The dates
Regulation (EU) 2023/1115 was due to apply from December 2024, was postponed by a year, and was postponed again and revised in December 2025. The application dates are now 30 December 2026 for large and medium operators and traders and 30 June 2027 for micro and small enterprises (Council of the EU press release, 18 December 2025; Access2Markets). In its May 2026 simplification package the Commission stated that there will be no further postponement (Hogan Lovells; Mayer Brown, 2026). Coffee shipped from Uganda in the 2026/27 main harvest — which starts in October and ships from December — will therefore arrive in the EU either side of the first date. This is not legal advice; confirm your company's category and obligations with your adviser.
What changed in the revision
- One statement per supply chain. Only the operator that first places the coffee on the EU market files the due diligence statement (DDS); downstream operators and traders reference it and keep records, rather than filing their own.
- Simplified traceability for small operators and a lighter administrative load; the Commission estimated compliance costs around three-quarters lower than the original design.
- Country benchmarking is in force: Uganda is standard risk, so full due diligence applies but not the enhanced scrutiny for high-risk countries.
- Cut-off date unchanged: coffee must come from land not deforested after 31 December 2020, and must have been produced legally in Uganda.
What the importer has to hold, per lot
- Geolocation of every plot: a point for plots under four hectares, a polygon for four hectares and above (WGS84).
- Evidence that those plots were not deforested after 31 December 2020 — normally satellite analysis against the coordinates.
- Legality evidence: farmer registration, the exporter's MAAIF licence and the export documents.
- Supply-chain records linking the lot to the plots: farmer identifiers, buying and processing records.
- A supplier statement supporting the DDS.
Uganda's national farmer registration and plot-mapping programme, covering roughly 1.6 million coffee farms, is the source for items 1 and 3 where the supply chain is organised; trader-aggregated coffee is traceable to district level rather than plot level. Our EUDR page states which level applies to each lot.
Month-by-month checklist
| When | Importer action | What to ask the supplier |
|---|---|---|
| September–October 2026 | Confirm your company's size category and whether you are the first operator. Decide which platform or format you will use for geolocation data. | Which lots for the 2026/27 harvest will be plot-level traceable? In what format is geolocation delivered? |
| October–November 2026 (harvest starts) | Contract fresh-crop lots with traceability level written into the contract. Run a test file through your DDS process. | Send a sample GeoJSON/CSV for a past or current lot so we can test it. |
| December 2026 (application date; fresh Robusta ships) | File the DDS for the first shipments placed on the market after 30 December. Record DDS reference numbers against lots. | Deliver geolocation, legality evidence and the supplier statement at or before PSS approval. |
| January–March 2027 (Bugisu ships) | Repeat for Arabica lots; audit one shipment end-to-end. | Same data pack per lot; confirm farmer identifiers match the national register. |
| By June 2027 | Small and micro operators come into scope. | Ensure smaller customers you supply can reference your DDS. |
What we provide and what we do not
For lots from registered farmer groups or washing stations with mapped plots we deliver plot geolocation (GeoJSON or CSV), farmer identifiers, buying and processing records, a deforestation-free and legality statement and the export document set, handed over at or before pre-shipment sample approval. For trader-aggregated lots we state district-level traceability and do not claim more. We do not file the DDS — the importer does — and we do not guarantee compliance, which is the operator's legal responsibility based on its own risk assessment. What we can guarantee is that the traceability level of a lot is stated before you contract it.
Beyond the EU
UK and US buyers are outside the regulation, but many ask for the same data for their own sustainability programmes; it is available to them on the same basis. Importers considering the UK or US routes will find the country guides useful.
Frequently asked questions
When does EUDR apply to coffee?
From 30 December 2026 for large and medium operators and traders, and from 30 June 2027 for micro and small enterprises, following the December 2025 revision. The Commission has stated there will be no further postponement.
Is Uganda high risk under EUDR?
No. Uganda is classified as standard risk in the Commission's May 2025 benchmarking, which means full due diligence but not the enhanced checks applied to high-risk countries.
Does the Ugandan exporter file the due diligence statement?
No. The first operator placing the coffee on the EU market — normally the importer — files the DDS. The exporter supplies the geolocation, legality and supply-chain data that support it.
What geolocation format should I ask for?
Points (latitude/longitude) for plots under four hectares and polygons for larger plots, in WGS84, delivered as GeoJSON or CSV with the lot reference. Ask for a test file before the harvest.