CUPRIMA's Key Insights, Takeaways and Best Practices for EUDR Compliance
October Forest Month? A Focus on Forest Preservation and EUDR Compliance
As we celebrate October Forest Month, it’s the perfect opportunity to highlight the vital importance of preserving our planet’s forests. The European Union Deforestation Regulation (EUDR) plays a key role in this effort. At CUPRIMA?-EFICO Group’s specialty coffee division, we’re dedicated to promoting deforestation-free supply chains while honouring the rich diversity of flavour and origin.
EUDR compliance remains a controversial and?complex topic -as highlighted by recent developments.?Following weeks of speculation, the?European Commission officially proposed a 12-month extension to the EUDR transition period on Wednesday, 2 October.?This phase-in period aims to ensure proper and effective implementation.?If the European Parliament and the Council approve the one-year extension, it will come into effect on 30 December 2025 for most companies,?on 30 June 2026 for micro and small enterprises. Currently, companies are required to comply by 30 December 2024, while smaller businesses have until 30 June 2025. The Commission has justified the proposed delay based on feedback from international partners, who have indicated varying levels of readiness. While some stakeholders are well-prepared, others have voiced concerns about meeting the initial deadlines.
Along with proposing the postponement, the Commission has issued?new guidance documents, which include?clarifications on the regulation's scope, updated FAQs, and clarifications for?evaluating deforestation and legality risks.?The European Parliament may expedite the proposal through an urgent procedure, as it has done in the past, bypassing the Environment Committee and proceeding directly to a plenary vote.
CUPRIMA : Ready for EUDR Compliance? Anytime and Beyond
At CUPRIMA,?we have been closely monitoring the developments surrounding the EUDR, ensuring we are prepared regardless of when the regulation enters into application. Whether it takes effect later this year or after an extended transition period, we are ready to adapt and comply seamlessly. Our commitment to full compliance with the EUDR remains unwavering. If additional time is granted, we will use it to explore the requirements in greater depth, aiming to deliver even more value.
Leading these efforts is?our Sustainability Team?-a diverse, international, and multilingual group of dedicated women who have been on top of it for some time now, coordinating, initiating, and advancing our green coffee goals. They’ve been driving our progress behind the scenes, ensuring we stay ahead of the curve.?Recently, we sat down with them to gain firsthand insights into their work on EUDR compliance. They shared their field experiences and framed them within the broader coffee landscape, providing valuable takeaways for European roasters and stakeholders.
As experts in EUDR-related matters, our team is perfectly positioned to offer tailored support to our partner producers, exporters, and roasters, guiding them on the path to sustainable, deforestation-free coffee. This aligns with our tailored approach to EUDR compliance: ensuring alignment across the entire coffee value chain, reducing duplicated efforts, and openly sharing insights and practical tips. We are all about personalised strategies, customised advice, and creating bespoke partnerships.
A Conversation with our Sustainability Team Key Insights, Practical Takeaways and Best Practices on EUDR Compliance?for our Partners
I. IMPACT OF EUDR ON COFFEE PRODUCERS
Most people are likely familiar with it by now, but here’s a brief summary. The EU Deforestation Regulation (EUDR) -one of the most stringent and comprehensive environmental laws in the EU,?aims to ensure that 7 key consumer goods?(soy, cattle, oil palm, wood,?cacao,?coffee?and natural rubber)?and some of their derivatives?placed on the EU market?are?free from deforestation.?
For our coffee sector, this translates as follows: Fundamentally, the EUDR dictates that?all coffee entering or leaving the EU must comply with these principles:
The?workload* for mapping coffee plots?under the EUDR largely falls on?farmers and producers with the support of exporters, importers and governmental and non-governmental organisations. The coffee producers with less than 4 hectares of coffee land are required to provide a?GPS pin?marking the center of their plot, while producers with more than 4 hectares of coffee must also use?'polygon mapping',?a more detailed method that outlines the boundaries of each plot.
This?strict, zero-tolerance approach, where?products are either compliant or not,?places significant pressure on importers?(in our sector: importers of green coffee, decaffeinated coffee, roasted coffee, and other coffee derivatives) to ensure accurate and comprehensive data collection.
A. CUPRIMA x COFFEE PRODUCING PARTNERS? ? ? ? ? ? ? ? ? ? ? ? ? ? EUDR COMPLIANCE VS FIELD REALITY
'Farmers?in developing countries are now suddenly?expected to have smartphones?and become?tech-savvy enough to?map?their coffee growing areas?and?interpret satellite imagery',?explains Katrien Delaet. 'While the?technological demands, such as?handling geo-location data,?are already?challenging, the?legal obstacles are even harder to overcome. In many of these regions,?land ownership is often uncertain. As a result, the?EUDR legislation?can feel?disconnected from the practical realities?these farmers face on the ground.'
Katrien continues: 'So maybe let's start by?addressing the in-the-field realities, such as the?challenges related to boundaries and the associated costs of data collection?for?smallholder farmers.?Farmers must be involved in identifying plot boundaries, as they know the land best.?Mapping every farm, especially for smallholders, involves?significant resources,?including time,?human, and financial expenses. Even getting to remote farms is challenging due to?poor infrastructure, and many farmers don’t live near their plots.'
Pauline Vandeputte -Value Chain Expert & Sustainability: 'The EUDR mandates geolocation data for every coffee plot to demonstrate that no deforestation occurred after 30/12/2020. This involves?advanced geolocation techniques?and ground-truthing, often requiring enumerators and?farmers to work together.?There’s a significant gap between the expectations set by EUDR regulators and the realities faced by farmers and data collectors on the ground. In many African countries, farmers frequently rely on informal methods, such as memory or handwritten notebooks, to manage their business data.'
Katrien agrees and concludes: 'Collecting accurate, formalised data for regulatory purposes is?quite a challenge.?The process is more effective when personal relationships are built, because qualitative insights are more easily gathered when data collectors build a relationship with farmers. Something that we at EFICO and CUPRIMA?are fortunately used to doing naturally and well and enjoy doing over the years,?building purposeful partnerships.?This is always beneficial, but especially needed right now.'
Camila Perez, who joined the Sustainability team very recently as?GIS Data & Sustainability Officer, shares: 'I was quickly thrown into the deep end! At the moment, my role involves?coordinating the collection and analysis of GIS datasets,?assessing deforestation risks with external partners, and?reviewing critical cases with EFICO & CUPRIMA's coffee-producing partners. Later on, I will help refine internal methods, enhance risk analysis, and design systems to track our social and environmental impact. I’ll also be involved in setting up new data collection projects from farm to customer, focusing on full traceability and sustainability. I’m looking forward to assisting with hands-on work in the countries of origin!'
B. CUPRIMA'S TAKEAWAYS
→?Any EUDR compliance effort must consider the?socio-economic realities?faced by smallholder farmers, who risk losing market access if they cannot meet the requirements.?Developing an inclusive approach should be a priority?when building sustainable supply chains.
→?While technology -such as satellite data, is crucial for compliance, manual interventions and human judgment are often needed to correct inaccuracies and ensure reliable results;?ground truthing is a must!
→?These challenges and insights emphasise the?need for realistic and context-sensitive approaches to EUDR compliance, balancing regulatory demands with the practical needs and limitations of farmers and supply chain participants, specific to each country of origin.
→?The EUDR regulation is still evolving, with several grey areas remaining in the legislation. Additionally, many countries of origin face ongoing political and economic instability, presenting significant challenges.?A one-size-fits-all approach simply doesn’t exist.
C. CUPRIMA'S APPROACH
→ CUPRIMA’s approach emphasises enhancing supply chain transparency while providing tailored support through direct contact and dialogue with our producer partners. Recognising the pressures this regulation can impose on farmers, our strategy is flexible, collaborative, and progressive.
→ CUPRIMA?works closely with its partner producers to ensure compliance without adding unnecessary pressure. We provide clear data requirements for geolocation, traceability, legality, and harvest periods.
→?To avoid duplicating efforts and incurring unnecessary verification costs, CUPRIMA allows suppliers to submit risk assessments conducted by other approved service providers. Our approach is tailored with tiered engagement levels, ranging from basic data submission to comprehensive risk assessments. By adapting to each supplier’s needs, we ensure compliance while minimising additional burdens.
→?Sustainability has been at the heart of EFICO and CUPRIMA?since the beginning. With the new EUDR regulations on the horizon, we had?expanded our team with two full-time sustainability experts. They are here to assist our partner farmers and roasters in navigating these new regulations, helping us all maintain the highest standards of sustainability.
II. WHAT DOES IT MEAN FOR SPECIALTY ROASTERS, FROM SMALL TO LARGE??
Thibault Chauvin -specialty green coffee specialist: 'Now that you understand the?work required both in the field and during the import of specialty coffee for the European market, let’s summarise the implications for European specialty roasters: Companies lacking strong policies on sustainable sourcing and deforestation will face significant challenges.?For us this means simply stepping up our CUPRIMA?efforts.?The EUDR aligns with our sourcing strategy and?standards, which we’ve been investing in from the beginning, even before these regulations were introduced.'
领英推荐
A. CUPRIMA?TEAM-UP WITH SPECIALTY COFFEE ROASTERS VS EUROPEAN SPECIALTY COFFEE BEAN SCENE?
'As an importer', Thibault?explains?'we?must ensure?that?all coffee?beans are traceable to the specific plot of land where they are grown. This involves?providing geolocation?and?legality data for the production areas. We also need to?assess and mitigate the risk of our coffee?contributing to deforestation?by thoroughly examining supply chains. To validate that no deforestation occurs in our sourcing areas, we use a combined approach of satellite imagery and artificial intelligence. EFICO & CUPRIMA?team?up?with a private service provider for satellite images, integrating open-source data such as Global Forest Watch Pro and Whisp.'
Thibault: 'Once documentation confirms there is no or minimal?risk of non-compliance, CUPRIMA must submit a Die Diligence Statement (DDS) via the EU Information?TRACES .?This submission?generates a DDS reference number, which is required for the product to be released for circulation within or export from the EU market.'
Thibault advises: 'Just a heads-up -the EUDR information system is still under development. According to the latest update, registration for using the system will start in?November 2024, with full access available to all users in December 2024.'
'Once the coffee is cleared by customs for free circulation in the EU, the requirements change',?Thibault explains. 'Large downstream operators?(such as processors, roasters or decaffeinators,) must meet?similar due diligence obligations?and?submit a DDS?based on a previous reference number. In contrast,?SMEs are not required to submit a due diligence declaration for products already covered by another economic operator. They only need to provide the reference number of the existing declaration if requested.'
'Once the EUDR enters into application',?Thibault continues 'CUPRIMA will?consistently include our DDS numbers on every invoice to directly demonstrate the compliance of the beans we sell, ensuring automatic and direct information transfer to our small and medium-sized coffee roasters in Europe.?Additionally, larger customers will receive a security token for access to the EU platform and automated transfer of geolocation-data.
B. CUPRIMA'S TAKEAWAYS
→?The EUDR stands out from other legislation by being product-based and focusing on prohibitions. In contrast, the CSDDD (Corporate Sustainability Due Diligence Directive) for example requires companies to address human rights and environmental risks in their supply chains, while the German Supply Chain Act (LkSG) emphasises companies' responsibility to ensure due diligence and prevent harm in their supply chains. Both the CSDDD and LkSG focus on best efforts to manage risks, whereas the EUDR takes a stricter approach by banning products linked to deforestation.
→?If specialty roasters?process coffee beans after the enforcement date of December 30, 2024, they must provide evidence that the coffee?was?imported into the EU before this date?(as per order request, transport document, or invoice). Or in case?the coffee is made with beans?introduced to the market after December 30, 2024,?they must demonstrate that the beans are deforestation-free by providing the respective DDS number.→?While?certified coffee?ensures traceability up to the farm level, it does?not necessarily guarantee EUDR compliance.?Certification?is a significant step in the right direction, but it?is not sufficient for geo-data requirements. Many certification organisations, such as Rainforest Alliance and Fairtrade, have developed support systems to help demonstrate compliance.
→?What does this mean for?specialty coffee??While?traceability is a crucial aspect?and assurance for all specialty coffee, the resources required to comply with the EUDR are substantial relative to the volumes sourced. This includes the?burden of data collection, risk assessment, and validation.?As a result, the specialty sector faces a significant challenge.
→?The?workload*?required to achieve EUDR compliance is?substantial,?and its?impact on the coffee industry is immense, affecting nearly all supply chain actors. Non-compliance could result in fines of up to 4% of annual turnover, potential confiscation of shipments, and the loss of access to a market that represents half of global coffee consumption.
C. CUPRIMA's APPROACH
→?CUPRIMA's approach focuses on?enhancing supply chain transparency.
→ At?CUPRIMA, we collaborate?closely with our partner roasters,?offering clear data requirements to help facilitate compliance with the EUDR.
→?All coffee imported on or after the EUDR's enforcement date (30?December 2024, or 30 December?2025, if the one-year phase-in period is approved by Parliament and Council) will be subject to EUDR regulations. However, coffee that CUPRIMA has in stock prior to this EUDR enforcement date will not be subject to these regulations.
→?CUPRIMA?makes compliance easy and hassle-free by streamlining the process. Upon the enforcement date of the EUDR?legislation -starting December 30, 2024, or December 30, 2025, if the one-year phase-in period is approved by Parliament and Council,?every CUPRIMA?invoice will include the DDS reference number from the EU IT platform for coffee imported and cleared after this date. This ensures compliance with geolocation and legality requirements, while?batches cleared before this date are exempt. Additionally, our?larger customers will receive a security token to access the EU platform.
→?If needed, CUPRIMA is available to provide detailed information to demonstrate compliance during controls or audits by your competent authorities.
Are you still having a little trouble seeing the forest for the trees?
Then you can always consult the updated?FAQs published by the European Union ; they?are particularly insightful for a better understanding.
Our sustainability team has been actively engaged as well. Here is a careful selection of the questions we've been asked most frequently in recent weeks.
CUPRIMA's?FAQ's - curated by our Sustainability Team
How does CUPRIMA collect the necessary geolocation data? Geolocation data collection is managed by our suppliers, as CUPRIMA does not own farms or plantations. However, we work closely with our partner producers?to ensure they understand and meet the stringent requirements of the EUDR. We provide detailed guidelines, along with ad-hoc training sessions, to help them comply. Additionally, CUPRIMA offers direct support to origins that may lack the necessary knowledge and capacity, particularly those at higher risk of EU market exclusion.
When and how will?EFICO share geolocation?data with clients? CUPRIMA will share geolocation data with clients?whenever the EUDR legislation?enters into application?-either on December 30, 2024, or December 30, 2025, if the one-year phasing-in period is approved by Parliament and Council. - For large clients, relevant geolocation data in GeoJSON format will be accessible via the EU's IT system (TRACES ) using the DDS number and security token provided on the CUPRIMA invoice. - For SME clients, storing geolocation data is not mandatory. The DDS number provided on the CUPRIMA invoice will be sufficient to meet the requirements. Heads up!?For coffee placed on the market before the EUDR enforcement date?(December 2024 or December 2025, depending on the approval of the one-year phasing-in period by the Parliament and Commission), the CUPRIMA?invoice?will specify that customs clearance was completed prior to the enforcement date. Therefore, DDS and geolocation data will not be mandatory for these shipments.
Can CUPRIMA?share geolocation data for products purchased in the past? In compliance with privacy and data security regulations, CUPRIMA is unable to provide geolocation data for purchases of beans that were customs cleared before the EUDR enforcement date, which is either December 30, 2024, or December 30, 2025, if the one-year phasing-in period is approved by Parliament and Council.
What information will CUPRIMA provide prior to shipment? Due to time constraints and the need to gather and pre-validate datasets from the origin, we do not typically provide geolocation data in advance for clients for whom we handle customs clearance. However, exceptions may be made for specific origins or suppliers if clients have concerns, which will be reviewed on a case-by-case basis.
How will we know if the coffee sold/bought is EUDR compliant? EUDR compliance is determined by the customs clearance date, not the arrival date in the EU.?As a result, in early 2025 (or early 2026 if the one-year phasing-in period is approved by Parliament and Council), clients may receive coffee lots with or without a DDS number, depending on when customs clearance was completed for each lot. This will be clearly indicated on the CUPRIMA invoices.
How does CUPRIMA ensure traceability from physical coffee to geolocation coordinates? For each geolocation dataset submission, suppliers must inform CUPRIMA of the data's source (whether collected by the farmer, verified by an external third-party auditor, or obtained through other means) and provide supporting documentation. For certified coffee, we use traceability systems from independent certification bodies or national systems in advanced producing countries (e.g., Costa Rica). CUPRIMA is also committed to building a comprehensive traceability system for its entire value chain as part of its sustainability strategy.
What happens if products are found to be non-compliant? To prevent non-compliance, we encourage suppliers to share their geolocation datasets with us for pre-validation before finalising contracts with CUPRIMA.?This enables us to detect potential issues even before the crop season begins. Once contracts are finalised, suppliers must submit geolocation and legality information at least one month before shipment. If deforestation is discovered on declared coffee plots, suppliers are notified and may challenge the findings with supporting evidence, such as geotagged photos, drone footage, or satellite images. If non-compliance is confirmed, suppliers must segregate the affected products and provide proper documentation. In extreme cases, if non-compliance is detected upon arrival in the EU, the products will be replaced with compliant coffee, and the non-compliant coffee will be redirected to other markets.
When will CUPRIMA be ready to comply with the EUDR? Our internal Due Diligence System will be fully operational as from the date of enforcement.?According to the latest update, the EU IT system is expected to go live in November 2024 for registrations, with testing starting in December 2024. This means we will not be able to provide DDS numbers until then. As outlined in the Regulation, DDS codes will be available by December 30, 2024, unless the proposed 1-year phase-in period is approved by Parliament and the Council, in which case the DDS codes would become available by December 30, 2025.
FOOTNOTE, DEFINITIONS & REFERENCES
*The workload for EUDR compliance is immense. but to keep it brief, in a nutshell: 1. Mapping the entire supply chain 2. Geolocating all farms (polygons for farms >4 hectares, GPS for <4 hectares) and document legality 3. Conducting a risk assessment on deforestation up to December 30, 2020 4. Establishing a batch chain of custody 5. Providing a due diligence statement 6. The latter must accompany every container imported into the EU as of December 2024.
Definition SME according to Article 3 of Directive 2013/34/EU of the European Parliament and of the Council : Enterprises which on a consolidated basis, do not exceed the limits of at least two of the three following criteria on the balance sheet date of the parent undertaking:? (1) Balance sheet total: EUR 20 000 000; (2) Net turnover: EUR 40 000 000; (3) Average number of employees during the FY: 250.
Definition Ground Thruth :?Ground truth?is information that is known to be real or true, provided by direct observation and measurement.
EUROPEAN UNION -?Press Release dd October 2, 2024
EUROPEAN UNION -?Guidance on EU Deforestation Regulation
EUROPEAN UNION -?Proposal?for a Regulation amending Deforestation Regulation as regards the date of application
EUROPEAN UNION -?Frequently Asked Questions - Deforestation Regulation
EUROPEAN UNION -?EU Deforestation Union - An Opportunity for Smallholder
EUROPEAN UNION -?SME Factsheet