The EUDR compliance checklist for small coffee and cocoa importers.

Last updated: 23 August 2026

Before you start: is this even you?

The checklist below is for the operator, the business that first places non-EU coffee or cocoa on the EU market. If you import green coffee or cocoa from a non-EU supplier and sell, roast or use it in the EU, that is almost certainly you, and the duty to file is yours regardless of your size. A downstream business that only buys and resells goods another EU company already placed on the market is a trader, with lighter obligations. If you’re not sure, settle it first with the three-question operator self-check. Everything that follows assumes you’re the operator.

One thing to fix in your mind before step one: the legal responsibility for the due diligence and the Due Diligence Statement stays with you, the operator, at every step, even if you have someone else do the work. No service and no supplier can take that liability off you.

Phase 1: Get set up

Groundwork you can do now, before a single coordinate arrives.

• ☐  Confirm your role and your deadline. Micro and small operators must comply from 30 June 2027; large and medium operators from 30 December 2026. Anchor on the date that applies to you, but note it has moved before, so keep an eye on the deadlines page.
• ☐  Get your EU Login and TRACES access. Statements are filed in the EU’s TRACES system, which needs an EU Login account and your operator profile set up. Sorting this early removes a classic last-minute blocker: the TRACES filing guide walks through it.
• ☐  Have your EORI number ready. As an importer you file under your own operator identity with your EORI number. If you import already you have one; if not, obtain it now.
• ☐  Set up somewhere to keep the file. You’ll retain the due-diligence evidence for five years and must produce it on request, so decide where the geolocation, screening results and legality documents will live, together and retrievable.

Phase 2: Gather the data

The long-lead work. Start this earliest: it moves at the speed of your supply chain.

• ☐  Map your supply chain to the plot. For each supplier and lot, work out who actually knows where the coffee or cocoa was grown: a direct estate, a cooperative, or an exporter in between. That map tells you who to ask.
• ☐  Collect the geolocation of every plot. Not the farm, not the supplier: every production plot, complete. A point with its area for plots of four hectares or less; a polygon for anything larger. This is the hardest and slowest step: the guide on collecting geolocation from suppliers is the playbook, and the geolocation requirements cover the format.
• ☐  Record the production period and origin details. Capture the date or time range of production, and the country and region, alongside the coordinates, not as an afterthought later.
• ☐  Tie every plot back to a lot. Coordinates you can’t connect to the beans you actually bought aren’t usable evidence. Keep the link.

Phase 3: Do the due diligence

Turning the data into a defensible conclusion.

• ☐  Check how each origin is benchmarked. Find each country (and region) on the current low / standard / high country benchmarking list. It sets how much due diligence is expected and whether a lighter route is even possible.
• ☐  Decide whether simplified due diligence applies. Only if all the goods come from low-risk origins and you can show negligible mixing risk. Most importers can’t use it for most of their volume: check honestly against the simplified due diligence guide before relying on it, and remember it never lifts the geolocation or the filing.
• ☐  Screen every plot for post-2020 deforestation. Each plot must trace to land not deforested after 31 December 2020. For shade-grown coffee and cocoa this is where a naive satellite read goes wrong: see why agroforestry gets false-flagged.
• ☐  Check legality at origin. Satisfy yourself the production complied with the relevant laws of the country of production: land use, environment, labour, trade. No satellite answers this leg; it’s documentary.
• ☐  Assess and mitigate to negligible risk, unless Article 13 genuinely applies. Weigh the risk of non-compliance against the regulation’s criteria; where it’s more than negligible, mitigate and re-assess until it isn’t, or don’t place the lot. The bar is negligible risk, and it’s the thing your statement asserts.

Phase 4: File and keep

The statement, and everything that has to survive it.

• ☐  Submit the Due Diligence Statement in TRACES. Before the goods are placed on the market, file the DDS under your operator identity, with the plot geolocation in it. You receive a reference number back: the filing guide covers the reference and verification numbers and where first-timers stall.
• ☐  Pass the reference number down the chain. Your customers downstream need it to discharge their own obligations.
• ☐  Keep the whole file for five years. The geolocation, the screening results, the legality evidence, the risk assessment and any mitigation, stored together, retrievable if a competent authority asks. An inspector audits your reasoning, not just your conclusion.

Phase 5: Keep it current

EUDR is not a one-and-done filing. A little upkeep keeps you defensible.

• ☐  File for each consignment. Due diligence attaches to what you place on the market, not to your company once. New lots need their own statements.
• ☐  Re-check benchmarking and deadlines. The country list is reviewed and updated, and the dates have shifted before. An origin can move from low to standard risk, switching the full assessment back on.
• ☐  Refresh plot data when your sourcing changes. New suppliers, new cooperatives or new plots mean new geolocation to collect and screen.
• ☐  Watch for enforcement signals. Competent authorities check a risk-based share of operators every year, more from higher-risk origins. A serious or repeated infringement can cost you the simplified route and bring real penalties.

The one-line version

If you remember nothing else: get the plot geolocation, screen it honestly against the 2020 cut-off, document a negligible-risk conclusion, and file the statement under your own operator identity, and start the geolocation now, because that is the part that takes a season, not a week. Everything else on this list supports those four things.

This is the work we do, end to end. We take your origin data in whatever shape it arrives, collect and clean the plot geolocation, place each plot against the right country tier and the deforestation record with a type-aware screen that won’t confuse shade-grown agroforestry with clearing, assemble the evidence file behind a defensible conclusion, and (if you want) file the statement in TRACES under your operator identity. What we do not do (what no service honestly can) is take on the legal responsibility, which stays with you as the operator. The full detail behind every step is in the complete importer guide; the method is on how it works.