As the EU importer filing the Due Diligence Statement, you bear the full legal burden of proof under Article 4. Coffee presents particular verification challenges: smallholder fragmentation, a 5:1 cherry-to-green-bean weight loss complicating volume reconciliation, different aggregation patterns between wet and dry processing, and shade-grown systems that challenge satellite screening. This checklist helps you verify what your coffee supplier has provided and flag evidence requiring additional investigation.
What is the EU importer's verification obligation?
Under Regulation 2023/1115, the operator placing a product on the EU market must exercise due diligence — not merely collect evidence, but critically assess it. Article 10 requires evaluation using "adequate and verifiable information." For coffee, the importer must verify evidence across a chain where cherry from hundreds of smallholders is aggregated, undergoes significant weight loss, and may be blended across origins. The competent authority holds the filing operator accountable. If volume reconciliation ignores processing losses or geolocation is village-level, the importer must resolve these before filing.
What this template covers
Supplier documentation review
- Verify the supplier has provided individual farmer-level documentation — not village-level aggregates
- Confirm documentation identifies every tier: farmers, collection points, processing stations, dry mills, and exporter
- Check internal consistency — farmer names, coordinates, and volumes align across geolocation files, collection records, and transport documentation
- Verify certifications (Rainforest Alliance, Fairtrade, 4C) are supplementary only — certifications do not satisfy the EUDR
- For multi-origin blends: confirm separate documentation for each origin
Red flags: Station summaries without individual farmer identification. Single attestation covering the entire consignment. Multi-origin blend treated as a single origin. Certifications cited as sole evidence.
Geolocation data verification
- Verify coordinates are field-captured with GPS devices, not estimated from village names, with collection timestamps and device metadata
- Confirm coordinates use WGS84 (EPSG:4326) at 6-decimal precision
- For plots of 4 hectares or less (most coffee smallholdings): verify GPS centroids. For larger plots: verify polygon boundaries
- Cross-check a sample against satellite imagery to confirm coffee-producing land at plausible altitudes
- Verify plot count matches the number of individual farmers claimed
Red flags: Round-number coordinates (e.g., -6.000000, 37.000000) — likely estimated. Multiple farmers sharing identical coordinates — copy-paste. Missing timestamps on geolocation records. Coordinates at implausible altitudes for the claimed variety (e.g., Arabica at lowland elevations).
Deforestation-free evidence assessment
- Verify screening uses satellite imagery anchored to the December 31, 2020 baseline
- Confirm screening methodology accounts for the difference between natural forest canopy and shade-grown coffee canopy — satellite imagery may not distinguish the two
- Verify shade-grown plots have specific methodology documentation for how shade canopy was distinguished from forest
- Cross-reference against at least one independent alert system (Global Forest Watch, GLAD alerts)
- For origins with documented forest encroachment: verify proximity screening was performed
Red flags: No deforestation alerts in a region with documented forest encroachment — may indicate inadequate methodology. Imagery resolution too coarse for smallholder plots in mountainous terrain. No shade-canopy methodology documented. No independent cross-referencing.
Legality evidence assessment
- Verify the supplier identified relevant legislation: land use laws, forestry regulations, labour laws, tax obligations, and community rights including FPIC
- For origins with protected forest designations (Ethiopian coffee forests, Indonesian forest zones): verify documentation confirms plots are not within protected boundaries
- Confirm legal evidence goes beyond self-attestation — permits, cooperative registrations, or third-party verification on file
- Verify land tenure documentation per farmer — title, customary record, or local authority attestation
- Confirm export authorisations are current for the specific consignment
Red flags: No protected-area assessment for origins bordering forest reserves. Land tenure based on verbal claims only.
Processing and traceability verification
- Verify cherry collection records link each delivery to a specific farmer and plot
- Confirm processing method (washed, natural, honey) documented per lot with corresponding yield ratio
- Verify volume reconciliation accounts for ~5:1 cherry-to-green-bean loss
- For wet processing stations: verify individual farmer linkage is maintained through processing
- Confirm batch identifiers maintained from station through dry mill and exporter
Red flags: Volume gaps exceeding 5% with processing loss unaccounted for. No lot-level linkage despite identity preservation claims. Mass balance language anywhere — EUDR prohibits mass balance (Article 9). Uniform cherry weights (suggests estimates). Multi-origin blend with no per-origin traceability.
Risk assessment and DDS readiness
- Verify the risk assessment covers all Article 10 factors: country classification, deforestation prevalence, supply chain complexity, and circumvention risk
- For multi-origin blends: confirm each origin has its own risk assessment
- Confirm the "negligible" conclusion is supported by evidence, not merely asserted
- Verify documented mitigation measures were implemented before shipment where risks were identified
- Confirm evidence is archived for the 5-year retention period (Article 12)
How to use this template
Step 1 — Request the full evidence package. Ensure your supplier has provided per-farmer geolocation, screening reports, legality evidence, processing records with yield reconciliation, and traceability linking each farmer to the export lot. For multi-origin blends, request separate evidence for each origin. For coffee, verify processing-loss-adjusted volume reconciliation — the 5:1 cherry-to-green-bean ratio means raw volume comparisons are misleading.
Step 2 — Work through each section. Mark items verified only when independently confirmed. Focus on whether volume reconciliation accounts for the 5:1 processing loss and whether shade-canopy screening is documented.
Step 3 — Escalate red flags. Any red flag requires additional investigation. Do not file a DDS with unresolved red flags.
Step 4 — Document your verification. Record what you checked and how you resolved issues. Your verification process is itself due diligence evidence.
How to implement this in your organisation
Assign ownership. Your EU compliance officer owns the checklist end-to-end, from receiving the supplier evidence package through to the filing decision. Procurement acts as the first filter, performing a completeness check on each incoming package before forwarding it for substantive review. An internal auditor should review the compliance officer's verification work at least annually to confirm procedures are followed consistently.
Set the review cadence. Run this checklist for every consignment before filing the DDS — per-consignment review is non-negotiable. Conduct a full supplier re-assessment annually, and trigger immediate re-verification whenever a supplier reports changes to their farmer base, processing stations, or intermediary chain. For each consignment, verify processing-loss-adjusted volume reconciliation against the expected 5:1 cherry-to-green-bean ratio — raw volume comparisons that ignore this loss are misleading and will not withstand scrutiny.
Define your escalation path. Any red flag identified during verification pauses the DDS filing immediately. Procurement holds the next payment milestone until the issue is resolved. If a red flag remains unresolved within 30 days, escalate to the head of compliance or legal counsel. Document every escalation, including the date raised, parties involved, and resolution or outcome.
Connect to existing workflows. Embed the evidence specification directly in purchase contracts so suppliers know what to provide before shipment — particularly the requirement for per-farmer geolocation, processing yield records, and shade-canopy screening methodology. Gate customs release on checklist sign-off — no signed-off checklist, no release authorisation. Integrate QC inspection at port with the verification process so that cupping, grading, and documentation review happen as a coordinated step rather than separate procedures.
Who needs this template
- EU importers verifying coffee supplier evidence packages before filing a DDS
- Compliance officers assessing whether upstream evidence across fragmented origins and processing chains supports a defensible Due Diligence Statement
- Procurement managers evaluating supplier evidence quality, particularly for multi-origin blends requiring per-origin verification
Does completing this checklist mean my DDS will pass?
No. Completing every item means you have systematically reviewed the evidence — it does not certify compliance, guarantee a successful regulatory review, or substitute for independent legal counsel. The competent authority assesses the substance of your evidence, not whether you completed a checklist.
How should I verify volume reconciliation given the 5:1 processing loss?
Request both inbound cherry weight and outbound green bean weight per lot. For washed processing, ~5 kg cherry should produce ~1 kg green bean. Significant deviations without explanation suggest inaccurate measurement, undocumented mixing, or data fabrication. Natural and honey processing have different ratios — ensure the correct ratio is applied per method.
What additional verification is needed for multi-origin blends?
Each origin in a blend requires separate geolocation, deforestation screening, legality verification, and risk assessment. Three origins means three complete evidence packages. If per-origin documentation is unavailable, the evidence does not support a defensible DDS.
How do I verify shade-grown plots that look like forest on satellite imagery?
Request the supplier's methodology for distinguishing shade canopy from natural forest. The supplier should document imagery resolution, analytical method, and whether ground-truthing was performed. No documented methodology means screening may not have assessed these plots adequately.
Coffee verification demands that EU importers account for the 5:1 processing loss, shade canopy screening complexity, and multi-origin blending — challenges that cannot be addressed by accepting supplier documentation at face value. A checklist structures the review — a platform automates the verification. Book a demo to see how ResourceLedger helps EU importers verify supplier evidence with audit-grade traceability from smallholder plot to port of entry.