Reg. (EU) 2023/1115 · large and medium operators from 30 Dec 2026 · micro and small enterprises from 30 Jun 2027.
Coffee placed on the EU market must be deforestation-free and legally produced, backed by a due-diligence statement with geolocation of every production plot. Large and medium operators come into application on 30 December 2026; micro and small enterprises follow on 30 June 2027, under the postponement in Regulation (EU) 2025/2650. For a crop grown by millions of smallholders, the plot-level data requirement is the entire project.
Coffee must not come from land deforested after 31 December 2020 — proven, not presumed, for every plot in the supply chain.
Due diligence includes geolocation coordinates for all plots of land where the coffee was produced — polygon-level for larger plots.
Operators file a statement in the EU information system before placing product on the market; reference numbers travel with the trade.
Beyond deforestation: production must comply with the producing country's laws — land rights, labor, environment. Paper claims invite challenge; linked evidence survives it.
The application dates were set back once to allow the system to stand up. They are live now — EU roasters and importers are pushing the data requirement down through traders to origin.
Plot geolocation for smallholder networks is slow, physical work. Start with the cooperatives that feed your largest EU volumes.
The gap in most EUDR programs is between the map and the bag: harvest lots must link to plot polygons at intake, not be reconstructed at export.
Due-diligence reference numbers must follow the coffee through blending and consolidation. Design the data flow for how coffee actually moves.
Aeroz binds identity to coffee at bag or lot level from cooperative intake onward, writing each custody step as an EPCIS 2.0 event linked to plot geolocation and the due-diligence statement. The importer's file stops being a folder of PDFs and becomes a verifiable chain — and shipments routed through the Aeroz Dubai hub can leave for the EU with the evidence already attached.
From 30 December 2026 for large and medium operators and traders, and 30 June 2027 for micro and small enterprises — the dates set by Regulation (EU) 2025/2650. Coffee from land deforested after 31 December 2020 cannot be placed on the EU market.
Coordinates for every plot of land where the coffee was produced — with polygons expected for plots above four hectares. "Region" or "cooperative" level is not sufficient.
Through mapped cooperative networks: plot registration at the co-op, harvest lots linked to registered plots at intake, and that linkage preserved through processing and export. It is achievable — but only as a data chain, not a certificate.
They cannot lawfully be placed on the EU market; member-state authorities can detain product, impose penalties and confiscate revenue. The commercial reality arrives earlier: EU buyers simply stop buying unverifiable origin.
A fixed-fee Aeroz audit maps your products against eudr for coffee requirements and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.