THE PROCESS IN MOTION

What must a bag of green coffee prove to enter the Union after December 30, 2026?

Start the scene or choose a stage. The animation simplifies the mechanism; what follows gives the details and the available references.

▶ Play the process01The hill02The plot in 202003The declaration04The chain copies05Instant coffee

The hill

A hill of coffee trees seen from above. A polygon is drawn point by point around a plot of more than 4 hectares; the neighboring plot, smaller, needs only a point, latitude and longitude to at least six decimals. This is the geolocation the regulation requires for each plot.

Read the stages without animation

1. The hillA hill of coffee trees seen from above. A polygon is drawn point by point around a plot of more than 4 hectares; the neighboring plot, smaller, needs only a point, latitude and longitude to at least six decimals. This is the geolocation the regulation requires for each plot.
2. The plot in 2020The state of the plot on December 31, 2020 is superimposed: the forest has not moved. Shade coffee trees under tall trees remain “zero deforestation” coffee: according to the Commission’s guidance, a small production under forest cover is not an agricultural use and does not make a forest agricultural land.
3. The declarationThe bag passes the Union door. The importer who places it on the market for the first time is the operator: it files its due diligence statement in the information system, before placing on the market, keeps a register for five years and passes the reference number on to its customers.
4. The chain copiesThe bag goes down the chain. The roaster, a downstream operator, copies the reference number into its register, with the name of its supplier and its professional customers; the grocery, a trader, notes only the name of the roaster. Since December 2025, only the operator exercises due diligence: the others only keep records.
5. Instant coffeeIn front of the door, a jar of instant coffee waits: coffee extracts enter the regulation only on December 30, 2027. A small sample bag passes without a number: samples of negligible value and quantity intended to obtain orders are excluded.

To remember: A roaster that buys its green coffee from a Union importer is a downstream operator: it keeps for five years its suppliers, the reference numbers and its professional customers, nothing more.

In history: In history: the regulation of May 31, 2023 was postponed twice, to December 30, 2025 and then to December 30, 2026.

Read the full article and its sources ↓

State of the law as of October 21, 2026. 7 deadlines fall after this date; they are listed at the end of the section.

What the regulation asks, in one sentence

Regulation (EU) 2023/1115 of May 31, 2023, which the press calls by its acronym EUDR (EU Deforestation Regulation), is read here in its version consolidated as of September 18, 2026, which incorporates Regulations (EU) 2024/3234 and 2025/2650 and Delegated Regulation (EU) 2026/2102 (source 1). Its Article 3 comes down to three conditions: a coffee may be placed on the Union market, made available or exported only if it is “deforestation-free,” if it was produced in accordance with the law of the country of production, and if it is covered by a due diligence statement or a simplified declaration. “Deforestation-free” means produced on a plot that was not deforested after December 31, 2020; a forest, within the meaning of the text, is an area of more than 0.5 hectare with trees higher than 5 meters and a canopy cover of more than 10% (Article 2).

The coffee covered is broad: the whole of heading 0901 of the customs nomenclature, that is, green, roasted or decaffeinated coffee, husks and skins, and substitutes that contain coffee in any proportion whatsoever (Annex I). Instant coffee was not included. Delegated Regulation (EU) 2026/2102 of July 13, 2026, published on September 17, 2026, adds coffee extracts, essences and concentrates (subheading 2101 11 00) from December 30, 2027, because their exclusion “weakened” the system (source 4, recital on instant coffee). The same act excludes samples of negligible value and quantity intended to solicit orders, and products destroyed during an analysis (Annex I, note 5).

The Commission’s guidance document of July 20, 2026 provides a useful clarification for shade-grown coffee: small-scale coffee production under forest cover is not a main “agricultural use,” and therefore does not make a forest into agricultural land, as long as it does not degrade the forest habitat (source 7). A coffee grown under the trees of an existing forest is not, by itself, deforestation.

Dates that have moved twice

These dates come from Article 38 in each of its versions (sources 1, 2 and 3). The last revision provided for a simplification review by April 30, 2026 at the latest. The Commission’s report, sent to the Council on May 4, 2026 (COM(2026) 191), puts the expected reduction in annual compliance costs at “about 75%” compared with the initial costs, and concludes that there is no reason to propose a further amendment to the basic text, in the name of legal certainty (source 6). As of October 21, 2026, no proposal for a new postponement has been found; the only pending proposal that touches the regulation aims to remove French Guiana from its territorial scope (source 9).

Operator or downstream operator: the word that decides everything

The regulation distinguishes three roles, and the obligation changes completely from one to another. The operator is whoever places the coffee on the Union market for the first time or exports it. The downstream operator places on the market a product made from products already covered by a statement. The trader resells without processing (Article 2). Since the December 2025 revision, only the operator exercises due diligence.

Geolocation, within the meaning of the text, is a point of latitude and longitude to at least six decimal places; for a plot of more than 4 hectares, a polygon that describes its perimeter (Article 2). An SME, a small or medium-sized enterprise, is understood within the meaning of Accounting Directive 2013/34/EU. The Commission’s report confirms that the role of the downstream operator is limited to “passive collection and retention” of information (source 6). All actors keep an active obligation: to warn the competent authority and their own customers without delay if they learn that a product they sold may not be compliant (Articles 4, paragraph 5, and 5, paragraph 5).

The case of the roaster who imports a microlot itself deserves to be stated clearly: by clearing this coffee through customs, it becomes an operator, with geolocation of the plots and the due diligence statement; if it is a micro or small enterprise established on December 31, 2024, the obligation begins on June 30, 2027. Penalties are set by each State; for a legal person, the maximum amount of the fine must reach at least 4% of annual turnover in the Union (Article 25).

Risk by country of origin

Article 29 classes countries in three risk levels, which modulates the intensity of controls and opens the simplified regime to small producers in low-risk countries. Implementing Regulation (EU) 2025/1093 of May 22, 2025 places four countries at high risk (Belarus, North Korea, Myanmar, Russia) and 139 at low risk; all the others remain at the standard level (source 5). Among coffee producers, Burundi, China, Costa Rica, Cuba, India, Jamaica, Kenya, Nepal, Papua New Guinea, the Philippines, the Dominican Republic, Rwanda, Sri Lanka, Thailand, Timor-Leste, Togo, Vietnam and Yemen are classed at low risk; Brazil, Colombia, Ethiopia, Honduras, Peru, Uganda, Indonesia or Guatemala are at the standard level. No revision of this list was found in 2026.

The sustainability report and due diligence: two texts for the very large

Directive (EU) 2022/2464, known as the CSRD (Corporate Sustainability Reporting Directive), was tightened twice, by Directive 2025/794 of April 14, 2025, which postponed the schedule, then by Directive (EU) 2026/470 of February 24, 2026 (sources 8 and 10). For financial years beginning on or after January 1, 2027, it now targets only companies and groups that exceed both 1,000 employees on average and 450 million euros of net turnover (Article 5, paragraph 2, version consolidated as of March 18, 2026). No independent roastery comes near these thresholds; a few coffee groups exceed them.

The trickle-down to small firms, which the plan for this plate feared, has received a written answer. Directive 2026/470 creates a “value chain cap”: a company of at most 1,000 employees, called protected, has the right to refuse to supply a customer subject to the report with information that goes beyond the voluntary standard provided for by the directive; the customer must point out to it what goes beyond and remind it of this right, and a contrary contractual clause does not bind it (Article 1, point 4, which amends Article 19a of the Accounting Directive) (source 10). States must transpose these rules by March 19, 2027 at the latest. The cap covers only the sustainability report: it limits neither the requests linked to the EUDR nor those of a commercial specification.

Directive (EU) 2024/1760, known as the CSDDD (Corporate Sustainability Due Diligence Directive), amended by the same Directive 2026/470, now targets only companies of more than 5,000 employees with more than 1.5 billion euros of net worldwide turnover (Article 2). It will be transposed by July 26, 2028 at the latest and applied from July 26, 2029 (Article 37) (source 11). It also protects suppliers: a company may ask a direct partner of fewer than 5,000 employees for information only if it cannot reasonably be obtained otherwise (Article 8, paragraph 2a). In France, the duty of vigilance under Law No. 2017-399 of March 27, 2017 already exists for the very large companies; its thresholds were not reread in this pass.

The above is the user guide. The cost of compliance for origin is in the page on climate, the EUDR and the cost of compliance, in the economics plate; the EUDR as what is coming, in the page on the European deforestation regulation, in the plate on the future; traceability as a tool against fraud, in the “Today” page of the adulteration plate.

The sources for this section

1. Regulation (EU) 2023/1115 of May 31, 2023, OJ L 150 of June 9, 2023, consolidated version of September 18, 2026, Articles 2, 3, 4, 4a, 5, 8, 9, 25, 29, 38 and Annex I · online · primary · reading: yes (Cellar, CELEX 02023R1115-20260918, and original version for Article 38)
2. Regulation (EU) 2024/3234 of December 19, 2024, postponement of application · online · primary
3. Regulation (EU) 2025/2650 of December 19, 2025, obligations of operators and traders, second postponement · online · primary
4. Delegated Regulation (EU) 2026/2102 of July 13, 2026, OJ of September 17, 2026, list of products (instant coffee, samples) · online · primary
5. Implementing Regulation (EU) 2025/1093 of May 22, 2025, list of low- or high-risk countries, annex · online · primary
6. Commission, simplification review report on Regulation 2023/1115, COM(2026) 191, sent to the Council under reference ST 8943/26 of May 6, 2026 · online · primary
7. Commission, guidance document on Regulation 2023/1115, OJ C of July 20, 2026 (CELEX 52026XC03896), definition of agricultural use · online · primary · reading: yes (passages)
8. Directive (EU) 2022/2464 (CSRD), consolidated version of March 18, 2026, Article 5 · online · primary
9. Commission, proposal for a Council regulation on the outermost regions, COM(2026) 661 of September 10, 2026 (French Guiana and Regulation 2023/1115) · online · primary · reading: yes (passage)
10. Directive (EU) 2026/470 of February 24, 2026, OJ of February 26, 2026, Article 1 (thresholds, value chain cap) and Article 5 (transposition) · online · primary
11. Directive (EU) 2024/1760 (CSDDD), consolidated version of March 18, 2026, Articles 2, 8 and 37 · online · primary