The European Commission confirmed in May 2026 that there will be no third postponement of the EU Deforestation Regulation (EUDR). From 30 December 2026, large and medium-sized companies may only place green coffee and cocoa on the EU market if a due diligence statement covers it. Micro and small operators follow on 30 June 2027. With less than three months to go, the question we hear most from roasters and traders is no longer what the regulation requires, but which of my lots it applies to.
The answer depends on one moment: when the goods are placed on the EU market. For imported coffee and cocoa, that is the date they are released for free circulation by EU customs. It is not the contract date, the shipment date or the date the beans were harvested.
Four situations, four answers
| Where the lot is on 30 December 2026 | Due diligence statement needed? |
|---|---|
| Already cleared for free circulation in the EU (for example duty-paid stock in Antwerp) | No. The lot was placed on the market before the application date and can be sold on afterwards. Keep the customs declaration: it is the evidence of when the goods entered the market. |
| Afloat, arriving and cleared after 30 December | Yes. The operator who clears the lot must file a statement first, even if the coffee was bought and shipped months earlier. |
| In a bonded or customs warehouse in the EU, not yet cleared | Yes, when it is released after 30 December. Goods under a customs procedure have not yet been placed on the market. |
| Outside the EU (for example Felixstowe in the UK, or a warehouse at origin) | Yes, if it enters the EU after 30 December. A lot moved from the UK to the EU is a new import into the EU. |
Two further points follow from the Commission's 2026 guidance. Once a lot has been placed on the EU market with a statement, companies further down the chain do not repeat the due diligence: they keep the reference number and pass it on. And goods that were already placed on the EU market and are re-imported are treated as a downstream activity, without a new statement.
Why lots shipping in November matter most
Coffee or cocoa leaving Dar es Salaam or Mombasa in November will usually reach Antwerp in late December or January. Add the risk of congestion in European and West African ports as shippers try to land stock before the deadline, and many lots bought today as "pre-EUDR" will in practice be cleared under the new rules. If the plot data and legality documents are not ready when the container arrives, the lot cannot be released.
Bonded stock: clear early or prepare the file
For coffee and cocoa sitting in a customs warehouse in Antwerp or elsewhere in the EU, buyers and importers have two options. Release the goods for free circulation before 30 December, which brings import formalities and VAT forward but takes the lot outside the EUDR. Or keep the goods under bond and make sure the full due diligence file is ready for release in 2027. Which option makes sense depends on how quickly the stock will be used.
Questions to ask about every open contract
- What is the shipment period, and what is the realistic arrival and clearance date?
- Who is the operator placing the lot on the EU market, and who files the statement?
- Will the due diligence reference number and the geolocation data be available before the vessel arrives?
- Does the contract say who bears the cost if documents are missing and the container is held?
- For stock already in Europe: is it in free circulation or still under bond?
How we handle it at MD Trade
Our coffee and cocoa moves through our own network: collection in Beni (North Kivu), warehouses in Kampala and Dar es Salaam, and stock in Antwerp and Felixstowe. For every lot we can tell you where it is, whether it is already in free circulation in the EU, and what EUDR documentation travels with it. Where we place a lot on the EU market, we file the due diligence statement and give you the reference number with the shipping documents. For the documents themselves and a buyer checklist, see our article EUDR in practice.
This article is a practical summary, not legal advice. Check the latest European Commission guidance and talk to your customs broker about your own situation. To review your open positions with us before the deadline, contact our trading desk.