Does EUDR Apply to Roasted and Instant Coffee?

The EU Deforestation Regulation (EUDR) sets conditions for listed products placed on, made available on, or exported from the EU market. Covered coffee must be deforestation-free and produced legally under the regulation’s requirements.

For coffee, deforestation-free sourcing concerns land not deforested after 31 December 2020. Upstream operators gather plot-level origin evidence and carry out due diligence; downstream operators and traders have different obligations.

A Vietnamese supplier selling to an EU importer is not automatically the operator lodging a due diligence statement. Agree who performs that role and what sourcing data the supplier will provide.

Roasted coffee is listed in Annex I. Being covered does not mean every farmer, roaster, exporter and trader has identical filing duties; identify the company’s role before assigning responsibilities.

Roasted coffee falls under HS 0901.21 (not decaffeinated) or 0901.22 (decaffeinated). Green coffee is also listed under heading 0901.

Check the product code, sourcing evidence and applicable start date together. A supplier certificate alone is not the complete due diligence process.

Use the classification for the actual product and formulation.


HS codes and classification

Roasted coffee uses 0901.21 and 0901.22; green coffee uses 0901.11 and 0901.12. These fall within Annex I heading 0901.

The 2026 amendment adds CN 2101 11 00 for coffee extracts, essences and concentrates from 30 December 2027. Do not assume preparations under 2101.12 are included by that addition.

Confirm the declaration code with your importer or customs broker before agreeing the documentation file.


Compliance steps for roasted coffee

For an EU-bound order, agree how the following will be handled:

• Link the coffee lot to the geolocation of its production plots.
• Provide evidence of lawful production and deforestation-free sourcing.
• Identify the responsible operator and applicable DDS or simplified declaration.
• Agree access to records; operators keep due diligence documentation for five years.

When the relevant obligations apply, the operator completes due diligence and submits the required statement before the product is placed on the EU market. A DDS can cover multiple batches or shipments if the regulatory requirements are met.

Ask the buyer which identifiers and supporting records are needed for the particular order before shipment.

Soluble coffee has been added to EUDR Annex I by Commission Delegated Regulation (EU) 2026/2102.

The added entry is CN 2101 11 00: coffee extracts, essences and concentrates. Its obligations apply from 30 December 2027.

The Commission adopted this product-scope change on 13 July 2026; the regulation was published in the Official Journal on 17 September 2026.

This is a separate application date from the 2026–2027 dates for products already covered, such as green and roasted coffee.

For a mixed instant-coffee product, start with its composition and correct declaration code.


What changed in the Annex

The original coffee entry covered heading 0901. The amendment inserts the specific soluble-coffee entry after it.

It does not add every product under heading 2101. A preparation classified under 2101.12 should not be treated as included solely because it contains coffee.

Confirm the scope for the actual SKU rather than relying on the word “instant.”


Preparing for the applicable start date

Agree the required sourcing records with the EU buyer early, including how lots connect to farms and production periods.

Check the product code and application date before fixing the shipment and documentation schedule.

Confirm which party performs the operator’s due diligence and filing tasks.

For Vietnamese coffee supply, the practical task is connecting the exported lot to its sourcing records, including any farms, collectors and processors involved.

Ask your EU buyer which plot, production-period and legality information is needed for the coffee you intend to supply.

Resolve gaps before confirming that the order can meet the buyer’s sourcing requirements.


EUDR preparation for Vietnamese suppliers

Prepare a sourcing file with your buyer:

• Connect each lot to its production plots and geolocation records.
• Collect the evidence needed to establish lawful production.
• Track collection, processing and any blending through the supply chain.
• Agree the product-specific application date and data handover schedule.
• Identify the operator responsible for due diligence and system submissions.

Selling coffee from Vietnam to an EU buyer does not itself make every supplier an EUDR operator. Directly placing a product on the EU market can create operator responsibilities.

Check your contractual role and the importer’s requirements before promising a compliance package.


Steps Vietnamese exporters can take right now

Review one actual sourcing lot with the buyer. Confirm the product code, records available, missing data, and who supplies each document.

Use that review to plan the next order and resolve traceability gaps before shipment.