EUDR: green light, red tape

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As the European Parliament agrees to postpone the EUDR, non-governmental organisations weigh in on what this means for the global coffee industry.

The European Union (EU), a leading global economy, made a significant move towards forest protection with the EU Deforestation Regulation (EUDR), agreed upon by the Commission, Council, and Parliament in December 2022.

However, as voted by the European Parliament in November 2024, the regulation’s timeline has been extended by 12 months with enforcement now set for December 2025 for large operators and June 2026 for micro and small enterprises, pending negotiations.

When enforced, the EUDR will require companies to provide geodata, traceability information, and proof of legal compliance to ensure products such as coffee, cocoa, and palm oil imported into the EU are not linked to deforestation.

Non-governmental organisations (NGOs) that initially called for a delay, including International Coffee Partners (ICP), have welcomed the Parliament’s decision, citing a lifeline for smallholder farms that gives them a chance to build technical capacity for a smooth transition.

On the other hand, the Rainforest Alliance – although agreeing the postponement can help smallholders transition to this new framework – says the delay is a setback that mostly benefits the corporate entities who haven’t invested at scale. 

Red tape

Fanny Gauttier, Public Affairs Lead at the Rainforest Alliance, says the NGO has backed the implementation of the EUDR since before it was proposed. She says the organisation believes legislation is necessary to ensure a level playing field and drive widespread change.

“We’ve always been in favour of the EUDR. As an NGO with a certification program, we believe legislation is necessary to drive change at scale. Certification is a valuable tool, but its reach is limited,” she says.

Until 2020, many companies made voluntary commitments to tackle deforestation, but those commitments were not met. Therefore, this highlighted the need for legislation to hold companies accountable and ensure compliance.

Overall, the adoption of the EUDR represented a huge step forward in global environmentalism because, according to Gauttier, it was ambitious.

“The final regulation closely aligned with the original proposal. It wasn’t watered down during the legislative process, which makes it a great example of a successful legislative outcome,” she says.

Despite the delay providing a potential lifeline to smallholders, Gauttier says it serves to benefit those who haven’t been working as intensively to prepare for implementation.

“While it also gives more time to those who were ready, it really benefits those who hadn’t invested at scale,” she says. “On the other hand, from a smallholder farmer perspective, the delay provides more time to work with them and ensure they produce products that align with the EUDR, which is one positive aspect.”

The main issue observed by the Rainforest Alliance is that the European Commission had not delivered on its commitments to support implementation, such as providing guidance and updated FAQs sufficiently ahead of the initial date of implementation.

“As a result, it was becoming increasingly difficult to imagine how the regulation could be implemented on time,” says Gauttier.

“By October 2024, it was clear that continuing on the current path wasn’t feasible.”

Even though the Parliament has agreed to a postponement, many companies are concerned the EU institutions won’t reach an agreement before the end of the transition period, and that the EUDR will apply at the end of December 2024

“This creates a lot of uncertainty, as companies don’t know what to expect in terms of the implementation date. Initially, they thought the regulation would take effect by the end of this year, then the Commission proposed a 12-month postponement, and everyone thought that was the way forward,” she says.

“As you can imagine, for a company, not knowing whether they’ll need to implement the regulation at the end of the year or in a year changes a lot about what they need to do. It creates a lot of uncertainty.”

During the 12-month postponement, in the short term the Rainforest Alliance’s strategy is two-fold. In terms of advocacy, the NGO is mobilising the companies it works with to engage directly with EU decision-makers, as the corporate sector tends to have more political sway.

And in terms of implementation, the Rainforest Alliance will continue working with its certificate holders – especially smallholder farmers – to ensure they are ready.

“Now that we have more time, it gives us an opportunity to further support them and ensure they are fully prepared,” she says.

In the future, Gauttier says the EU can set a precedent to stronger global commitments to stopping deforestation, as decisions like this depend on the political situations in major markets.

“Once we have more certainty about the implementation of the EUDR, it could help support the introduction of similar requirements in other governments, which would be ideal,” she says.

“At the Rainforest Alliance, we had already prepared for the start of the implementation by the end of this year. Moving forward, we will continue to develop our systems and support the smallholder farmers in our network.

“For most companies, they should have the opportunity to register in the information system soon and begin uploading due diligence statements. Hopefully, this will allow them to test the system before the actual implementation. We’ll keep encouraging our partners to be ready on time.”

No one left behind

Meanwhile, the ICP has welcomed the postponement to give smallholders more time to comply and build the technical capacity for a smooth transition.

Anders Thorén, Head of Corporate Communications at Löfbergs – one of the seven members of the ICP, says the steps taken by the EU to address the issue of deforestation have been positive, with the purpose of the EUDR aligning closely to the company’s long-standing commitment to sustainability.

However, like Gauttier and many others in the coffee sector, Thorén says the company experienced uncertainties regarding its implementation, especially for smallholder farmers.

“The timeline was tight, and clear guidance on reporting, control schemes, and other essential aspects was lacking,” he says.

“The necessary systems and support simply weren’t in place, which created potential risks for coffee farmers, roasteries, and consumers.”

Thorén believes the delay reflects a recognition of the challenges raised by stakeholders worldwide and shows a commitment to making the regulation practical and effective for everyone involved.

“The extended timeline provides an opportunity to implement the regulation more effectively by fostering stronger dialogue and collaboration across the value chain,” he says.

He adds that Löfbergs has already made significant progress, investing in innovative solutions for traceability such as Era of We – sustainability software for farmers, coffee roasters and others to ease transition to EUDR – as well as data management and compliance.

“Together with Era of We, we’ve developed a solution to address this challenge,” says Thorén.

“While the delay allows companies to refine their processes, it doesn’t alter our commitment – we remain fully focused on achieving the regulation’s goals without pause.”

According to Thorén, smallholder farmers require support in three critical areas to transition to deforestation-free coffee supply chains: financial assistance to adopt traceability systems and sustainable farming practices, capacity building through training programs that enable compliance with regulatory standards, and investments in technical infrastructure, including geodata tools and other necessary systems.

“Ensuring access to these resources is vital for their success,” he says.

Moreover, the EUDR as it is currently designed is challenging for some smallholders as infrastructure varies significantly across regions, with some countries having robust national traceability systems while others lack such frameworks entirely.

“These differences highlight the need for a flexible and inclusive approach,” says Thorén.

“Despite the challenges, collaboration across sectors is the way forward. Unified standards, adapted to regional realities, can drive meaningful change while ensuring smallholders are supported throughout the transition.”

Above all, Thorén does not foresee any environmental setbacks with the extended timeline. Rather, he sees this as an opportunity to strengthen the value chain.

“The extended timeline is an opportunity to strengthen implementation and mitigate risks. The international community can support this by fostering transparency, promoting sustainable practices, and enhancing collaboration across supply chains.”

Empowering smallholders

Norbert Schmitz, Managing Director at 4C, an internationally recognised third-party certification system for the coffee sector, says although the postponement of the regulation was not unexpected as prerequisites from the EU were not in place for timely implementation, many of 4C’s system users are already well-prepared thanks to its proactive EUDR solution.

He adds the postponement is still dependent on the outcomes of the trilogue negotiations between the European Parliament, the Council, and the Commission to reach a final decision, but 4C is prepared to support its partners regardless of the outcome.

“At 4C we are fully prepared for any scenario,” says Schmitz. “We are ready to support organisations in meeting EUDR requirements effectively.”

Schmitz iterates this is not the time to become complacent as deforestation-free supply chains remain a critical priority, and the regulation will still take effect soon.

A cornerstone of the 4C certification, according to Schmitz, is the no-deforestation criterion established with a 2006 cut-off date and now updated to align with the requirements of the EUDR. 4C had implemented the EUDR requirements in its certification standard at the beginning of 2024. As a result, he says its partners are equipped to meet the regulatory requirements once implemented.

As part of this solution, 4C utilises remote sensing technologies for robust risk assessments and verification of deforestation-free coffee production.

“Legality requirements of the EUDR are covered in the 4C system and will be adopted accordingly once further guidance is available,” he says.

He adds that traceability is a key feature of the system, with the 4C Portal designed for seamless tracking along the supply chain.

Its EUDR solution is built on the organisation’s sustainability certification program and provides a traceability system to ensure transparent sourcing and compliance, along with risk assessments from partner Global Risk Assessment Services to identify deforestation risks.

“The organisation’s approach offers strong risk mitigation through independent third-party audits, which verify compliance and build confidence in the integrity of certified supply chains,” says Schmitz.

“We do also see that roasters outside the EU have started to ask specifically for EUDR coffee, as they are committed to deforestation-free coffee as well,” he says. “Deforestation-free coffee goes along  with a lower carbon footprint and helps companies to achieve SBTi (Science Based Targets initiative) targets.”

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