After two postponements, the EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) now has a fixed start. From 30 December 2026, large and medium-sized companies may only place coffee and cocoa on the EU market, or export them, if the product is deforestation-free, legally produced and covered by a due diligence statement. Micro and small enterprises follow on 30 June 2027.
For green coffee and cocoa buyers this is no longer a policy debate. It is a document question that will decide whether a container can be cleared in January.
What the regulation asks for
- Deforestation-free: the coffee or cocoa was grown on land that was not deforested after 31 December 2020.
- Legally produced: production respected the laws of the country of origin, including land rights, labour and tax rules.
- Geolocation: the coordinates of every plot where the product was grown. Plots above 4 hectares need a polygon, smaller plots a single GPS point.
- A due diligence statement, filed in the EU information system before the goods are placed on the market, with a reference number that travels with the lot.
Who does what in the supply chain
The company that first places the coffee or cocoa on the EU market carries the main obligation: collect the information, assess and reduce the risk, and file the due diligence statement. The simplification adopted in December 2025 and reviewed in 2026 lightened the load further down the chain and for micro and small operators, but it did not remove the need for plot-level data at origin. Without that data, nobody downstream can complete their own checks.
In practice, roasters and processors will ask their importer for the due diligence reference number and supporting origin data for every lot. Importers will ask the same of their suppliers. The weakest link is almost always the first mile, at farm and cooperative level.
Why the first mile matters in East and Central Africa
Much of the coffee and cocoa in Kivu, Uganda and Burundi comes from smallholders farming one or two hectares, often selling through collectors and cooperatives. Mapping those plots, keeping lots separate and linking each bag back to its farms is work that has to be done on the ground, season after season. A spreadsheet in Europe cannot replace it.
Ports are already feeling the deadline. Exporters in West Africa expect congestion in November and December as shippers try to land non-compliant stock before 30 December, and Vietnamese exporters report premiums of around USD 50 per tonne for EUDR-ready coffee. Compliant lots are becoming a quality attribute in their own right.
What MD Trade provides with each lot
- Origin and geolocation data for the farms and cooperatives behind the lot, collected by our own team in Beni and partners in the region.
- Lot separation from collection to export, so the data matches the bags you receive.
- The due diligence statement reference number where we are the operator placing the lot on the EU market.
- Clear documents per container: contract, packing list, quality certificate and EUDR file.
A short checklist for buyers
- Ask every supplier now how they will deliver geolocation and the due diligence reference for lots arriving after 30 December 2026.
- Check which of your current contracts ship late in the year and who bears the risk if documents are missing.
- Register in the EU information system early if you will be filing statements yourself.
- Keep records for five years, as the regulation requires.
This article is a practical summary, not legal advice. Always check the latest European Commission guidance for your own situation. If you want to see how our lots are documented, request access to the MD Trade Market or contact our trading desk.