EUDR Impact on Cocoa and Coffee Importers: Geolocation, Traceability, and What UK and EU Businesses Must Do

Why Cocoa and Coffee Are High-Risk for EUDR#

Cocoa and coffee are cultivated predominantly in tropical regions — West Africa for cocoa, East Africa and Latin America for coffee — where deforestation pressure is high. Côte d'Ivoire, Ghana, and Nigeria produce over 70% of global cocoa, and satellite data has documented deforestation linked to cocoa farming expansion across all three countries, including within protected areas. Indonesia and Brazil — major robusta coffee and Arabica producers respectively — have similarly documented deforestation in coffee growing regions. EUDR's cut-off date of 31 December 2020 means any production that involved land cleared after that date is non-compliant, regardless of whether the clearance was legal under local law. For supply chains with significant volumes from these regions, the compliance challenge is substantial.

The Geolocation Polygon Requirement in Practice#

For cocoa and coffee, EUDR requires operators to collect and provide the geolocation coordinates of each plot of land where the commodity was produced. Where a farm plot exceeds four hectares, polygon coordinates (the boundary of the plot) are required rather than a single point. For most cocoa and coffee supply chains — which involve hundreds or thousands of smallholder farmers, each with plots of 1-5 hectares — this means individual farm polygon data at scale. Origin country industry associations and certification bodies including Rainforest Alliance, Fairtrade, and UTZ have been building geolocation data collection programmes using mobile applications. However, coverage is incomplete, particularly in remote growing areas where the most vulnerable deforestation risk often lies. Importers who have relied on third-party certification as their primary supply chain assurance must now supplement it with verified geolocation data.

Supply Chain Traceability Systems Required#

Meeting EUDR geolocation requirements demands supply chain traceability systems that connect farm-level data to shipment-level imports. For a cocoa cooperative aggregating beans from 500 smallholder farmers, this means: recording individual farmer plot coordinates, matching individual farmer deliveries to the cooperative's export lots, and maintaining that chain of custody through the export process. Achieving this consistently requires digital record-keeping systems at cooperative or trader level, which are not universally present in origin countries. Importers need to ask their suppliers specific questions: do you have geolocation data for all producing farms in your supply shed? Is that data linked to the lots you are selling us? Can you provide plot-level polygon coordinates for our due diligence statement? AskBiz provides supplier due diligence questionnaire templates tailored to EUDR cocoa and coffee requirements.

UK Business Considerations Post-Brexit#

The UK is not subject to EUDR directly — it applies to the EU customs territory. However, UK businesses are affected in two ways. First, UK companies importing covered commodities for re-export to the EU (for example, a UK chocolate manufacturer exporting to EU customers) must ensure their supply chains meet EUDR standards because their EU customers will require EUDR-compliant inputs. Second, the UK government announced in 2024 that it would introduce its own due diligence legislation on forest-risk commodities — the UK Forest Risk Commodities legislation under Schedule 17 of the Environment Act 2021 — though secondary legislation implementing it had not been enacted as of early 2025. UK businesses should therefore plan for effective EUDR-equivalent requirements both for EU-bound supply chains and, prospectively, for UK domestic market compliance.

Supplier Questionnaires and Contractual Requirements#

Proactive EU and UK importers are updating supplier contracts to include EUDR data provision obligations: requirements to supply farm-level geolocation coordinates for all production plots supplying the contract, warranties that no commodity derives from land deforested after 31 December 2020, obligations to notify the buyer of any supply chain changes affecting deforestation risk, and rights for the buyer to audit origin claims. These contractual provisions shift some compliance risk to suppliers but do not eliminate the operator's due diligence obligation — the due diligence system, risk assessment, and due diligence statement submission remain the operator's responsibility. AskBiz tracks EUDR implementation updates and country risk benchmarking decisions so you know when the regulatory position for your origin countries is confirmed.

• Cocoa and coffee are two of the seven commodities covered by EUDR.
• For importers and manufacturers, compliance means tracing supply chains to farm level, collecting GPS polygon data for every production plot, and submitting due diligence statements before goods enter the EU.
• UK businesses exporting EU-bound chocolate or coffee products face equivalent requirements.