The European Union Deforestation Regulation (EUDR) continues to reshape the global coffee industry, setting new benchmarks for sustainability and traceability. However, as compliance deadlines draw near, the European Commission has proposed key changes to make the law more accessible — particularly for micro and small enterprises (SMEs).
These updates could transform how small roasters, traders, and cooperatives across producing countries engage with the EU market, offering some relief amid complex reporting and traceability requirements.
What is the EUDR?
Adopted in December 2022, the EUDR aims to eliminate products linked to deforestation from EU supply chains. It covers commodities such as coffee, cocoa, soy, palm oil, cattle, timber, and rubber. Companies importing these products into the EU must prove they are deforestation-free, legally produced, and fully traceable to their origin.
The legislation was widely praised for its environmental ambition but quickly drew criticism for its complexity, particularly from smallholder coffee producers in developing countries. Critics argue that the EUDR’s strict due diligence requirements and benchmarking system — which classifies countries as low, standard, or high risk — could unfairly restrict access for farmers in emerging economies.
EUDR timeline for the coffee sector
Originally, the EUDR was scheduled to take effect on 30 December 2024 for all companies. However, after strong industry pushback, the Commission approved a one-year delay, extending compliance deadlines to December 2025 for large enterprises and June 2026 for SMEs.
Now, following ongoing IT issues related to data reporting systems, the Commission has proposed a further simplification for small businesses — pushing their compliance deadline to December 2026. Large companies, meanwhile, will maintain the December 2025 deadline but receive a six-month grace period.
If approved, the proposal would also exempt certain actors, including smallholder farmers and downstream companies, from submitting due diligence statements (DDS).
Why EUDR simplifications are being proposed
The EUDR’s digital infrastructure — including the EU’s centralized IT system for traceability data — has faced significant delays. Many small operators lack the resources to collect GPS coordinates, farm boundaries, and legal documents required for compliance.
To ease this transition, the Commission proposed simplifications that would reduce reporting obligations for micro and small coffee businesses.
“We see the proposal as a realistic step towards a more balanced implementation of the EUDR,” says Héctor, Head of Quality and Sustainability at a specialty coffee importer in Spain. “For small roasters, it means simplified obligations and more time to adapt”.
Under the new framework, importers will bear the main responsibility for due diligence, while small roasters and downstream companies will focus on traceability and sustainability verification rather than direct compliance filings.
How the EUDR defines small coffee businesses
According to the European Commission, a micro-enterprise is defined as having fewer than 10 employees and annual revenue below €2 million. A small enterprise has up to 50 employees and revenue under €10 million.
For such companies, the proposed EUDR updates would mean:
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No requirement to submit due diligence statements directly.
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Obligation to maintain traceability and supplier data for five years.
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Ability to rely on importers’ DDS records for verification.
Larger roasters and brands that import directly will still be required to file their own due diligence statements and prove that all upstream supply chain actors comply with the EUDR.
Implications for coffee roasters and importers
These proposed EUDR changes could bring meaningful relief for smaller coffee businesses, particularly specialty roasters that rely on smallholder suppliers in Africa, Asia, and Latin America.
For many, the challenge has been not intent but infrastructure. Proving deforestation-free origins requires digital land mapping, geolocation data, and verified supplier records — all of which are costly and time-consuming for small actors.
However, while simplifications ease administrative burden, they also raise concerns about data consistency. “If only part of the supply chain complies, traceability breaks down,” says Harry, founder of OpenAtlas, a satellite-based deforestation monitoring company. “Simplifications help in the short term but could weaken the transparency the EUDR was designed to achieve.”
Risks and benefits of the EUDR simplifications
The benefits are clear:
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More time and flexibility for SMEs to prepare.
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Reduced bureaucracy for small roasters and downstream companies.
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Fewer reporting requirements for smallholders without advanced technology.
Yet, the drawbacks remain significant. The risk of creating a two-tier compliance system could complicate relationships between smallholders and large importers.
Even if smallholders are exempt from submitting due diligence statements, buyers will still require the same data to comply with their own EUDR obligations. “The larger importers will continue to demand full traceability,” Harry explains. “So even if the paperwork is simplified, the expectations remain.”
The broader context: balancing sustainability and trade
The EUDR’s mission — to eliminate deforestation-linked commodities — aligns with the EU’s Green Deal and global sustainability targets. However, balancing environmental goals with trade equity remains challenging.
Countries like Indonesia and Ethiopia have publicly criticized the EUDR, calling it “discriminatory and punitive”. They argue that the regulation risks marginalizing millions of small farmers who lack access to digital tools or compliance training.
In August 2024, organizations such as Fairtrade International, Global Coffee Platform, and the European Coffee Federation warned that without significant flexibility, the EUDR could unintentionally shrink smallholder participation in global coffee trade — particularly in countries where the EU buys 30% or more of exports.
What small roasters should do next
Even with simplifications, small coffee roasters still play a key role in ensuring transparency across the supply chain. The most practical steps include:
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Partnering with certified importers who already conduct EUDR due diligence.
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Maintaining traceability records for each batch and supplier.
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Verifying farm-level data through trusted exporters and cooperatives.
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Engaging in sustainability programs that support digital mapping and farm registration.
Héctor emphasizes, “Micro and small roasters should not see the EUDR as a threat but as a framework for traceability and trust. The new changes make it more manageable — but accountability will still matter.”
The road ahead for EUDR and coffee
The EUDR will continue to evolve as policymakers balance environmental priorities with economic realities. The latest proposals suggest the EU is willing to adapt implementation timelines and simplify requirements — but not abandon its core mission.
As the global coffee industry moves toward a more transparent, traceable future, the challenge will be building systems that include everyone — from multinational importers to smallholder farmers.
“The deforestation footprint won’t disappear because the rules are softened,” says Harry. “Real progress depends on creating scalable, affordable tools that let small actors participate — not just comply”.
In short, the EUDR marks a turning point for coffee’s sustainability journey. Whether simplified or not, it’s reshaping how the world grows, trades, and consumes one of its most beloved commodities.
Helena Coffee Vietnam: Committed to Sustainable and Transparent Coffee
At Helena Coffee Vietnam, sustainability and traceability are core to everything we do. As one of Vietnam’s leading producers and exporters of specialty Robusta and Arabica, we are preparing to fully align with EUDR standards — from farm mapping to digital traceability.
Working directly with smallholder farmers in the Central Highlands, we promote deforestation-free farming, transparent sourcing, and innovative processing such as Anaerobic Fermentation and Yellow Honey.
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