Article
Ensuring Traceability: Cocoa and Coffee in EUDR Compliance
By Caoilinn O’kelly
October 26, 2026
Key takeaways
The EUDR applies from 30 December 2026. Micro and small operators established by 31 December 2024 have until 30 June 2027, and soluble coffee is covered from 30 December 2027.
Cocoa and coffee are mostly grown by smallholders, so collecting plot-level geolocation data and keeping origins separate are the main traceability challenges.
Importers placing cocoa beans or green coffee on the EU market are operators, and they carry out due diligence and submit DDSs in TRACES.
Roasters and chocolate makers buying from importers are often First Downstream Operators, who must collect and keep DDS reference numbers for at least five years.
Ensuring Traceability: cocoa and Coffee in EUDR compliance
The European Union Deforestation Regulation (EUDR) aims to minimise the EU's contribution to global deforestation and forest degradation. It applies from 30 December 2026, and from 30 June 2027 for micro and small operators established by 31 December 2024.
The EUDR covers seven commodities linked to deforestation: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Cocoa and coffee face some of the biggest traceability challenges, because both are grown largely by smallholder farmers in tropical regions. This article looks at what the EUDR means for these two sectors in practice.
New to the EUDR? Read our articles What is the EUDR and what does it mean for companies? and The Ins and Outs of the EUDR first.
Which cocoa and coffee products are in scope?
Cocoa: cocoa beans, cocoa shells and husks, cocoa paste, cocoa butter, cocoa powder, chocolate and other food preparations containing cocoa.
Coffee: coffee (whether or not roasted or decaffeinated), coffee husks and skins, as well as coffee substitutes containing coffee.
New from 30 December 2027: Delegated Regulation (EU) 2026/2102 adds soluble coffee to the scope. Companies producing or trading instant coffee have one extra year, but should include it in their planning now.
Cocoa: what makes it challenging
The EU is the world's largest cocoa importer, accounting for around 60% of global cocoa imports. Most of this cocoa comes from West Africa, where production is spread across a very large number of small family farms. The EU is also a major cocoa processor, and products made in the EU and then exported are in scope too.
The main practical challenges for cocoa are:
Collecting geolocation data for every plot. Operators need geolocation for every plot where the cocoa was grown. A single point is enough for plots of up to 4 hectares, and larger plots need the full boundary.
Keeping cocoa of known origin separate. Every product must be linked to the plots it came from, so cocoa of known origin cannot be mixed with cocoa of unknown origin along the way, for example at cooperatives or exporters.
Showing legal production. Operators must also show the cocoa was produced in line with local laws, including land use rights, labour rights and the rights of Indigenous peoples.
Coffee: what makes it challenging
According to the FAO, smallholdings make up as much as 80% of coffee farms worldwide. That makes plot-level traceability a large data-collection task, especially where farmers have limited access to digital tools.
The main practical challenges for coffee are:
Gathering data from many farms. Coffee often passes through several intermediaries before export, so geolocation data has to be gathered from many farms and passed along the chain.
Keeping origins separate. Coffee lots from verified and unverified plots must not be mixed.
Planning for soluble coffee. Companies making soluble coffee need to prepare for its addition to the scope in 2027.
Where does your company sit in the chain?
For most European cocoa and coffee companies, the key question is their role:
Operators: importers bringing cocoa beans or green coffee onto the EU market. They carry out due diligence, collect the plot-level geolocation data and submit a due diligence statement (DDS) in TRACES.
First Downstream Operators: roasters, chocolate makers and food manufacturers buying from those importers. They don't submit a DDS themselves. They must collect and keep the DDS reference numbers from their suppliers for at least five years, linked to the right products.
Traders and companies further down the chain: retailers and wholesalers. They keep supplier and customer records for at least five years.
How Simvia supports cocoa and coffee companies
Many roasters, chocolate makers and food manufacturers are First Downstream Operators. For them, the challenge is collecting DDS reference numbers from many importers and suppliers and keeping them linked to the right products. Simvia gives you one place to:
Tag the cocoa and coffee products and suppliers that fall under the EUDR.
Map the supply chain of each product.
Request DDS information from suppliers based on rules you set.
Receive DDS documents and reference numbers in a simple way from suppliers. Simvia extracts the key details from shared documents using AI.
Keep audit-ready records for five years or more, with an Excel export so you can respond quickly to authorities and retailers.
What to do next
With the EUDR applying from 30 December 2026, cocoa and coffee companies should take three steps:
Confirm which of their products are in scope, including soluble coffee from 2027.
Determine their role for each product.
Agree with their suppliers how DDS reference numbers will be shared.
Want to know how Simvia can help you prepare?
