EUDR and Coffee: Covered Products, HS Codes, Supply-Chain Risks and Due Diligence

Yes: coffee is a relevant commodity of the EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115), and heading 0901 is covered from 30 December 2026, soluble coffee (CN 2101 11 00) from 30 December 2027.

The EU Deforestation Regulation makes the operator that first places coffee on the EU market, or exports it, prove the coffee is deforestation-free, legal and covered by a due diligence statement. The coffee rules cover two CN entries, four roles from importer to café, origin risk classes, due diligence and a preparedness exercise run with two national authorities.

The coffee rules in force on 24 October 2026 are summarised below.

Which Coffee Products Does the EUDR Cover?

Annex I lists coffee in 2 of its 89 entries: heading 0901 and CN 2101 11 00. Heading 0901 has stood unchanged since entry into force on 29 June 2023; soluble coffee joined through Delegated Regulation (EU) 2026/2102.

Heading 0901 in Annex I: Green, Roasted and Decaffeinated Coffee, Husks, Skins and Substitutes

Annex I covers heading 0901 as "Coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee in any proportion", with no "ex" prefix, so every subheading is in scope. The 2026 Combined Nomenclature (Implementing Regulation (EU) 2025/1926) splits it into 6 subheadings. Green coffee (0901 11 00) dominates: EUR 16,904.3 million of the heading's EUR 18,731.5 million in 2025. No volume threshold applies (FAQ 2.3). The codes of the other six commodities are in EUDR Annex I.

The seven coffee lines are compared below.

Heading 0901 applies from 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024 (Art. 38(3)). Figures are EU imports under the heading (Eurostat Comext), not scope.

Is Soluble Coffee Covered by the EUDR?

Yes, from 30 December 2027: Commission Delegated Regulation (EU) 2026/2102 added CN 2101 11 00 to Annex I with effect from 18 September 2026. The delegated act (adopted 13 July 2026, OJ L, 2026/2102, 17 September 2026) sets one date for every operator. Instant mixes (2101 12) stay outside. Of 2025 soluble imports, about 72.7 % by volume came from low-risk partners (approximation: trade data record the partner country, not the country of production).

Which Coffee Products Are Not Covered?

Four products fall outside: preparations under 2101 12, roasted chicory under 2101 30 11, coffee beverages under 2202 99 and used coffee grounds that are waste.

These EUDR exemptions are narrow: beyond them, the Annex I code and the production date decide scope. All carve-outs sit under EUDR exemptions.

EUDR Timeline for Coffee: When Do the Obligations Apply?

Heading 0901 applies from 30 December 2026, and from 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024 (Article 38(3)); 2101 11 00 applies from 30 December 2027. An undertaking is micro if it does not exceed at least two of three limits: balance sheet EUR 450,000, net turnover EUR 900,000, average employees 10; small uses EUR 5 million, EUR 10 million and 50 (Directive 2013/34/EU as amended by Delegated Directive (EU) 2023/2775, values on 31 December 2024).

The EUDR timeline for coffee has four dates.

Every other date sits on the EUDR timeline.

Is Coffee Harvested Before 29 June 2023 Covered?

No: coffee produced before 29 June 2023 is outside (Article 1(2)), and production means harvest (Guidance, section 3). This limit is not the cut-off of 31 December 2020. Heading 0901 coffee placed on the market before 30 December 2026 needs only proof of that placing (FAQ 9.1 to 9.2), as explained under EUDR transitional stock.

Who Carries Which EUDR Role and Obligation in the Coffee Supply Chain?

Only the operator that first places or exports coffee carries due diligence and files a DDS; roasters, retailers and cafés are downstream operators or traders. Regulation (EU) 2025/2650 set this split on 26 December 2025.

The four coffee actors compare as follows.

The same tests define the EUDR roles for every commodity.

Green Coffee Importers: Operators

The EU company releasing 0901 11 00 for free circulation is the operator: it applies Articles 8 to 12 and files the DDS. Customs warehousing and inward processing are not placing on the market (FAQ 5.5). EU exporters are operators too; extra-EU exports under 0901 reached EUR 3,593.6 million in 2025. The duties of EUDR operators bind SMEs as well.

Are Coffee Roasters Downstream Operators?

Yes: roasting 0901 11 00 already placed on the market into 0901 21 00 makes a company a downstream operator (Article 2(15b); FAQ 3.1.1). Since 26 December 2025 it files no DDS; under Article 5 it keeps supplier and customer information for 5 years. FAQ Version 5 (April 2026) is the Commission's non-binding view (Article 15(5)). Reselling beans unchanged makes the roaster a trader; importing green coffee makes it the operator, as explained for downstream operators under the EUDR.

Retailers, Cafés and Other Traders

A supermarket, coffee shop or wholesaler selling coffee already placed is a trader (Article 2(17)) and files no DDS. Under Article 5, a non-SME trader registers and acts only on substantiated concerns, as set out for EUDR traders.

Coffee Producers in Low-Risk Countries: The Simplified Declaration

A coffee farmer that is a natural person or micro or small undertaking established in a low-risk country and places its own coffee submits a one-time simplified declaration (Article 4a, Annex III). Producers in Vietnam, India and Kenya (low risk) can meet this test; those in Brazil, Colombia and Ethiopia (standard risk) cannot. The identifier has 14 characters starting with S, and a postal address may replace geolocation (Article 4a(5)). This is not Article 13 simplified due diligence; see EUDR micro or small primary operators.

How Does EUDR Country Benchmarking Apply to Coffee Origins?

Most EU coffee imports come from standard-risk countries under Implementing Regulation (EU) 2025/1093, which lists 140 low-risk and 4 high-risk countries; every other country is standard risk. The class rates Article 3(a) deforestation risk only. About 71.3 % of 2025 green coffee volume came from standard-risk partner countries, an approximation.

Coffee origins and their consequences are listed below.

The four high-risk countries (Belarus, North Korea, Myanmar, Russia) carry checks on at least 9 % of actors and 9 % of quantity (Art. 16(9)). All 194 classifications are listed under EUDR country benchmarking.

Country of Production, Not Customs Origin: Roasted Coffee From Switzerland or the UK

The class follows where coffee was grown (Article 2(24)), not customs origin (Article 2(23)): Swiss roasted coffee from standard-risk beans needs full due diligence. Article 13 requires every input to be low risk, so roasting in Switzerland or the UK changes nothing. Roasted coffee imports under 0901 21 00 reached EUR 1,573.9 million in 2025.

Does Low Risk Exempt Coffee From Due Diligence?

No: low-risk coffee still needs Article 9 information including geolocation, a DDS and a due diligence system (Article 12); Article 13 removes only Articles 10 and 11 (FAQ 1.28), when every input is low risk and circumvention or mixing risk is negligible. New risk information restores them (Article 13(2)); see simplified due diligence under the EUDR.

What Does EUDR Due Diligence Require for Coffee?

Coffee due diligence has 3 steps: information (Article 9), risk assessment against 14 criteria (Article 10(2)) and risk mitigation (Article 11), under Article 8(2). The system and its annual review are covered under EUDR due diligence.

Geolocation of Coffee Plots

Every coffee plot needs at least six decimal digits: a point up to 4 hectares (about 9.88 acres), a polygon above (Article 2(28)). About 90 % of coffee comes from smallholders with plots under 4 hectares (EFI report, January 2026). Polygon files fail on self-intersections and spikes. Formats are explained under EUDR geolocation; files can be tested with the EUDR GeoJSON checker.

Shade Trees, Agroforestry and Forest Coffee: What Counts as Deforestation-Free?

Coffee on land predominantly under agroforestry systems is agricultural use, not forest (Article 2(6); Guidance, section 11.4(d)); the test is the land on 31 December 2020. Forest means more than 0.5 hectares, trees above 5 metres and canopy cover above 10 % (Article 2(4)). Three land situations decide the outcome.

• Agroforestry coffee: shade coffee on land that was agricultural plantation on 31 December 2020 involves no deforestation.
• Forest coffee: small-scale coffee production in forests without detrimental effect on the habitat does not make agricultural use predominant (Guidance, section 11.4(b)).
• Conversion after the cut-off: forest cleared for coffee after 31 December 2020 is deforestation.

The forest test is explained under deforestation-free under the EUDR.

Legality in the Coffee-Producing Country

Coffee must comply with the relevant legislation of the country of production, 8 headings in Article 2(40), from land use rights and labour rights to free, prior and informed consent and tax and customs rules. The risk class is silent on legality, which the EUDR legality requirement sets out. The EFI report cites LandMark data recognising 41 % of Uganda's territory as Indigenous Peoples' land.

Segregation, Blending and Why Mass Balance Is Not Compliant

Coffee lots stay segregated from coffee of unknown origin because mass balance is not compliant; full identity preservation is not required (FAQ 1.4). Three blending situations follow.

• Blends: multi-country lots declare every plot in every country (FAQ 1.24).
• Tainted batches: one non-compliant lot in an unseparated batch taints the whole batch (FAQ 1.5).
• Silos: under first in, first out, the declaration covers all inflows since the silo was empty, or at least 200 % of capacity (FAQ 1.17).

These rules continue under EUDR traceability.

The Due Diligence Statement for Coffee

The operator files one due diligence statement in the EUDR Information System before placing or export and quotes its reference number at customs (Article 26(4)). Filing is free (Implementing Regulation (EU) 2024/3084, Article 18(1)). The EUDR due diligence statement holds Annex II points 1, 2, 3, 5 and 6; point 4 was deleted by Regulation (EU) 2025/2650. Amendment or withdrawal is possible within 72 hours after the reference number is available (Article 5(1) of the implementing regulation), and records are kept 5 years (Article 4(3)). Release checks are explained under EUDR at customs.

What Did the EUDR Coffee Preparedness Exercise Show?

In an exercise reported by the European Forest Institute (EFI) in January 2026 and cited in COM(2026) 191, footnote 20, the Belgian and French competent authorities tested 4 shipments from Uganda, Vietnam, Brazil and Honduras. The EFI report gives one finding per origin.

• Honduras: 10 of 15 plots were missing from the national coffee map; non-spatial evidence was requested.
• Vietnam: one plot lay within the 15 to 30 metre riverbank distance.
• Uganda: LandMark data recognise 41 % of the territory as Indigenous Peoples' land.
• Brazil: yields were not low, unlike elsewhere; low yields alone raised no concern.

Its lesson on secondary statements is outdated: Regulation (EU) 2025/2650 abolished them.

Can Certification Prove EUDR Compliance for Coffee?

No: a coffee certificate is complementary information under Article 10(2)(n); it never replaces due diligence and the operator stays liable. Mass-balance certified coffee is not compliant. No "EUDR certificate" and no EU list of approved schemes exist as of 24 October 2026. What schemes prove is set out under certification and the EUDR.

Find Independent Providers and Suppliers for Coffee Under the EUDR

Coffee importers, roasters and non-EU exporters can describe what they need: mapping, risk assessment, audits, software or coffee with EUDR information.

Facts are checked against EUR-Lex and the Commission sources named; see our methodology and fact-checking.

This guide explains the rules; it is not legal advice for an individual case.

How Does Coffee Connect to the Other EUDR Commodities, Checks and Dates?

Coffee is one of 7 relevant commodities; it shares crop rules with cocoa, while oil palm and wood add processed lines and wood the degradation test. The EUDR commodities hub compares all seven. Cattle, rubber and soya share the plot logic of EUDR and soya.

Cocoa follows the same agroforestry rules (EUDR and cocoa). Oil palm gained 16 lines from 30 December 2027 (EUDR and oil palm).

Wood alone faces the forest degradation test of Article 2(13)(b) (EUDR and wood).

Why Is Coffee One of the Seven Relevant Commodities?

Coffee is covered because the research behind recital 38 attributed 7.0 % of EU-driven deforestation to it, a historical figure. The review COM(2026) 191 proposed no change. "Deforestation-free" marketing claims fall under EU green-claims rules (greenwashingdirective.com).

Checks and Penalties for Coffee Operators

Authorities check at least 1 %, 3 % and 9 % of operators, non-SME downstream operators and non-SME traders yearly by origin class (Article 16(8) to (10)). Selection rules sit under EUDR checks. For legal persons, the maximum fine must be at least 4 % of total annual Union-wide turnover (Article 25(2)(a)), detailed under EUDR penalties.

Is the EUDR Postponed or Simplified Again?

No further postponement is proposed as of 24 October 2026: 30 December 2026 stands. COM(2026) 191 of 4 May 2026 made no proposal (EUDR simplification). Earlier steps sit under EUDR postponement.