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What documents do you need for the deforestation regulation declaration for coffee?

An overview of the documents you collect as a coffee importer for a due diligence file under Regulation (EU) 2023/1115, with attention to the point where coffee often encounters difficulties: the mixing of batches from multiple plots.

What documents do you need for the deforestation regulation declaration for coffee?

If you import coffee, you collect three types of documents for EUDR purposes at its core: evidence of origin down to plot level, evidence that production complies with the legislation of the country of origin, and the commercial documents that link your coffee shipment to that origin. Together, these form the basis on which you draw up a due diligence declaration or a simplified declaration.

With coffee, there is one additional practical point that occurs less frequently with other commodities: coffee is often mixed early in the supply chain. A collection point or cooperative combines batches from dozens or hundreds of smallholder farmers before the coffee is transported. This makes documentation of that mixing moment just as important as the geographic data of the plots themselves, and more on this later.

Documents demonstrating origin

The core of your file is the geographic location of the plots where the coffee was grown: coordinates or, depending on the size of the plot, a polygon of the plot boundary. You must also record who the farmer or cooperative is, in which country and region the plot is located, and when the harvest took place. For coffee that goes through a cooperative, it is customary for you to receive these details per affiliated farmer, not as a single aggregated location for the entire cooperative.

How you practically request, validate and add those details to your file is set out in the knowledge base on geographic data in practice. It also explains how you handle suppliers who provide the information in a different format than you expect.

Documents substantiating legality

In addition to origin, the Regulation requires you to demonstrate that production complies with the legislation applicable in the country of origin: rules on land use, environment, labour, human rights, taxation and trade. In practice, this consists of export permits, ownership or use certificates of the plot, and where applicable, certifications. A certificate does not replace your own risk assessment, but it does count as supporting documentation.

Whether and how rigorously you substantiate this also depends on the risk classification of the country of origin. With a high-risk country, a competent authority typically expects a more robust file than with a low-risk country. What a risk classification entails and how it is determined per country is explained in a separate article in the knowledge base.

The mixing point: where coffee often gets stuck

The detail that most affects coffee is the moment when batches from multiple farmers come together. Once coffee from ten or a hundred plots ends up in a single silo, bag or container, your file must still be traceable back to each individual plot. This means you must document not only the plots themselves, but also the document in which the cooperative or collection point records which plots have been combined into which batch. If that linking document is missing, you have geographic data, but no unbroken chain from plot to delivered batch.

For SME importers working with multiple small suppliers, this is often the point where the conversation with the supplier becomes concrete: not just asking for coordinates, but also for the collection point's own records.

The declaration and the reference number

From the entirety of origin, legality and commercial documents, you draw up the due diligence declaration, or the simplified declaration if your situation qualifies for it. You submit that declaration to the EU information system, after which you receive a reference number that you pass on to your buyer further down the supply chain. The file underneath — the documents themselves — remains with you.

Five years of retention: what that means in practice for coffee

You retain all supporting documents, from geolocation data to correspondence with your cooperative about the mixing point, for five years. For coffee, this concretely means you maintain a file per purchasing season, even if you purchase from the same cooperative year after year. A new season can indeed mean different plots, different farmers, or a different composition of the batch.

A well-structured file per product stream prevents you from having to figure out which document belonged to which delivery during an inspection. How such a file is structured and where the data comes from is explained on the page on how the file structure works.

Getting started

Which documents you precisely need depends on your role in the chain and the country of origin of your coffee. With the free role check from eudri.com you see in a few questions which role and which obligation apply to your situation. To build a complete file, including templates for the mixing point and the retention obligation, you can review the topics in the knowledge base.

This article is general information and not legal advice.