You can’t trace coffee retroactively.

Last updated: 23 August 2026

Two clocks, and only one of them is yours to set

The regulatory clock is fixed and public: large and medium operators must comply from 30 December 2026, and micro and small operators from 30 June 2027, against a deforestation cut-off of 31 December 2020 that does not move. We keep those dates current in the deadlines guide.

The second clock is the harvest, and it answers to the season, not to Brussels. Coffee and cocoa are gathered in a window each year; once that window passes, the beans are pulped or fermented, dried, bulked, milled and bagged. The plot-level identity you need for the regulation is easiest to capture at the very start of that chain and hardest at the end. The two clocks are not aligned, and it is the harvest, not the deadline, that decides when you can act.

Why traceability can’t be reconstructed later

The EUDR does not ask where your supplier is. Article 9 asks for the geographic coordinates of every plot of land where the coffee or cocoa was produced, with the date or range of production: the plot, not the farm and not the cooperative. We set out exactly what that means in the geolocation requirements guide.

Geolocation is an attribute of the lot while the lot is still distinct. Blend first, ask later, and the question has no answer.

Picture a cooperative that gathers cherry from four hundred smallholders. At harvest, each delivery can still be tied to a farmer and a plot. Once those deliveries are combined into a drying batch and then an export lot, that link is gone, not misplaced, but genuinely untraceable, because the physical beans from four hundred plots are now one indivisible mass. No amount of paperwork in spring 2027 rebuilds a plot list for a lot that was blended in late 2026. This is why “we’ll sort the data out before the deadline” is the one plan that cannot work: the deadline is after the harvest, and the data lives in the harvest.

Which harvest your 2027 imports actually come from

Work backwards from when you place goods on the EU market. Coffee and cocoa contracted now, gathered at the coming harvest and shipped over the following months, is what you will be importing through 2027, the goods that fall under the regulation for small operators. The harvest that supplies your first compliant imports is, for most origins, the one happening around now through early 2027.

The exact window varies by origin and hemisphere, and you should map it to your own suppliers rather than to a generic calendar, but the shape is consistent: a main harvest of a few months, followed by processing and export. If your sourcing plan for 2027 depends on beans gathered this season, the geolocation for those beans has to be requested this season, while the cooperative can still connect a delivery to a plot.

The test is simple: for every origin you will import in 2027, has the plot data been collected at the harvest that produced it? If not, that is the task in front of you now, not next spring.

The quieter risk: being last in the queue at origin

There is a second-order reason not to wait, beyond the physical one. Cooperatives and exporters are being asked for plot geolocation by all of their buyers at once, and the effort of mapping thousands of smallholder plots is real. It is reasonable to expect that the buyers who ask early, and who ask clearly, get served first, and that an importer who turns up late, in the middle of the harvest rush, with a vague request, is the one left without usable data. We would not overstate this as a certainty, but the direction is plain: early and specific beats late and general.

What to do this season

The work now is not the filing: that comes later, and quickly, once the data is in hand. The work now is securing the data while it exists:

• Map your chain to the plot. For each origin you intend to import in 2027, identify the cooperatives or producers and, through them, the plots. The supplier geolocation guide covers how to ask, and the collection mistakes that quietly sink a filing.
• Ask at, or before, the harvest. Put the geolocation request in now, for this season’s crop, so the cooperative captures it while deliveries are still attributable to a farmer and a plot.
• Screen the plots as the data arrives. There is no reason to wait for a complete set: each plot can be checked for post-2020 deforestation as soon as its coordinates are in, so a problem surfaces while you still have room to respond, not at the border. You can see what that check produces in the sample due-diligence file.
• Keep the record. Geometry, assessment, evidence and, once filed, the reference number are kept for the five years the regulation requires, assembled once, at the harvest, rather than scrambled together at the deadline.

Treated this way, June 2027 stops being a cliff and becomes a formality: by then the data has long been collected, the plots screened, and the statements ready to file. The operators who struggle will be the ones who confused the deadline with the start date.