Traceability rules

The EU Deforestation Regulation and Coffee

From December 30, 2026, most coffee placed on the EU market must come with a due diligence statement and the geolocation of every plot where it was grown. Small operators follow in June 2027.

Updated October 15, 2026 · 7 sources · 5 min read

The European Union's Deforestation Regulation, usually shortened to EUDR, is the most demanding origin-traceability rule coffee has ever faced. It does not care about flavour or reputation. It asks something more basic: can the seller prove, plot by plot, where the coffee was grown and that the land was not deforested after 2020? This page summarises what the regulation requires for coffee, when it applies, and what it means for small origins such as Jamaica Blue Mountain.

One-pound bag of 100% Jamaica Blue Mountain whole bean coffee marked Product of Jamaica
Under the EUDR, "Product of Jamaica" is not enough: the importer needs the plots where the coffee was grown. Photo: Mamre Blue Coffee.

What is the EUDR?

Regulation (EU) 2023/1115 covers cattle, wood, cocoa, soy, palm oil, coffee and rubber, and some products made from them. For coffee, Annex I links the rule to tariff heading 0901: coffee, whether or not roasted or decaffeinated, coffee husks and skins, and coffee substitutes containing coffee. Products in scope may be placed on the EU market or exported from it only if they are deforestation-free, produced in line with the laws of the country of production, and covered by a due diligence statement.

The regulation defines deforestation-free as produced on land that has not been subject to deforestation after December 31, 2020. Deforestation means converting forest to agricultural use, whether caused by people or not.

The geolocation requirement

The core of the rule for coffee is Article 9. Operators must collect the geolocation of all plots of land where the coffee was produced, along with the date or time range of production. If a lot mixes coffee from many farms, every plot must be included. Article 2 sets the format: latitude and longitude with at least six decimal digits, and, for plots of more than four hectares, a polygon tracing the plot boundary rather than a single point. Any deforestation on those plots disqualifies the coffee.

That is a big change for an industry where coffee has often been bulked from thousands of smallholders through collectors and mills. It pushes traceability back to the farm, which is exactly the level at which origin claims such as a protected origin name are made.

When does it apply?

  • Large and medium operators: December 30, 2026.
  • Micro and small operators: June 30, 2027.
  • Soluble (instant) coffee: added to the scope by a later delegated regulation, applying from December 30, 2027, according to the European Commission.

The dates have moved twice. The regulation originally applied from the end of 2024; it was postponed by a year, and an amendment in December 2025 moved it again to the dates above. In its simplification review of May 4, 2026, the Commission concluded that the regulation would not be reopened and that the existing timelines still apply, Baker McKenzie reported. The Commission also planned to relaunch its information system, where due diligence statements are filed, in June 2026.

Country risk tiers

An implementing regulation adopted on May 22, 2025 sorts countries into low, standard and high risk. About 140 countries are classed as low risk, including all EU member states, the United States, Japan and China; around 50, including Brazil and Indonesia, are standard risk; and four, Belarus, Myanmar, North Korea and Russia, are high risk, according to a Linklaters summary. Coffee from low-risk countries qualifies for simplified due diligence, which drops the formal risk assessment but still requires the information, including geolocation, and a due diligence statement. National authorities must check at least 1% of operators sourcing from low-risk countries, 3% for standard risk and 9% for high risk. Buyers should check the annex of the implementing regulation for the tier of a specific origin.

Penalties

Member states set the penalties, but Article 25 requires that the maximum fine for a company be at least 4% of its total annual EU turnover, and higher where needed to remove the economic benefit of the breach. Non-compliant coffee can also be confiscated.

What it means for small origins like Jamaica

For a small, mountainous origin with many smallholders, the practical challenge is mapping. Jamaica already has an unusual head start in record-keeping: the 2018 JACRA regulations require a register of registered growers and properties, signed receipts naming the property where coffee was grown, and dealer records kept for seven years, as our JACRA certification page explains. Those records were designed to protect the Blue Mountain name, not to satisfy the EUDR, and they do not by themselves supply plot coordinates. Whether Jamaican exporters will map every plot will depend on how much coffee they sell into Europe; most Blue Mountain coffee goes to Japan, as described on our Blue Mountain and Japan page.

The rule also interacts with certification schemes. Fairtrade has told its coffee cooperatives they have until January 2027 to complete geolocation mapping, a scheme deadline rather than an EU legal date. Our guide to coffee certifications explains what those labels do and do not prove.

What it means for coffee drinkers

Most of the work falls on importers and the companies that first place coffee on the EU market, not on shoppers. The likely visible effects are more origin detail on packaging, fewer anonymous blends of untraceable coffee, and possibly higher costs for origins that struggle to map their farms. For buyers outside the EU, the EUDR matters because big roasters tend to apply one traceability system across all markets. Readers interested in how growing areas are defined in the first place can start with the coffee belt.

Disclosure: this site is published by Mamre Blue Coffee, a Jamaica Blue Mountain estate (see about us), so we rely on official and independent sources for the facts on this page.

Questions people ask

Does the EUDR apply to coffee?
Yes. Coffee under tariff heading 0901, roasted or not and decaffeinated or not, is one of the seven commodities covered by Regulation (EU) 2023/1115. Soluble coffee is due to be added from December 30, 2027.
When does the EUDR start for coffee?
December 30, 2026 for large and medium operators and June 30, 2027 for micro and small operators, after two postponements. The Commission said in May 2026 that it would not reopen the regulation.
What does geolocation mean under the EUDR?
Latitude and longitude with at least six decimal places for every plot where the coffee was grown, and a boundary polygon for plots larger than four hectares.
What is the EUDR cut-off date?
December 31, 2020. Coffee grown on land deforested after that date cannot be placed on the EU market.

Sources

  1. Regulation (EU) 2023/1115 on deforestation-free products (EUR-Lex)
  2. Regulation on Deforestation-free Products (European Commission)
  3. EU Commission Publishes Simplification Review of EUDR (Baker McKenzie, May 2026)
  4. EU Deforestation Regulation: Country Risk Classification Adopted by the Commission (Linklaters)
  5. European Parliament Votes to Delay EUDR (Daily Coffee News, Dec 1 2025)
  6. Fairtrade Extends Timeline for Cooperatives to Complete Geolocation Data Collection (Fairtrade International)
  7. The Jamaica Agricultural Commodities Regulatory Authority Regulations, 2018 (Jamaica Gazette Supplement, March 2 2018)

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