Coffee
Green and roasted coffee and coffee extracts, a leading Indian export to the European market grown in Karnataka and Kerala.
EUDR Solutions for Exporters of
EU Deforestation Regulation readiness for Indian exporters of coffee, cocoa, rubber, soya, leather and wood, and the European operators that place those goods on the market. Plot geolocation, deforestation-free evidence after the 31 December 2020 cut-off and the due diligence statement readied as one engagement from Mumbai before the obligations apply from 30 December 2026.
Geolocate · Evidence · FileSeven covered commoditiesIndia benchmarked low risk
Reviewed by Team GreenSutra · Updated 12 June 2026
On recordRegulationRegulation (EU) 2023/1115Covered commoditiesSeven, plus Annex I productsDeforestation-free cut-offAfter 31 December 2020India risk statusLow riskCore dutyDue diligence and geolocationMaximum fine floorAt least 4 percent of turnover
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From a future obligation to a ready supply chain
For Indian exporters of coffee, cocoa, rubber, soya, leather and wood, and the EU operators who place those goods on the market.
EUDR Solutions by GreenSutra prepare an Indian export supply chain for the EU Deforestation Regulation, Regulation (EU) 2023/1115, before its obligations apply. One accountable engagement maps the commodities, geolocates the plots, assembles deforestation-free evidence and readies the trail so the European operator can file the due diligence statement in the EU information system and pass the reference number down the chain.
WHAT THE REGULATION WILL REQUIRE
The regulation will require that seven relevant commodities and their Annex I derived products reach the European market only when deforestation-free and legally produced. It covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, including derived goods such as leather, chocolate and furniture. The operator must hold plot geolocation and evidence that the land was not subject to deforestation after 31 December 2020, with wood harvested without inducing forest degradation after that date, before placing the goods on the market or exporting them.
WHEN DO THE OBLIGATIONS APPLY
The obligations are not yet applying. As amended by Regulation (EU) 2025/2650, the regulation will apply from 30 December 2026 for medium and large operators and traders, and from 30 June 2027 for micro and small operators and traders established by 31 December 2024.
WHY INDIA SITS IN THE LOW-RISK BAND
India is benchmarked a low-risk country under Implementing Regulation (EU) 2025/1093. An operator sourcing exclusively from India may apply the simplified due diligence of Article 13 and set aside the risk assessment and risk mitigation steps, unless it becomes aware of a non-compliance risk. The information and geolocation duties remain in every case.
WHAT THE ENGAGEMENT DELIVERS
- Commodity map checking products against the seven covered commodities and the Annex I derived-product list
- Plot geolocation by latitude and longitude, and polygons where a plot is larger than four hectares for commodities other than cattle
- Deforestation-free evidence that the land was not deforested after the 31 December 2020 cut-off
- Traceability records kept so the European buyer can rely on the chain
- Statement-ready trail so the operator can file the due diligence statement and pass the reference number on
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EUDR dates and duties at a glance
The application dates after two delays, the covered commodities and the two due diligence tracks.
The regulation has been in force since 29 June 2023 and the deforestation cut-off has never moved: land deforested after 31 December 2020 cannot supply covered goods. What moved twice are the application dates.
| Stage | Medium and large operators | Micro and small operators |
|---|---|---|
| Original, Regulation (EU) 2023/1115 | 30 December 2024 | 30 June 2025 |
| First delay, Regulation (EU) 2024/3234 | 30 December 2025 | 30 June 2026 |
| Current, Regulation (EU) 2025/2650 | 30 December 2026 | 30 June 2027 |
| Commodity | Derived products include |
|---|---|
| Cattle | Beef, leather and hides |
| Cocoa | Cocoa butter, chocolate |
| Coffee | Roasted and decaffeinated coffee |
| Oil palm | Palm oil, glycerol and derivatives |
| Rubber | Tyres, tubes, rubber articles |
| Soya | Soya beans, flour and meal |
| Wood | Timber, furniture, pulp and paper |
| Duty | Standard due diligence | Simplified, Article 13, low-risk sourcing |
|---|---|---|
| Plot geolocation | Required, six decimal digits, polygons over four hectares. | Required identically. |
| Deforestation-free and legality evidence | Required against the 31 December 2020 cut-off. | Required identically. |
| Risk assessment | Required for every supply chain. | Set aside unless non-compliance information emerges. |
| Risk mitigation | Required where risk is found. | Set aside unless non-compliance information emerges. |
| Due diligence statement | Filed before first placing on the market. | Filed identically. |
India is benchmarked low risk under Implementing Regulation (EU) 2025/1093, so exclusively Indian sourcing qualifies for the simplified track, and authorities need check only 1 percent of operators on low-risk origins against 3 percent standard and 9 percent high risk. The information duties in the first two rows never fall away.
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Commodities covered by the EUDR
The seven relevant commodities, with the derived products each carries and how the obligation attaches.
The EU Deforestation Regulation lists seven relevant commodities and the products derived from them in Annex I. The obligation follows the commodity and its derived products rather than the trade name, so the commodities below act as the guide. Printed Chapter 49 products such as books and newspapers were removed from Annex I by Regulation (EU) 2025/2650.
Rubber
Natural rubber and derived products including tyres, sheets and latex, sourced from Kerala and the North-East.
Soya
Soya beans and derived products including soya meal and soya oil placed on the European market.
Cattle
Cattle and derived products including leather and hides; geolocation polygons do not apply to cattle plots.
Cocoa
Cocoa beans and derived products including chocolate and cocoa butter listed in Annex I.
Oil palm
Oil palm fruit and palm oil and its derivatives placed on the European market.
Wood
Wood and derived products including timber, furniture, pulp and paper, with degradation as well as deforestation in scope.
A precise check of which commodities and derived products a business exports, and in what role toward the European market, is the first step of every EUDR readiness review.
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How an EUDR engagement runs
From commodity scoping and plot geolocation through deforestation-free evidence and the filed statement to a cleared border.
01
Scope the commodities and supply chains
Products checked against the seven covered commodities and the Annex I derived-product list, the role toward the European market confirmed, and every supply chain back to the production plot identified.
02
Geolocate the production plots
Every plot supplying the export located by latitude and longitude to at least six decimal digits, and described as a polygon where the plot is larger than four hectares for commodities other than cattle.
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Assemble deforestation-free evidence and assess risk
Proof that each plot was not deforested after 31 December 2020 assembled from satellite history, land records and supplier declarations, with the simplified due diligence of Article 13 applied where sourcing is exclusively from low-risk India.
04
File the due diligence statement
Geolocation, evidence and traceability records compiled so the European operator can file the due diligence statement in the EU information system and obtain the reference number passed down the chain.
05
Clear the border and keep watch
Once the obligations apply, the goods clear the European border with the reference number demonstrating compliance, and the geolocation and evidence are kept current for every later consignment.
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How EUDR due diligence flows from origin plot to EU market
A commodity from a geolocated plot clears due diligence, the statement is filed in the EU information system, and the goods enter the market.
01Origin plot
A relevant commodity is grown on a geolocated production plot, recorded by latitude and longitude and, where the plot is larger than four hectares for commodities other than cattle, by a polygon of the plot perimeter.
02Supply chain
The commodity and its Annex I derived products travel the supply chain from the Indian producer toward the European operator that will place them on the market or export them.
03Due diligence
The operator collects the Article 9 information and, where sourcing is not from a low-risk country, assesses and mitigates the risk that the goods are not deforestation-free or not legally produced.
04DDS filed
The operator first placing on the market or exporting files a due diligence statement in the EU information system and receives a reference number; downstream operators pass that reference number on.
05EU market
Once the statement is filed, the goods clear the European border and enter the EU market, with the reference number demonstrating compliance down the chain.
A relevant commodity grown on a geolocated origin plot travels the supply chain to the operator placing it on the EU market or exporting it. That operator files a due diligence statement in the EU information system and obtains a reference number, which downstream operators pass on, before the goods clear the border. Sourcing exclusively from low-risk India sets the Article 13 risk steps aside.
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EUDR exposure self-check
Three answers map an export trade onto the EU Deforestation Regulation.
Three questions place an export trade against the EU Deforestation Regulation: the commodities or derived products involved, who places the goods on the European market, and the size of the operator that does. The result states what the regulation will require and from when.
Three questions decide EUDR exposure: which relevant commodities or derived products the business exports to the European market, who places the goods on the market, and the size of that operator. An EUDR readiness review works through all three with the supply chain on the table.
Request an EUDR readiness review →- Medium and large operatorsFrom 30 December 2026
- Micro and small operatorsFrom 30 June 2027
- EU information systemLive, registration open
The trade sits outside the EU Deforestation Regulation
None of the seven relevant commodities or their Annex I derived products are exported to the European market, so the EU Deforestation Regulation will place no obligation on this trade. The regulation covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, and the products derived from them. Printed Chapter 49 products such as books and newspapers were removed from scope by Regulation (EU) 2025/2650, so the commodity mix is the point to watch.
In scope, with obligations from 30 December 2026
Covered commodities are exported to the European market through a medium or large operator, so the EU Deforestation Regulation will apply to that trade from 30 December 2026. From that date the operator first placing the goods on the market or exporting them will need to run due diligence and file a due diligence statement in the EU information system, supported by plot geolocation and evidence that the land was not deforested after 31 December 2020. The preparation window is now, so geolocation and deforestation-free evidence assembled ahead of the date keeps the goods moving when the obligation applies.
In scope, with obligations from 30 June 2027
Covered commodities are exported to the European market through a small or micro operator, so the EU Deforestation Regulation will apply to that trade from 30 June 2027 where the operator was established by 31 December 2024. The same duties attach: plot geolocation, evidence that the land was not deforested after 31 December 2020, and a due diligence statement filed in the EU information system, with the later date giving more of the preparation window. Sourcing exclusively from low-risk India lets the operator apply the simplified due diligence of Article 13.
In scope, with the date set by operator size
Covered commodities are exported to the European market, so the EU Deforestation Regulation will apply to that trade; the size of the operator decides from when. Obligations will apply from 30 December 2026 for a medium or large operator or trader, and from 30 June 2027 for a small or micro operator or trader established by 31 December 2024. Either way the same duties attach: plot geolocation, evidence that the land was not deforested after 31 December 2020, and a due diligence statement filed in the EU information system. Confirming the operator size and the route to market is the first step of a readiness review.
An own European entity placing the goods on the market files the due diligence statement itself, so the geolocation and deforestation-free evidence stay within the business.
The European buyer is the operator carrying the due diligence statement and will demand plot geolocation and deforestation-free evidence from the Indian supplier.
Traders or agents in the chain register in the information system and pass on the reference number issued by the operator first placing the goods on the market rather than filing fresh statements.
Identifying the operator that places the goods on the market, and so who files the statement, is part of the readiness review.
Answers stay in this browser. Nothing is sent until a contact channel is opened.
Due diligence runs from the geolocated origin plot to the statement filed in the EU information system, and a readiness review turns that path into a geolocated, evidenced, ready supply chain before the obligations apply.
WhatsAppRequest an EUDR readiness review →07
Benefits of EUDR solutions
What an EUDR-ready supply chain earns an exporter and its European operator before the obligations apply.
B·01
Market access protected
Plot geolocation and deforestation-free evidence ready ahead of the application dates keep covered commodities moving into the European market when the obligations apply.
B·02
Traceability in place
Every plot located and documented, so the European operator can file an accurate due diligence statement and pass the reference number down the chain.
B·03
Preferred supplier status
A ready trail of geolocation and evidence positions the Indian exporter as a low-friction supplier to European operators sourcing under the regulation.
B·04
Low-risk advantage
India benchmarked low risk lets the European operator apply simplified due diligence, an advantage that holds while the information and geolocation duties are met cleanly.
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Why GreenSutra leads EUDR consulting
The reasons behind the reputation.
R·01
Certified expertise
Each engagement led by a certified specialist with proven experience across deforestation due diligence and supply-chain traceability.
R·02
EU and India regulatory fluency
Working knowledge of the EU Deforestation Regulation as amended alongside Indian export realities, so guidance fits both sides of the trade.
R·03
Geolocation discipline
Plot coordinates and polygons captured to the standard the regulation sets, including the cattle carve-out, so the data stands up at the European border.
R·04
End to end delivery
Commodity mapping, geolocation, deforestation-free evidence, traceability and statement readiness handled as one accountable engagement, or any stage standalone.
R·05
Mumbai based, serving worldwide
EUDR readiness delivered to exporters and their European operators worldwide from a Mumbai base.
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Built for every covered commodity
The same geolocation and evidence discipline, tuned to the commodity and the operators it supplies.
01
Coffee and cocoa exporters
Plantation plots geolocated and deforestation-free evidence assembled so European operators can file the statement.
02
Rubber and oil palm suppliers
Smallholder and estate plots mapped to coordinates and polygons, with traceability kept for the European buyer.
03
Soya and leather producers
Soya and cattle-derived goods evidenced as deforestation-free, with the cattle polygon carve-out applied correctly.
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EU operators and traders
Operators and traders sourcing from India obtain ready geolocation and evidence to file accurate due diligence statements.
Every covered commodity carries the same geolocation and evidence discipline, tuned to the exporter and the European operators it supplies.
WhatsAppRequest an EUDR readiness review →10
EUDR questions, answered
Q·01What are EUDR solutions?
EUDR solutions prepare a business for the EU Deforestation Regulation, Regulation (EU) 2023/1115, which will require covered commodities to be deforestation-free and legally produced before they reach the European market. The work covers mapping products against the seven covered commodities, geolocating every production plot, assembling evidence that the land was not deforested after 31 December 2020, and readying the trail so the European operator can file the due diligence statement in the EU information system. The aim is an export supply chain that is ready before the obligations apply.
Q·02When does the EUDR start applying after the latest delay?
Under Regulation (EU) 2025/2650, published on 23 December 2025, the obligations will apply from 30 December 2026 for medium and large operators and traders, and from 30 June 2027 for micro and small operators and traders established by 31 December 2024. The earlier 30 December 2025 and 30 June 2026 dates set by Regulation (EU) 2024/3234 are superseded, and the original 30 December 2024 date never took effect. The regulation is not yet applying, so the period now is a preparation window.
Q·03Which commodities does the EUDR cover?
The regulation covers seven relevant commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood, together with the products derived from them listed in Annex I, such as leather, chocolate, furniture, soya meal and palm oil derivatives. Printed products of Chapter 49 of the Combined Nomenclature, such as books and newspapers, were removed from Annex I by Regulation (EU) 2025/2650 and are no longer in scope.
Q·04Is India high risk or low risk under the EUDR?
India is classified a low-risk country under Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025. An operator sourcing exclusively from a low-risk country may apply the simplified due diligence of Article 13, which sets aside the risk assessment and risk mitigation steps unless the operator becomes aware of information pointing to a risk of non-compliance. Only four countries are classified high risk, and India is not among them, so the low-risk benchmark is a genuine advantage for Indian exporters.
Q·05What is the deforestation-free cut-off date?
A commodity must be produced on land that was not subject to deforestation after 31 December 2020, and wood must be harvested without inducing forest degradation after that date. The cut-off is a fixed baseline and was not changed by the 2025 amendment, so plots that were forest after that date and cleared since cannot supply covered commodities to the European market once the obligations apply.
Q·06What geolocation data does the EUDR require?
Due diligence requires the geolocation of every plot of land where the commodity was produced, given as latitude and longitude using at least six decimal digits. For plots of more than four hectares used to produce relevant commodities other than cattle, the geolocation must be provided as polygons describing the plot perimeter. Cattle plots are exempt from the polygon requirement, which is a point the data capture has to get right.
Q·07Do Indian exporters file the due diligence statement themselves?
The due diligence statement is filed in the EU information system by the operator that first places the goods on the market or exports them, which is usually the European-side operator. An Indian supplier provides the plot geolocation, the deforestation-free evidence and the traceability records that the operator needs. Where the exporter places the goods on the market through its own European entity, that entity is the operator and files the statement itself.
Q·08Does every business in the chain file a separate statement?
No. As amended by Regulation (EU) 2025/2650, the full due diligence statement obligation falls on the operator carrying out the first placing on the market or export. A downstream operator registers in the information system and passes on the reference number issued for that statement rather than filing a fresh one. A micro or small primary operator uses a one-time simplified declaration and receives a declaration identifier sufficient for traceability.
Q·09What can the fines be for breaking the EUDR?
Under Article 25 the maximum fine must be set at least at 4 percent of the operator or trader total annual Union-wide turnover in the year before the fining decision, and each EU Member State sets the actual level and may go higher. Penalties also include confiscation of the relevant products and of the revenues gained, temporary exclusion of up to 12 months from public procurement and public funding, and, for serious or repeated infringements, a temporary ban on placing the products on the market or exporting them.
Q·10Is the low-risk status enough to skip due diligence?
No. India being low risk lets the European operator apply the simplified due diligence of Article 13, which sets aside the risk assessment and risk mitigation steps, but the information and geolocation duties remain in every case. Plot coordinates, polygons for plots over four hectares other than cattle, and evidence that the land was not deforested after 31 December 2020 are still required, and the simplification falls away if the operator becomes aware of a non-compliance risk.
Q·11How many EUDR checks do authorities run on low-risk sourcing?
Member State authorities must check at least 9 percent of operators placing products from high-risk countries, 3 percent for standard-risk countries and 1 percent for low-risk countries, counted per commodity under Article 16. Sourcing from India therefore sits in the lightest inspection tier, provided the geolocation and evidence package behind each due diligence statement holds up when a check does come.
Q·12Does meeting the EUDR also cover other EU import rules?
No. The EU Deforestation Regulation is one of several European frameworks an Indian exporter may face, separate from the Carbon Border Adjustment Mechanism and other EU rules. A business serving the European market may carry more than one obligation at once, and meeting the EUDR satisfies only the deforestation due diligence requirement. Where several frameworks apply, planning them together keeps each obligation from being missed.
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Primary sources
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Asked at the Expert's Corner
Real EUDR and deforestation due diligence questions from the community, answered by the GreenSutra team.
Q · 01EUDR814 views
When does EUDR come into force?
The EU Deforestation Regulation (EUDR) came into force on June 29, 2023. After two postponements, the requirements become applicable to Medium and Large Companies…
Answered by Shravani MestryQ · 02EUDR809 viewsWhat is EUDR ?
European Union Deforestation Regulation (EUDR) is a regulation implemented by European Union to encourage consumption of Deforestation-free products. European Union (EU) avoids import, export…
Answered by [email protected]Q · 03EUDR804 viewsWhich commodities are included under EUDR?
The commodities listed under EUDR are: Palm Oil Cattle Soy Coffee Cocoa Timber Rubber
Answered by Shravani Mestry13
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Field notes and stories
Reading on forests, supply chains and the EU green standards EUDR sits within, from the GreenSutra journal.
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