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Is your coffee in scope? (Almost certainly yes)

Coffee sits squarely in Annex I — green coffee (HS 0901) and roasted coffee are covered, and coffee husks and substitutes containing coffee are caught too. [Reg. 2023/1115, Annex I] The one live question is soluble/instant coffee: a draft delegated act was pending as at 9 July 2026 that proposes adding soluble coffee and coffee extracts to Annex I. [Commission EUDR implementation page] If you sell instant coffee, treat it as an imminent addition rather than out of scope.

Which role are you? (This is the roaster's real question)

• You import green coffee into the EU yourself. You are the first operator: you run due diligence and file the DDS before the beans clear customs. [Reg. 2023/1115, Art. 4(2)]
• You buy green coffee from an EU green-coffee importer, then roast. The importer is generally the first operator who filed the DDS; you are downstream and collect and keep the DDS reference number. If you are a non-SME, you must also register and verify the upstream due diligence. [Reg. 2025/2650, Art. 5]
• You are a micro or small roaster. Your application date may be 30 June 2027 rather than 30 December 2026 — coffee is not timber, so the later date is available if you meet the size test. [Reg. 2025/2650, Art. 38(3)]

What to ask your green-coffee supplier for

Whatever your role, you will want origin data in the chain. For each lot, request: [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• Plot geolocation — coordinates, and polygons for plots over 4 hectares.
• Harvest/production dates.
• Country of production (which sets the risk tier — see below).
• Legality evidence for the country of origin.
• The DDS reference number, where the supplier is the operator that filed it.

Origin risk tiers for coffee

Coffee origins span the tiers. Under Implementing Regulation (EU) 2025/1093, most major coffee origins are standard risk, which means full due diligence; some are low risk (simplified). [Impl. Reg. 2025/1093] Blends complicate this: a multi-origin blend can pull the whole lot to full due diligence, so keeping single-origin lots separable helps preserve any simplified route.

What this determines — and what it doesn't

Screening your coffee tells you scope, role, deadline and the documentary obligations you owe. It does not verify that any farm is deforestation-free — that depends on the geolocation-plus-evidence your suppliers provide and any satellite check. You don't need a traceability platform to begin; you need to know your position and exactly what to ask your green-coffee supplier for.

General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free. Confirm your classification with counsel before relying on it for a market-access decision.

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