How to Comply with the EUDR in 2026: Step-by-Step

The December 30, 2026 deadline for large and medium operators is eight months away, and if you're wondering how to comply with EUDR as a small importer, this guide is for you. If you run a coffee import business with 30 people, you probably don't have a compliance department. You have a procurement manager who is already busy, a finance team that has other things to worry about, and a logistics coordinator who has never heard of TRACES NT.

It's written for importers, not for consultants. It walks through the five concrete actions you need to take to comply with Regulation (EU) 2023/1115 before the deadline hits.

A note on deadlines: The December 30, 2026 deadline applies to large and medium operators. If your company qualifies as a small or micro enterprise under EU definitions, your deadline is June 30, 2027. Either way, starting now gives you time to work through supplier data collection without a last-minute crisis.

What EUDR compliance actually requires (the short version)

The EUDR requires you to prove (before your goods clear customs) that the commodities you're importing were not produced on land that was deforested after December 31, 2020. That proof takes the form of a Due Diligence Statement (DDS), which you submit electronically through TRACES NT, the EU's official compliance system.

You don't submit the DDS once and you're done. You submit one for every shipment. Every single time goods cross the border, a DDS must already be in the system.

Fines for non-compliance can reach 4% of your annual EU turnover. Germany's BLE and the Netherlands' NVWA are the primary enforcement bodies in the two largest EU coffee import markets. Both are active. Neither is treating this as a soft launch.

Step 1: Confirm whether you're an operator or a trader

The EUDR defines two roles, and they have different obligations.

An operator is the first company to place a regulated product on the EU market. If you import green coffee from Brazil and sell it to a German roaster, you are an operator. You bear the full due diligence obligation: geolocation data, risk assessment, DDS submission, the works.

A trader buys from an operator who has already done the due diligence. Traders in the supply chain can reference an existing DDS rather than generating a new one, but only if the operator's DDS covers your specific shipment.

Most SME importers are operators. If you're the first EU entity handling the product, assume you're an operator and plan accordingly.

Step 2: Map which of your products fall under Annex I

The EUDR covers 7 commodity groups: cattle, cocoa, coffee, palm oil, soy, wood, and rubber. Annex I of the regulation lists the specific HS codes that fall under each group. It's longer than you expect.

For a coffee importer, the obvious codes apply: green coffee, roasted coffee. But processed products derived from covered commodities can also fall in scope. If you import chocolate-covered coffee beans, both the coffee and the cocoa content may need separate DDS records.

Go through your product catalog line by line. Check each HS code against Annex I. Mark what's in scope and what isn't. This exercise typically takes half a day for a company with 10-20 active SKUs. Do it now, not in November.

Step 3: Collect geolocation data from your suppliers

This is the step where most SME importers run into trouble. The EUDR requires GPS coordinates (polygon or point data) for every plot of land where your commodity was produced. Not the processing facility. Not the export warehouse. The actual farm.

For a coffee importer sourcing from five cooperatives in Colombia and Ethiopia, that means getting precise plot coordinates from every smallholder farmer those cooperatives work with. Some cooperatives already have this data. Many don't.

Start by asking your suppliers directly. Send a structured request that explains what you need and why. Some will respond with GPS files. Some will need help. A few will need technical assistance to collect the data in the first place.

The regulation requires you to make reasonable efforts to collect data, but "reasonable" has limits. If a supplier repeatedly fails to provide geolocation data, you cannot complete your DDS for that shipment. Build this into your procurement timelines now so you're not choosing between missing a shipment and non-compliance.

TracePlot's methodology includes a supplier data collection workflow that sends structured GPS requests directly to your suppliers and tracks responses in one place.

Step 4: Run a deforestation risk assessment for each plot

Once you have the plot coordinates, you need to verify that no deforestation occurred on or near those plots after December 31, 2020. The EUDR doesn't specify exactly how to do this, but it does require you to use reliable data sources and document your methodology.

In practice, this means running satellite imagery analysis against your GPS coordinates. The World Resources Institute's Global Forest Watch data and the Copernicus/Sentinel-2 satellite archive are the two most commonly used sources. You're looking for evidence of forest cover loss within or adjacent to the plot boundaries after the cutoff date.

The risk assessment also needs to account for country-level risk classification. The Commission has not yet published the final country benchmarking as of April 2026. When it does, high-risk countries will require enhanced due diligence, standard-risk countries a standard assessment, and low-risk countries simplified requirements. Plan for enhanced due diligence on your current origins until the classifications are confirmed.

Document everything. Your risk assessment record needs to be retained for at least 5 years and made available to enforcement authorities on request.

TracePlot automates this step using Sentinel-2 imagery. You upload plot coordinates and get a deforestation risk result within 24 hours, with the underlying satellite evidence stored and attached to your DDS record.

Step 5: Submit your Due Diligence Statement in TRACES NT

TRACES NT is the EU's official digital system for DDS submission. You'll need an EU Login account to access it. If your company doesn't already have one, set it up now — account provisioning can take time.

The DDS form requires: company information, product details (HS code, quantity, country of origin), geolocation data for the production plots, and a statement confirming you've conducted a risk assessment and found no reasonable risk of deforestation.

You submit the DDS before the goods are presented to customs. Not when they arrive at your warehouse. Before. Customs authorities in Germany and the Netherlands have the legal right to block clearance for shipments without a valid DDS reference number.

Once submitted, TRACES NT generates a reference number. That number goes on your customs declaration. Keep a copy of the full DDS record, your risk assessment documentation, and all supplier data together in a file. Enforcement inspections aren't common yet, but they're coming.

One practical note: TRACES NT was originally built for sanitary and phytosanitary controls. The EUDR module was added later and the interface is not intuitive. Give yourself time to learn it on a low-stakes shipment before your highest-volume routes depend on it.

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The importers who will meet this deadline comfortably are the ones who start supplier data collection now, not in October. If your geolocation data is in order before summer, everything else is manageable.

TracePlot automates Steps 3-5. Reserve your onboarding slot for EUR 49.

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