- The European Commission has proposed simplifying EUDR compliance for micro and small enterprises, including coffee businesses.
- This decision follows recent issues with setting up the IT system to handle data related to product transactions.
- If approved, SMEs would have reduced reporting obligations, and the formal entry into force of the application will be delayed until December 2026.
- For all other companies, the deadline would remain 30 December 2025, with a six-month grace period.
- Certain supply chain actors, including smallholder farmers and downstream companies, would also be exempt from submitting due diligence statements.
The European Union Deforestation Regulation (or EUDR) is already transforming the coffee industry as we know it, reshaping Environmental, Social, and Governance (ESG) compliance. The landmark legislation seeks to eliminate products sourced from supply chains that involve deforestation, including coffee and other commodities.
Although well-intentioned, the EUDR has come under continuous fire, particularly for its perceived political bias and potential harm to smallholder farmers in majority-producing countries. Many stakeholders have called for additional delays to grant supply chain actors more time to comply, especially after recent IT issues that could hinder data reporting.
While the European Commission has decided not to delay its regulation further for larger companies, it has proposed simplifications for micro and small enterprises (SMEs) that, it claims, would better support the transition to deforestation-free supply chains. If approved, certain supply chain actors, including smallholder farmers and downstream companies, would also be exempt from submitting due diligence statements.
We spoke to Harry Marshall at OpenAtlas and Héctor González at Xorxios to find out what this means for smaller roasters and coffee businesses.
You may also likeour article on what roasters need to know about EUDR-ready coffee.
A timeline of the EUDR in coffee
The EUDR has dominated conversations in the global coffee industry since its initial adoption in December 2022. The landmark legislation is among the most significant to affect agricultural commodity trade in recent history, aiming to eradicate deforestation in key global commodities, including soy, cattle, palm oil, coffee, cocoa, timber, and rubber.
While some have praised the regulation’s objective of ensuring environmental protection as non-negotiable, its strict implementation and compliance mechanisms have drawn criticism. Others assert that the legislation’s tier benchmarking system (which categorises commodity-producing countries as low, standard, or high risk) will deter buyers from certain countries, removing critical market access for smallholders.
Ministers from Indonesia – the world’s fourth-largest coffee producer and categorised as standard risk under the EUDR – referred to the regulations as “inherently discriminatory and punitive in nature” and expressed their concerns about their impact on key exports.
Calls to delay EUDR and buy supply chain actors more time to prepare for compliance have been persistent. In August 2024, key stakeholders, including Fairtrade International, Global Coffee Platform, and the European Coffee Federation, warned that the legislation could unintentionally harm smallholder farmers. For countries like Ethiopia, where the majority of coffee farmers have limited access to data needed to prove due diligence, the legislation could significantly restrict their access to the EU market, which buys up to 30% of the country’s coffee every year.
In response to these growing concerns, the European Commission approved a one-year delay, moving the compliance deadlines to December 2025 for large businesses and June 2026 for SMEs. The Commission also announced new simplification measures under which companies can submit annual due diligence statements rather than separate statements for each shipment or batch placed on the EU market.
No overall delay, but European Commission proposes weakened regulations
Changes to the EUDR over the last year have offered much-needed relief for producers, traders, and roasters.
A 2024 ODI report states that a year-long delay reduces the risk of a “green squeeze” in Least Developed Countries (LDCs), which contribute minimally to global emissions and often lack the resources and infrastructure to comply with complex traceability and compliance requirements.
In September 2025, following IT issues that would have hindered data reporting, the European Commission proposed another one-year delay to the EUDR.
While an overall delay wasn’t approved, the Commission recently put forth a formal proposal to simplify requirements for SMEs and downstream operators.
If approved, the formal proposal would delay entry into application for micro and small enterprises from June 2026 to December 2026. For all other companies, the entry into force date would remain 30 December 2025, but given the IT issues, they would have a six-month grace period for checks, during which they would receive no fines if unable to prove compliance.
“We see the proposal as a realistic step towards a more balanced and achievable implementation of the EUDR. For micro and small roasters, the changes bring simplified obligations and more time to adapt,” says Héctor, the Head of Quality and Sustainability at Xorxios, a specialty green coffee importer in Spain.
The new proposal, if approved, would also exempt certain actors, including smallholders and downstream companies, from the requirement to submit due diligence statements – seemingly addressing one of the major criticisms of the EUDR.
“The main responsibility shifts to the importers placing green coffee on the EU market, allowing smaller roasters to focus on traceability and sustainability rather than bureaucracy,” Héctor says. “From our perspective, these exemptions are logical and fair. They aim to maintain global traceability while reducing the administrative burden for smallholders and cooperatives with limited technical resources.
“In practice, only the operator placing coffee on the EU market for the first time (typically the importer) must file the full due diligence declaration in the system,” he adds. “Subsequent actors, such as roasters or manufacturers, may be exempt or able to submit a simplified declaration if the data is already available.
“This approach lightens the bureaucratic load for small producers and processors while ensuring accountability and traceability through the importers and primary operators.”
What do small coffee businesses need to know about EUDR updates?
In light of the recent proposal to simplify EUDR requirements for smallholder producers, SMEs, and downstream companies, many are seeking clarification on what the changes would mean in practice.
The term “downstream companies” refers to businesses that operate in the latter stages of a supply chain, including processing, marketing, distributing, and selling finished products to consumers. In the context of coffee, this technically refers to roasters; however, the EUDR’s legal framework defines this differently.
“Under the EUDR, a processing company is classified as an operator or trader depending on whether the transformation results in a significant change to the product’s four-digit Harmonised System (HS) code as listed in Annex I,” Héctor tells me. “In the case of coffee, roasting does not change the HS code (0901), meaning roasters are classified as traders rather than processors.
“This distinction carries practical implications. Micro and small roasters (SMEs) wouldn’t be required to file a due diligence statement (DDS), but must retain traceability information for at least five years,” he adds. “Large roasters or brands (non-SMEs), however, must submit their own DDS and verify that compliance has been properly exercised in previous stages of the supply chain.”
The European Commission defines a micro-enterprise as having 10 or fewer staff and an annual revenue of €2 million or less. A small enterprise, meanwhile, has 50 or fewer staff and an annual revenue of €10 million or less.
“Ultimately, the company’s size and position determine its level of responsibility, with large operators bearing the full legal accountability for compliance,” Héctor says.
For smaller roasters who don’t import coffee themselves, this means less administrative burden, but there’s still a responsibility to check and report data in compliance with the EUDR, including the identity of their suppliers and reference numbers for the due diligence statements associated with specific coffees. This means working closely with trusted importers and exporters who must carry out due diligence checks and risk assessments upstream.
Why EUDR simplifications pose challenges
The EUDR represents a significant step towards combatting deforestation and climate change more broadly, but understanding and adhering to the legislation requires a scrupulous approach.
While the simplifications could bring some relief, they also risk creating a two-tier system that effectively “waters down” the EUDR’s objective.
“The main concern is fragmentation. If the legislation formally requires only part of the supply chain to comply, data consistency breaks down, making it harder for everyone to demonstrate deforestation-free sourcing,” says Harry, the founder of OpenAtlas, a deforestation monitoring company that uses satellite imagery and AI to map areas of land. “It also sends a confusing message to markets and producers about the EU’s long-term direction.
“Simplifications offer short-term relief, not a long-term win,” he adds. “Simplifying obligations for small operators may reduce administrative burden now, but it risks undermining the level playing field and transparency that the EUDR means to establish.”
Additionally, proposed exemptions for smallholders to submit due diligence statements further reduce the administrative burden, which is critical for those without access to data and technology to demonstrate compliance. However, there could still be expectations to provide this data from downstream companies, creating more logistical hurdles that challenge the nature of partnerships between sellers and buyers.
“The larger companies will still need full traceability to comply, and that requirement will cascade down,” Harry explains. “So even if smallholders aren’t submitting due diligence statements themselves, they’ll still be asked for the same data by buyers who are.”
Recent proposals to “soften” EUDR requirements could provide the coffee industry with some breathing room. But overall, the legislation continues to reinforce the need for supply chain actors to work together to safeguard environmental protection and maintain producers’ access to the EU market.
“The deforestation footprint of commodities like coffee won’t shrink because reporting rules are softened,” Harry concludes. “What matters most is creating scalable, accessible tools so even small actors can participate in compliance without being priced out.”
Enjoyed this? Then readour article on why roasters can’t be complacent about EUDR.
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