• Regulation (EU) 2023/1115
• adopted on May 31, 2023, bans the placing on the European market of coffee, cocoa, palm oil, soy, wood
• rubber and cattle from land deforested after December 31, 2020 and requires due diligence with geolocation of plots. Its application
• December 30, 2024scheduled
• was postponed a first time to December 30, 2025, then
• December 18, 2025by the targeted revision signed by the Council
• to December 30, 2026 for large and medium-sized enterprises and to June 30, 2027 for micro and small ones. The Commission published on May 4, 2026 the simplification report it was due to deliver before April 30 (COM(2026) 191): estimated 75% reduction in annual compliance costs, a lighter obligation for downstream operators who can rely on their suppliers' reference numbers
• December 2026country directories of applicable legislation and certifications promised for
• June 2026relaunch of the information system
• and adoption of Delegated Regulation (EU) 2026/2102 of July 13, 2026, published in the Official Journal on September 17, 2026, which adds coffee extracts, essences and concentrates to the scope from December 30, 2027. The ranking of countries by risk level was not revised in 2026. As of the date of this plate
• no source later than May 2026 announces a new postponement: the date of December 30, 2026 is the one that applies.

Council of the EU, press releases of December 4 and 18, 2025, consilium.europa.eu; European Commission, COM(2026) 191 final, May 4, 2026; Baker McKenzie, May 2026; Access2Markets, trade.ec.europa.eu

For coffee, the whole difficulty comes down to one verb: geolocate. The regulation wants the coordinates of the plot that produced the lot. Yet the coffee of Ethiopia, Uganda or Honduras grows on millions of plots of less than one hectare.

These plots are gathered by cooperatives that have neither a cadastre, that is, any official register of property boundaries, nor the connectivity to record and transmit a point. So a map that exists nowhere has to be made, farm by farm.

Everyone reads the text from where they stand. Producing countries see in it a trade barrier disguised as an environmental measure. NGOs count one more step backward with each postponement. Traders see in it a fixed cost.

And a fixed cost does not weigh the same everywhere. Set against the volume of a large plantation already mapped, it is diluted until it disappears. Set against the few bags of one family, it becomes a barrier to entry. It is the mechanism by which the most demanding certifications exclude the smallest producers, played out once more.

One irony remains. The deforestation that the regulation wants to stop is also the one that climate models identify as the leading cause of loss of suitability in Ethiopia. The text therefore attacks what threatens Ethiopian coffee, at the price of a mapping effort that Ethiopian coffee growers are the least well equipped to supply.

Moat et al. 2017; Sprudge, “EU deforestation law headed for another delay”, 2025; LC ch. 16 (fixed cost of certifications)