Coffee is one of the seven commodities covered by Regulation (EU) 2023/1115, the EU Deforestation Regulation. If your company imports green beans, roasts for the EU market, or exports roasted coffee out of the EU, you will file due diligence statements in TRACES from 30 December 2026, or 30 June 2027 if you are a micro or small enterprise. This guide covers what is specific to coffee: the scope boundary, the smallholder geolocation problem, and how a roaster actually gets to a filed DDS.
What coffee products are in scope
Annex I lists coffee under HS heading 0901: coffee, whether or not roasted or decaffeinated, plus coffee husks and skins and substitutes containing coffee. That means green beans, roasted whole bean, ground coffee and decaf are all covered, regardless of packaging format.
Two boundaries matter in practice. First, soluble coffee, extracts and essences under HS 2101 are not listed in Annex I, so instant coffee currently falls outside the regulation. Second, the rules attach to the product being placed on the EU market for the first time: a café buying roasted coffee from an EU roaster is not filing anything - the roaster or importer upstream already did.
Operator or downstream: which one are you
- You import green beans from origin. You are the operator placing the product on the market. Full due diligence and a DDS per consignment (or an annual statement covering recurring imports) is on you.
- You roast beans bought from an EU importer. The importer filed the DDS. As an SME downstream operator you do not file a new one - you keep the upstream DDS reference numbers and pass them on. Large downstream companies must additionally confirm that due diligence was actually carried out upstream.
- You export roasted coffee from the EU. Export is also covered: a DDS is required before the goods leave.
The real work: geolocation from smallholders
Roughly 60–70% of the world's coffee comes from smallholder farms, most of them under 4 hectares. That shapes the data problem in your favour on one axis and against you on another.
In your favour: plots of 4 ha or less can be declared with a single point - one latitude/longitude pair at six decimal places - rather than a polygon. Most coffee plots qualify. Against you: a single container of green coffee routinely aggregates hundreds of farms through a cooperative or mill, and you need the geolocation of every plot of land where the coffee was produced, with production dates. A washing-station name and a region is not geolocation.
The workable pattern for an SME importer: request plot lists per lot from the exporter or cooperative as a condition of contract, in GeoJSON or CSV with coordinates; validate the geometry the day you receive it, not the week you file; and screen it immediately so a flagged plot becomes the supplier's problem to fix while the coffee is still on the water - or better, before it ships. The exact coordinate rules, and the errors that get files rejected, are in our geolocation requirements guide; the field mechanics of getting coordinates out of hundreds of farms are in the smallholder collection playbook.
Deforestation risk in coffee origins
Coffee expansion is a documented deforestation driver in parts of East Africa and Southeast Asia, and screening treats the question empirically: is there evidence of forest loss after 31 December 2020 inside each declared plot? Convergence-of-evidence screening (the approach behind FAO's open WHISP methodology) compares each plot against tree-cover, land-use and alert datasets rather than trusting any single map - important for coffee, where agroforestry systems grown under shade canopy can look like forest to a single-layer classifier. A plot that flags is not automatically non-compliant, but you must resolve the evidence before filing.
Where your coffee comes from also sets your inspection odds. Most major coffee origins are classified standard risk under country benchmarking, which targets checks on 3% of operators; low-risk origins allow simplified due diligence but still require full geolocation. We cover the four biggest origins in detail: Brazil (CAR polygons, fazenda-scale farms), Colombia (half a million smallholders), Vietnam (low-risk tier, simplified track) and Ethiopia (forest coffee and thin traceability).
What a coffee DDS contains
Per consignment you declare: your company details, HS code and product description, net mass, country of production, the geolocation of all source plots with production date ranges, and your confirmation that due diligence found no or only negligible risk. TRACES returns a reference and verification number that go in the customs declaration. Every field is explained in the DDS field-by-field guide.
What belongs in the evidence file
The DDS is the visible artefact, but Article 9 obliges you to hold the information behind it for five years, retrievable on request. For a coffee importer that file should contain, per lot: the supplier and exporter identity with contact records, the plot list with coordinates and production dates in its original delivered form plus any corrected versions, the screening outputs with dataset names and run dates, the legality evidence for the origin country (export permits, land documentation where obtainable), the contract clause requiring plot data, and the DDS reference and verification numbers TRACES returned. Blends deserve a note of composition: a roast combining a Brazilian and an Ethiopian lot inherits both plot files, and your file should show which green lots entered which roasted products. None of this is sophisticated - it is discipline, and it is what an authority checks first.
A realistic timeline for a roaster
- Now: map your supply chain - which lots you import directly versus buy from EU importers. Only the first group needs your own DDS.
- 3–6 months before deadline: put plot-data clauses in purchase contracts; start collecting coordinates per lot; screen as data arrives.
- 1–2 months before: get EU Login and TRACES operator access sorted; run a full test filing.
- At the deadline: file per consignment, quote reference numbers at customs, and keep the evidence file for five years.
Cocoa importers face a nearly identical smallholder-aggregation problem - the cocoa guide covers the West African specifics - while timber and cattle operate under different geolocation logic entirely.