Coffee Importers and the EUDR: From Farm GPS to DDS

Coffee is one of the EUDR's seven covered commodities, and Germany alone accounts for 38% of all EU green coffee imports. If you import green coffee, or buy it from someone who does, you are almost certainly in scope. The question isn't whether the regulation applies to your business. It's whether your supply chain data is ready.

This guide walks through the specific compliance challenges for coffee: long supply chains, smallholder farm structures, and what "GPS coordinates" actually means when you're buying from a cooperative in Sidama or Huila.

Does EUDR apply to your coffee business?

Coffee is listed explicitly in Annex I of Regulation (EU) 2023/1115. Green coffee (HS 0901.11, 0901.12), roasted coffee (0901.21, 0901.22), and decaffeinated variants all fall under the regulation. If you import any of these from a non-EU country, you are an operator and the full due diligence obligation applies.

The only way out of that obligation is if someone else already filed a Due Diligence Statement covering your specific shipment. If you buy from a Hamburg or Rotterdam trading company that imported the coffee and submitted a DDS when it entered the EU, you may be a trader rather than an operator. But you still need their reference number. You can't simply assume compliance has been handled.

The compliance deadline for large and medium businesses is December 30, 2026. Small enterprises (fewer than 50 employees, under EUR 10 million annual turnover) get until June 30, 2027. Neither deadline is close enough to wait.

The supply chain challenge: 10+ intermediaries between farm and roastery

A typical arabica supply chain looks like this: farmer, wet mill, dry mill, exporter, freight forwarder, importer, trader, roaster. That's seven links, and some chains add more. Each link is a potential gap in the data trail the EUDR requires you to document.

The regulation requires GPS coordinates for the actual production plot, not for the mill, the warehouse, or the exporter's office. That means your compliance data needs to travel the entire chain in reverse: from the farm back to your desk in Frankfurt or Amsterdam. In practice, few supply chains were built to carry that information.

Many exporters and importers currently track origin to the cooperative or washing station level, not to individual farm plots. That's commercially sufficient for quality traceability but legally insufficient for EUDR. You will need to go a layer deeper than you have before.

The good news for specialty coffee buyers: direct trade relationships often have shorter chains and better farmer-level data. If you're sourcing single-origin lots with documented producer relationships, you're starting from a better position than someone buying commodity blends through a spot market.

Origin country risk: Ethiopia, Vietnam, Colombia, Brazil

The European Commission will classify each country as low, standard, or high risk for deforestation. As of April 2026, those classifications haven't been finalised. For planning purposes, treat your origins as follows.

Brazil and Colombia are likely to be classified as standard risk. Brazil has the largest deforestation footprint of any country supplying the EU coffee market, though the Cerrado and Atlantic Forest regions relevant to arabica production differ significantly from Amazonian deforestation patterns. Colombia's coffee zones are generally lower-risk but not exempt. Both require full due diligence.

Ethiopia is the world's largest exporter of wild and semi-wild arabica. Its farms are also, on average, about 0.5 hectares (smaller than a city block). That's actually good news for geolocation purposes: a plot that size qualifies for a single GPS point rather than a closed polygon, which simplifies data collection considerably. Ethiopian origin still carries standard deforestation risk, particularly in forest-adjacent growing regions like Kaffa and Bench Sheko.

Vietnam is the EU's primary robusta source and is expected to be classified as low risk. Low-risk classification allows simplified due diligence: you still need to collect geolocation data and submit a DDS, but the risk assessment threshold is lower and the documentation burden is reduced.

Country classification is a starting point. If satellite imagery shows deforestation near a specific plot in a low-risk country, that plot requires the same scrutiny as one in a standard-risk country.

How to get GPS coordinates from your importer or origin supplier

GPS data is the bottleneck for every coffee importer we've spoken to. It's not the DDS form, not TRACES NT, not the risk assessment software. It's getting a reliable latitude and longitude from a cooperative in Yirgacheffe that has never had that conversation with a buyer before.

There are a few practical approaches, and the right one depends on your supply chain structure.

If you buy directly from a cooperative or exporter, the most effective method is a structured data request sent before your next purchase contract is signed. Frame it as a condition of the relationship going forward, not a favour you're asking. Cooperatives that work with multiple EU buyers will start hearing this from every direction, and the ones who collect data early will have a commercial advantage. Your request should specify: decimal degrees format, six decimal places, WGS84 datum. A coordinate like 6.130200, 38.754100 is correct. 6.13, 38.75 is not.

If your cooperative works with an origin-country NGO or certifier (Rainforest Alliance, Fairtrade, UTZ, various national bodies), those organisations often already hold farm boundary data. It's worth asking whether they can share it or facilitate a data collection exercise.

If you buy through a European trading company, your first question is straightforward: do you have a DDS reference number for this lot? If yes, you're a trader and you're mostly done. If no, that trading company should be collecting farm GPS data as part of their own compliance process. If they can't tell you what their plan is, that's a commercial risk as well as a regulatory one.

For small Ethiopian farms, mobile GPS collection is common. Apps like KoboToolbox or EarthRanger are used by cooperatives working with development programmes. If your supplier doesn't have data yet but is willing to collect it, these tools work on low-end Android phones with no connectivity required during field collection.

The roaster's specific question: am I an operator or a trader?

Most roasters in Germany and elsewhere buy from domestic or Dutch traders rather than importing directly. If that describes you, the question of whether you're an operator or a trader determines how much work you need to do.

The rule is straightforward: whoever first placed the green coffee on the EU market is the operator. If a Hamburg importer brought in the coffee, filed a DDS with TRACES NT, and then sold it to you, they are the operator. You are a trader. If you're a small business (under 50 employees and EUR 10 million turnover), Article 4(8) of the regulation lets you rely on the operator's DDS reference number rather than running your own due diligence. You get that reference number, store it, and pass it downstream when asked.

The scenario that catches roasters off guard: buying from an EU trading company that has not completed EUDR compliance themselves. Some traders imported coffee before enforcement deadlines crystallised their obligations and have not gone back to collect farm-level GPS data. If your supplier cannot give you a DDS reference number, one of you needs to go back to the source, and you need to resolve that question before December 30, 2026.

Specialty roasters importing directly, signing contracts with cooperatives in Ethiopia or Colombia and acting as importer of record, are operators. Full stop. Your compliance obligation is the same as a large commodity importer, scaled to your volume. The EUDR operator vs trader breakdown covers the regulatory definition in detail.

Germany has 3,000+ coffee roasters. Most don't have a compliance department. TracePlot is built for them.

Putting it together: what a coffee DDS looks like in TRACES NT

A completed DDS for a single coffee shipment contains, at minimum: your company details, the HS code and quantity, the country of production, GPS coordinates for each production plot, harvest year, your direct supplier's name and address, and your risk assessment conclusion.

For an Ethiopian lot from 50 smallholder farms within a cooperative, that means 50 sets of GPS coordinates, each tied to a harvest period and a supplier record. The TRACES NT system accepts bulk uploads, so you're not entering these manually, but you need the data in the right format before you start.

The risk assessment attached to those coordinates should cross-reference each plot against satellite-derived forest cover data for the period after December 31, 2020. For Ethiopian farms under 4 hectares, each farm is a single point and you're checking a small radius around that point. For larger Brazilian or Colombian farms with polygon data, you're checking the full plot boundary.

The DDS must be submitted and receive a reference number before your goods are presented to customs. Not when the container arrives at Hamburg. Before. If you're importing regular monthly shipments, you'll be submitting a DDS for each one. That rhythm needs to be part of your procurement calendar, not an emergency task when the cargo ship is already in the North Sea.

TRACES NT isn't intuitive, and the EUDR module was added to a system originally built for food safety controls. Give yourself at least one practice submission on a low-stakes shipment before your highest-volume import depends on it. For more on what the DDS must contain field by field, see the guide to EUDR due diligence statement requirements. For how TracePlot structures the underlying satellite analysis and data collection workflow, see the methodology.

---

The compliance gap for most coffee importers isn't in the paperwork. It's in the farm-level GPS data that nobody in the supply chain collected before this regulation existed. Starting that data collection conversation with your suppliers now, before the peak 2026 buying season, is the most valuable thing you can do before the deadline.

TracePlot handles the GPS collection workflow, satellite risk assessment, and DDS preparation for coffee supply chains. Reserve your onboarding slot for EUR 49.