quantity, country of production.
3. Geolocation: coordinates of every plot.
4. Deforestation-free statement (cut-off 31 Dec 2020).
5. Legality statement for production in the country of origin.
6. Risk assessment and, where applicable, mitigation measures.

Without these six blocks, the dossier is incomplete and you should not submit it to TRACES.

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6. Risk assessment (Art. 9-11)

The regulation distinguishes three country-risk levels: low, standard and high. The risk assessment considers:

• Country risk (official Commission lists).
• Supply chain complexity.
• Mixed lots.
• Documentary gaps.

The result is a Low / Standard / High classification. Where there is risk, you must apply mitigation measures before the dossier can be marked ready. Measures are documented and retained.

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7. Satellite screening: what it is and what it is not

Automated satellite screening takes your polygon, crosses it with forest layers and returns a result: screening passed, ready for review or alert signal.

• ✅ It is decision support: helps you prioritise which plots to review.
• ❌ It is not automatic legal conformity. No imagery provider can certify for you.

A good platform shows the result, the layers used and a confidence level, and lets you decide. EUDR-Comply always labels screening as decision support.

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8. The DDS dossier and the TRACES-ready pack

Once you have geolocation, statements, screening and risk assessment, you generate the pack:

• Bilingual PDF of the dossier.
• Structured JSON aligned with Annex II.
• GeoJSON of the plots.
• CSV of the lots.

The pack goes to the EU EUDR Information System (TRACES). Official submission is done by the operator; the platform leaves it ready to paste and send.

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9. Evidence retention: 5 years

You must keep all compliance documentation for at least five years and make it available for audit. This includes coordinates, statements, screening, risk assessment and supplier communications.

A system with immutable traceability and an audit log saves you hunting for emails and PDFs five years later.

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10. Timeline and deadlines

The EUDR (Reg. EU 2023/1115, amended by Reg. EU 2025/2650) applies in phases by operator size: from 30 December 2026 for large and medium enterprises, and from 30 June 2027 for micro and small enterprises (and natural-person operators). Always verify the current version on the Commission's official portal, but in general:

• Large and medium enterprises: 30 December 2026.
• Micro and small enterprises (and natural persons): 30 June 2027.

Do not wait until the last day: setting up supplier geolocation takes weeks.

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11. How to comply without friction: step-by-step checklist

1. Set up your company (name, country, EORI, operator type).
2. Register suppliers and their country of origin.
3. Invite each supplier with a magic link to capture their plot on mobile.
4. Validate the geometry (area, format, 6 decimals).
5. Run satellite screening and review alerts.
6. Complete the risk assessment and apply mitigations.
7. Generate the DDS dossier and the TRACES pack.
8. Submit to TRACES and store the EU reference number.
9. Keep everything for 5 years.

With EUDR-Comply you can do steps 1 to 7 the same day.

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12. Common mistakes to avoid

• Coordinates with fewer than 6 decimals → automatic rejection.
• Point instead of polygon on farms over 4 ha → invalid dossier.
• Confusing satellite screening with conformity → legal risk.
• Not retaining evidence → penalty on audit.
• Waiting until the last day → suppliers do not respond under pressure.

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Conclusion

The EUDR is not optional, but it does not have to be hell. With a mobile portal for your suppliers, clear satellite screening and a structured dossier, a coffee SME can comply in days, not months. The key is to start ahead of the competition and get geolocation captured.

Ready to generate your first TRACES-ready dossier? Create your free EUDR-Comply account and invite your first supplier today.