The EU Deforestation Regulation (EUDR) officially comes into force on 30 December 2025, and just weeks before that date, the European Commission has proposed a few late changes.
The European Coffee Federation (ECF) has responded with feedback on what these updates could mean for coffee businesses. Here’s a quick breakdown on what’s changing, what the industry is asking for, and what to keep an eye on as we move into 2026.
More time to get ready
ECF is asking for a 12-month grace period (until December 2026) for everyone in the coffee chain to adapt. The Commission’s plan only gives six months and ECF says that’s nowhere near enough time to adjust systems and processes, especially when final details are still changing.
However, the European Parliament has now agreed to extend the implementation deadlines. Large operators and traders must comply by 30 December 2026, while micro and small enterprises have until 30 June 2027.
Less red tape for roasters
Right now, the draft rules still ask roasters and traders to collect and store reference numbers for all supplier due-diligence statements (DDS). ECF says this would mean mountains of admin work, with little added benefit. Instead, they want the full responsibility to sit with the first EU importer.
In the most recent Parliament/Council draft, the obligation to submit the required due diligence statement would fall on the business that first introduces the product onto the EU market, rather than on each downstream operator or trader. Under that draft, micro and small primary operators would only need to submit a one-off simplified declaration.
Because the final version of the EUDR is not yet adopted, these simplifications remain subject to confirmation. Some obligations may still apply to downstream actors, especially in terms of retaining and passing on the DDS reference number to ensure traceability.
A fairer “grace period”
The ECF also wants clearer protection for companies during the grace period. Under the current wording, any “warnings” issued before full enforcement could still count as repeat offences later. ECF says these should be private, non-punitive, and used purely to help companies adapt.
Include instant coffee
Instant (soluble) coffee is still excluded from the EUDR product list, something ECF says creates a loophole. They’re calling for soluble coffee to be included, with samples for testing or promotion still exempt. That would ensure fair competition and consistent sustainability standards.
Backup plans and consistency
There’s concern that the EU’s new online system (TRACES) might not be fully ready in time. ECF wants clear backup measures and consistent enforcement across all EU countries so that businesses aren’t treated differently depending on where they operate.
Review sooner
ECF has asked the EU to bring the full EUDR review forward to 2028 instead of 2030. In parallel, the European Parliament has requested a simplification review by 30 April 2026 to assess administrative burden and early implementation. Both signals point to ongoing adjustments as the regulation rolls out.
What this means for you
If you roast, import, or sell coffee in the EU or UK, keep an eye on:
- Final confirmation of grace-period details and product scope.
- Guidance on how traceability and data sharing will work in practice.
- Updates from your national authority or trade body in early 2026.
The direction is clear: the industry supports deforestation-free supply chains and wants rules that are fair, practical and workable for businesses of all sizes. With a few details still being refined, the best step now is to stay close to updates from the Commission and your national authority, and make sure your supply-chain data is ready for the shift into full compliance.
For anyone looking to revisit the foundations, our previous EUDR guides offer an overview of how the regulation works and what operators need to prepare for.
Customers are still fully responsible for understanding and meeting their own obligations under EUDR and should seek independent advice to ensure compliance with their specific responsibilities.
