The EU Deforestation Regulation for cocoa and coffee: where it stands.
A short, sourced summary of the regulation’s scope and timing, and of the practical consequences for European commodity procurement.
The EU Deforestation Regulation — Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation — changes what a European operator must know about the origin of what it buys. Cocoa and coffee are both in scope.
Scope
The regulation covers seven commodities — cattle, cocoa, coffee, oil palm, rubber, soya and wood — together with certain products derived from them. For cocoa this reaches beyond beans into derived products; for coffee it captures green coffee entering the Union market.
Timing
The regulation entered into force in 2023 with an original application date of 30 December 2024. That date has been postponed twice. A first postponement moved it to 30 December 2025. A second, adopted in December 2025 as Regulation (EU) 2025/2650, moved the main obligations to 30 December 2026 for large operators and traders, and to 30 June 2027 for micro and small enterprises.
The same amending act introduced simplification measures. Among them, operators and traders further down the supply chain are no longer required to carry out due diligence and submit due-diligence statements; their obligations are framed around traceability, record-keeping, notification of risks and cooperation with competent authorities.
What this means for a European buyer
The commercial consequence is that origin information becomes part of the product specification. A buyer that cannot obtain production-location information from its supply chain has a supply problem, not merely a compliance problem, because the alternative supplier who can provide it becomes the only viable option.
Questions worth putting to a supplier now
- Can you identify the production locations for the lots you supply us, and in what form?
- How is lot identity maintained through aggregation, processing and packing?
- What records exist for the production period of the goods?
- Which party in your chain holds the information, and will it be released to us?
- How would you evidence this if a competent authority asked?
Nevermore’s position
We work with suppliers and partners to support the documentation and traceability requirements relevant to European commodity trade. We state the documentation status of each shipment in writing. We do not describe ourselves as ‘EUDR compliant’, because compliance is assessed per operator and per shipment against the obligations applicable to that party — not asserted as a marketing badge.
Sources
Tell us what you need to buy — or what you have to sell.
Send us the commodity, specification, volume and destination. We reply to qualified enquiries with an indication of feasibility, timing and commercial terms, or tell you plainly if we are not the right counterparty.