October Forest Month
A Focus on Forest Preservation and EUDR Compliance

CUPRIMA: Ready for Compliance
Anytime & Beyond

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 for EUDR Compliance for our Partners

I. IMPACT OF EUDR ON COFFEE PRODUCERS

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:

• Deforestation-Free: Ensuring that coffee products purchased, used, and consumed by Europeans do not contribute to deforestation or forest degradation, both within the EU and globally.
• Compliance with Local Legislation: Coffee must adhere to relevant legislation in its country of production -including laws on environment, land use, forest governance, labour, tax, and human rights.
• Due Diligence: Each shipment must be accompanied by a due diligence statement, confirming minimal risk of non-compliance with EUDR requirements.

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 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/CUPRIMA since the beginning. With the EUDR regulations on the horizon, we have expanded the 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 COFFEE 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.’

A. CUPRIMA TEAM-UP WITH SPECIALTY COFFEE ROASTERS
VS EUROPEAN SPECIALTY COFFEE BEAN SCENE REALITY 

‘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 (or 30 December 2025 – if the phasing-in periode of 1 year gets approved by Parliament and Council), they must provide evidence that the coffee was placed on the EU market 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 (or 30 December 2025 – if the phasing-in periode of 1 year gets approved by Parliament and Council), 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 geolocation-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.