Disrespect in new EUDR delays

The EU Deforestation Regulation (EUDR) has been delayed for a second year in a row [link].

It feels bizarre to be back in this position again; producers threatened with loss of market access and European companies cautioned with heavy fines have been working hard for two and a half years to comply with the laws set to take place. Then suddenly, in the last weeks before the law was supposed to come into effect, the brakes have been put on again. This has run to almost the exact same rhythm as last year’s delay. Back then, a 30 December deadline was pushed back with just two weeks to go.

EUDR compliance is a very complex exercise requiring not only a completely new approach to traceability - geolocation of all places of production required to run deforestation analysis - but fluency in human and workers’ rights and an understanding of laws of production in the sourcing area. Coffee growers and producers need to provide information showing compliance. Those importing or trading agricultural products in Europe run analysis and risk assessments.

Apparently a second delay like this in such a short space of time is incredibly unusual in EU lawmaking [link], and it seems to be part of an unfortunate trend. Right wing lawmakers are pushing for deregulation [link]. Support for a delay also came from some big industry players (like Mondelez) who weren’t able to achieve compliance in time. This is all in spite of significant opposition to a delay from other large companies like Nestlé who had managed to get their compliance completed.

(One of the maps provided by producer Migoti in Burundi. Producers have been required to plot the farms contributing to all of their coffee. For for the thousands of smallholder farmers in Africa, this can be a lot of work.)

We can’t over emphasise the amount of work that producers have put into meeting the requirements of EUDR before the end of 2025 deadline. We work with only a few partners - and even across just 9 washing stations, 18,771 farms have been mapped. This is the picture across much of the industry, with roasteries, importers, producers and growers finding their approaches and getting the work done.

In Kenya, Sidney Kibet at Lot 20 had to fight hard to overcome the understandable suspicion farmers had about people gathering their GPS data, putting lots of investment into outreach where government initiatives were lacking. “We explained as politely as we could, we paid field workers hundreds of shillings for each coordinate, cause that was the only way to get it, as well as even pay the farmer. It's been a massive pain in the butt to get validated data of each farm against each of our members and we spent a few thousand dollars on it”. Sidney has been left with a strong sense that the lawmakers “don't understand what actual farming in Africa looks like”.

For lawmakers to ask for incredibly detailed traceability information, set a compliance deadline that implicitly threatens loss of market access, then wait till last minute to delay (twice) is indulgent and hugely disrespectful to those who already deal with instability on a daily basis.

More worryingly, the vote approving a delay has also called for a review into the basic workability of the law. To review whether or not the requirements can be met when the majority of people have been out there already meeting them is pretty baffling. Why now, after so many other companies have already put in all this work and proven it to be possible? And not knowing how the law might look at the end of this review (due by April 2026), far from adding clarity and reducing burden on companies, leaves us in limbo.

This has got us reflecting on a few things.

The first is that it’s another very strong reminder of what it means to place additional burdens on producers and coffee growers. Collecting information, doing something new, experimentation, it all costs time, resources, and entails risk. There is a power imbalance that can make it very hard to say no to a request from someone who’s buying your coffee. Going forward, whether it's a request for transparency information or discussions on different processing methods, we’ll be asking ourselves more firmly: do we really need this, what’s this going to cost the producer, how easy is it to say no?

Which leads to the question of how we can ensure that these processes of digitisation and traceability are valuable to coffee growers and producers. Even where EUDR implementation has been chaotic, the building blocks of the regulation should bring benefits.

These kinds of benefits have already been shown by our partner Agri Evolve in Uganda who have been working on digitization and traceability for a long time, and not only (or even mainly) for EUDR. Agri Evolve source from thousands of coffee growers spanning a 100km stretch along the Rwenzori Mountains. Where coffee cherries need to be delivered within 1 day of harvest, having accurate location information is vital to planning buying centres and aggregation stations. Being registered on a digital system means coffee growers can more easily track the quantity of coffee they have delivered and the price they will receive. As Collins Kifula, a field coordinator at Agri Evolve, puts it in an article for SAP, Agri’s digital platform provider: “This price transparency is a big motivation for the farmers and creates trust”.

With plenty to think about and a fair bit of time to do it in, we’d love to hear any reflections from our roaster partners on this. Have you been affected by the delay? Has the effort so far been time well spent? Are there any parts of this you’d like to hear more about?