As the enforcement countdown for the new EU deforestation-free law (EUDR) reaches its final months, the chorus of prominent coffee industry voices urging a delay is growing ever louder.
Beginning Dec. 30 of this year, European companies with more than 250 employees could be subjected to financial and other market-related penalties should they fail to meet the EUDR due diligence and reporting requirements (enforcement for smaller companies starts June 2025).
The landmark legislation — which applies to the coffee, cocoa, cattle, palm oil, soy and wood sectors — is designed to prevent new deforestation associated with the supply chains of European companies, and ensure current products are not derived from deforested land.
It is arguably the most substantive government intervention that the global coffee roasting and trading industry has seen this century, and its market reverberations are expected to extend well beyond the EU’s borders.
So, of course, people have some problems with it.
We’ve published dozens of stories on the EUDR since the law’s language was finalized in late 2022.
Nearly every well-reasoned criticism, opinion piece or public statement on the new law leads with something like this: We fully support the spirit of EUDR and we believe in the need to prevent deforestation and create more environmentally sustainable supply chains, etc.
There appears to be almost unanimous support for the “spirit” of the deforestation-free law, just as there are shared concerns over the “unintended consequences” of the law.
In coffee, nearly every public criticism of the law has led with the idea that the industry’s more vulnerable actors, smallholder farmers, may be shut out of trade channels due to a lack of capacity to meet the EUDR requirements and/or report them to downstream supply chain actors.
A letter signed by multiple European coffee trade groups and multiple large producer trade groups just this week warned that the law could carry “unintended consequences for smallholder coffee farmers and smaller companies.”
That group said it represented “over 90% of the coffee imported, manufactured, sold, and exported in/from the EU annually.”
The letter’s sentiments have been echoed elsewhere. Earlier this month, Fairtrade International warned that smallholder farmers may be “cut off” from trade with the EU market, “not because they farm on deforested land, but because they face challenges in collecting, managing and submitting the necessary data.”
In June, a membership group composed of some of Europe’s largest coffee roasters warned that the legislation “could promote poverty and counteract sustainability” if smallholder coffee farmers are excluded from the EU market.
By all accounts, these concerns are legitimate, and the EUDR’s negative effects on smallholder farmers, or on specific coffee-growing countries or regions, may well be significant.
We hear these concerns loud and clear.
What we are not hearing is the slightest whisper of culpability or contrition.
The conspicuous silence is most pronounced among the world’s largest green coffee buyers and roasters.
Despite its high potential for combining production with sustainability, the high-volume commercial coffee trading and roasting industry remains resource-intensive and extractive in nature, incentivizing deforestation to support short-term volume gains created by monocrop systems.
The world’s largest coffee roasters have for decades, if not generations, profited off the backs of smallholder farmers, while inadequately investing in sustainability initiatives within their own supply chains.
The EUDR came into existence precisely because these agricultural industries remain predominant contributors to deforestation, despite whatever private sustainability schemes may be in place.
In their calls to delay or reconsider enforcement of the EUDR laws, many of these large European roasters say they are concerned about the fortunes of smallholder farmers, yet these are the same companies that have been unable to guarantee living incomes for farmers in their own supply chains.
To be clear, if smallholder farmers or specific production networks are going to be “shut out” of international trade due to EUDR, it will not be by the force of law, it will be by the world’s largest buyers seeking to mitigate risk and avoid financial penalties.
This is not meant to suggest that these largest buyers are shedding crocodile tears. They, too, have a vested interest in the success of the world’s approximately 12.5 million smallholder farmers, who represent 80-85% of all coffee farmers and produce approximately 60-65% of the world’s coffee.
The calls to delay enforcement of the EUDR law are highly persuasive, generally urging more communications between a broad range of stakeholders, more mechanisms to protect smaller producers and more time to sort out the near-infinite details of real-world implementation.
It may indeed be a time to delay.
Yet for those companies that actually have the economic capacity to invest in more sustainable supply chains, it’s surely a time to double down on action.
Comments? Questions? News to share? Contact DCN’s editors here.
