This checklist provides a 26-point framework for coffee operators and traders to assess readiness for the EU Deforestation Regulation. It is organised by supply chain tier — from smallholder sourcing through cherry collection, wet or dry processing, and export — reflecting the aggregation complexity where cooperatives collect cherry from hundreds of smallholders and process them through shared facilities before the coffee reaches the EU market.
Completing this checklist does not constitute compliance. The EUDR requires operators to exercise due diligence and file a Due Diligence Statement substantiated by evidence. This checklist helps identify where your evidence chain has gaps before a competent authority finds them.
What is the EUDR coffee compliance obligation?
Regulation 2023/1115 prohibits placing on or exporting from the EU market commodities that are not deforestation-free or were not legally produced. Coffee (HS 0901 — green and roasted) is among the seven covered commodity groups.
For coffee, the supply chain spans 4-5 tiers: smallholder to cherry collection point, collection to wet or dry processing station, processing station to dry mill or exporter, exporter to EU importer. A single processing station may aggregate cherry from hundreds of contributing farms. The operator filing the DDS — typically the EU importer — bears the full burden of proof under Article 4.
Cherry-to-green-bean processing involves approximately 5:1 weight loss, and different processing methods (washed, natural, honey) produce different yield ratios, adding complexity to volume reconciliation and traceability documentation.
What this template covers
Sourcing and geolocation (Articles 9(1)(d), 9(1)(e))
- All source plots identified and geolocated in WGS84 (EPSG:4326) at 6-decimal precision
- Single GPS point captured for plots of 4 hectares or less; polygon boundaries captured for plots exceeding 4 hectares (most coffee smallholdings fall within the single-point threshold)
- Geolocation data includes collection timestamp, device metadata, and collector identity — not just raw coordinates
- Each plot linked to an identified farmer with tenure documentation on file
- Planting year or crop establishment date recorded for each plot to verify production against the December 31, 2020 deforestation cutoff
- For plots in highland forest areas or regions with documented forest encroachment: satellite imagery analysis performed to confirm no forest loss after December 31, 2020
- Growing system documented — shade-grown under canopy, full-sun, or mixed agroforestry — as this affects deforestation risk profile and satellite imagery interpretation
Risk assessment (Article 10)
- Country risk classification confirmed for each origin (standard, low, or high risk) using current EU benchmarking
- Deforestation screening performed using satellite imagery anchored to the December 31, 2020 baseline
- Independent deforestation alert systems cross-referenced for each source area (e.g., Global Forest Watch, GLAD alerts)
- Risk assessment methodology documented: data sources, resolution, thresholds, and decision criteria recorded
- Where concerns identified: risk mitigation measures documented and implemented before DDS filing (Article 10(2))
- Origin-specific risks documented — altitude and terrain of growing areas may affect satellite imagery availability and resolution
Legality verification (Article 9(1)(e))
- Relevant legislation of the country of production identified (land use laws, forestry regulations, environmental protections, labour laws, tax obligations, and community rights including FPIC)
- Legal compliance evidence collected or supplier attestation obtained with supporting documentation for each origin
- For origins with protected forest designations (e.g., Ethiopian coffee forests, Indonesian forest zones): documentation confirming production area is not within protected forest boundaries
- Applicable permits, cooperative registrations, or export authorisations on file and verified as current
Processing and traceability (Articles 4, 9)
- Cherry collection points mapped — each collection station's contributing smallholders documented
- Processing method recorded for each lot — washed (wet), natural (dry), or honey — as yield ratios differ by method
- Cherry-to-green-bean conversion documented (approximately 5:1 by weight for washed processing, varying for natural and honey) with measurement methodology
- Cooperative or station-level aggregation tracked — each outbound lot of parchment or green bean linked to the specific set of contributing source farms
- Batch or lot identifiers maintained from processing station through dry mill and exporter with traceability links at each transfer
- No mass balance applied — the EUDR prohibits mass balance; physical segregation or identity preservation required
Documentation and filing (Articles 4, 9, 12)
- DDS prepared with all required fields under Article 4(2) before the product is placed on the EU market
- All supporting evidence archived and retrievable for the mandatory 5-year retention period (Article 12)
- Evidence chain auditable end-to-end: competent authority can trace from filed DDS to individual smallholder plot through each aggregation stage
- DDS reference number obtained from the EU Information System and linked to shipment and customs documentation
How to use this template
Step 1 — Map your supply chain. Document every tier from source plot to EU market entry: smallholders, cherry collection points, processing stations, dry mills, exporters, and the EU importer. For coffee, identify whether your supply chain uses wet or dry processing — the station where cherry is processed is a critical aggregation point.
Step 2 — Work through each section. Mark items complete only when documentary evidence exists — not when a process is planned or verbally confirmed.
Step 3 — Close gaps before filing. Prioritise smallholder geolocation and processing-station traceability, as cherry aggregation is the hardest gap to close retroactively.
Step 4 — Review quarterly. New contributing farmers, station changes, and risk reclassifications require reassessment.
How to implement this in your organisation
Assign ownership. Your compliance officer or sustainability manager owns this checklist and is accountable for its completeness. Station managers and cooperative coordinators contribute processing and sourcing evidence; the export manager reviews the assembled package before DDS filing.
Set the review cadence. Integrate geolocation capture with cherry delivery at washing stations so plot data is recorded at the point of intake, not reconstructed later. Conduct a full checklist reassessment quarterly and immediately when triggered by a new contributing farmer, a station change, or a country risk reclassification by the European Commission.
Define your escalation path. Any gap identified during review halts DDS preparation for the affected consignment until the gap is closed. The responsible team member escalates unresolved gaps to the export manager within 48 hours, with a documented explanation of the gap and a proposed remediation timeline.
Connect to existing workflows. Link farmer geolocation verification to your existing cooperative enrolment and cherry intake procedures so data is captured before aggregation begins. Tie cherry-to-green-bean conversion documentation and lot traceability to your existing QC handover points at washing stations and dry mills, and attach completed checklist evidence to export documentation packages alongside ICO certificates and commercial invoices.
Who needs this template
- Coffee exporters assembling DDS evidence packages for EU-bound consignments
- Processing stations and cooperatives documenting cherry-to-green conversion, batch traceability, and farmer enumeration
- Compliance officers auditing evidence chains across multi-tier coffee supply chains before DDS filing
- EU importers verifying upstream evidence meets the standard for a defensible Due Diligence Statement
FAQ
How do processing method differences affect EUDR traceability?
Washed, natural, and honey processing produce different yield ratios and involve different aggregation patterns. Washed processing occurs at centralised washing stations aggregating cherry from many farmers; natural processing may occur at the farm level. Regardless of method, the EUDR requires traceability to the plot where the cherry was produced (Article 9(1)(d)). Document the processing method, yield ratio, and aggregation pattern for each lot.
Does shade-grown coffee have different compliance requirements?
The compliance requirements are identical. However, shade-grown coffee under forest canopy challenges satellite-based deforestation screening: the transition from natural forest to shade-coffee may not be visible in canopy-cover analyses. Operators must ensure their screening methodology can distinguish natural forest from shade-coffee agroforestry established after December 31, 2020.
How do I handle Arabica and Robusta from different origins in the same shipment?
Each variety from each origin requires its own geolocation data and risk assessment. Where both are included in a single shipment, each must be separately documented in the DDS with its own geolocation, deforestation screening, and legality verification.
Does completing this checklist mean I am EUDR compliant?
No. This checklist helps identify evidence gaps. Completing every item means you have documented your evidence chain — it does not certify compliance, guarantee a successful regulatory review, or substitute for independent legal counsel. Operators must exercise due diligence and substantiate their DDS with evidence a competent authority can verify.
Coffee supply chains involve smallholder fragmentation, significant processing weight loss, and diverse growing conditions across origins that create unique traceability challenges among EUDR-covered commodities. A checklist identifies gaps — a platform closes them. Book a demo to see how ResourceLedger provides evidence-grade traceability from smallholder plot to EU port of entry.