In the future, anyone who trades certain products will have to prove that no forest was cleared for them. A big challenge, as a look at the coffee industry shows.
Green coffee in Kenya: A forest area the size of Rhineland-Palatinate was cut down worldwide within 15 years to grow coffee beans. Photo: imago images/VWPics
From December 30th, the EU deforestation regulation EUDR requires large and medium-sized companies in particular to prove the origin of agricultural products and to prove that no forests were cut down for their production.
Smaller companies in the coffee industry often do not have enough skilled workers and resources to implement the new, complex documentation requirements. Associations and environmental foundations therefore offer information and support services.
To prove forest protection, companies like Tchibo and Gepa use satellite data and geodata to monitor the cultivated areas, but have to add further checks because such data does not clarify all legal questions.
The regulation covers products such as coffee, soy, palm oil, cocoa and beef, the production of which is checked under European law and the law of the producing countries in order to prevent illegal deforestation and ensure sustainable use.
Hamburg. Deforestation is considered one of the central causes of species extinction worldwide. In addition, clear-cutting contributes to global warming: with forests, important CO₂ stores disappear, the carbon bound in them is released and drives climate change.
Nevertheless, millions of hectares of forest have been cleared in the past - for palm oil production, cattle pastures or coffee plantations. According to the wishes of the European Union (EU), consumption within Europe should no longer drive this destruction. On December 30th, the politically controversial deforestation regulation EUDR comes into force, initially for large and medium-sized companies.
In concrete terms, this means: Companies that import agricultural products must trace their origin back to the production areas and prove that no forests were cut down for them. This poses problems for medium-sized companies in particular.
“Most large companies are now very well prepared,” says Steffen Kemper, project manager for biodiversity and sustainable supply chains at the international environmental foundation Global Nature Fund (GNF). Smaller companies, on the other hand, often lack skilled workers and money for expensive software or advice. They sometimes felt “overwhelmed and left alone” with the implementation, says Kemper.
The Global Nature Fund supports such companies via the Elan information portal, for example with a tool analysis and a guide for supplier communication. As a first step, companies should clarify which of their products fall under the EUDR and what obligations arise from their role in the supply chain, says Kemper. Then they should create a plan for implementation.
The coffee industry is one of the particularly affected sectors of the economy: between 2001 and 2015, according to the environmental think tank World Resources Institute, around 1.9 million hectares of forest were cut down worldwide for coffee cultivation, which is roughly equivalent to the area of Rhineland-Palatinate.
Coffee is predominantly grown by small farmers. This makes tracing and proof of legality particularly challenging, says the general manager of the German Coffee Association, Holger Preibisch. The association supports its members in implementing the new rules, among other things, with the “EUDR Coffee Compass”. Companies that import coffee into the EU must not only prove that it does not come from areas that were deforested after December 31, 2020, but also that it was produced in accordance with the applicable law of the producing country.
The Hamburg roaster and retailer Tchibo has already set up a corresponding verification system with test procedures, which has already been used to process test deliveries. “The framework is in place,” says Lena Schweighöfer, head of the coffee sustainability team. Tchibo's suppliers also mostly have small farmers under contract.
The Wuppertal trading company Gepa buys fairly traded coffee directly from 44 partner cooperatives in 14 countries. Through Fairtrade and organic certifications, the cooperatives already have a lot of documentation that makes EUDR preparation easier, says Kleber Cruz García, purchasing manager for green coffee. Additional tests are still necessary.
There is also educational work: Because of the surveying work, some producers were afraid that their land would be taken away from them, others feared for access to the EU market. "We first had to explain what the regulation requires and what information the cooperatives already have. The trust that we have built up over the years helps us," says Cruz García.
In order to prove that the coffee does not come from newly deforested areas, companies must know where exactly it was grown and collect the geodata of the areas. Tchibo uses the Osapiens platform to check whether forest was cleared for the coffee plantations after the deadline using satellite data. To do this, the suppliers upload GPS coordinates or digitally drawn boundaries of the areas. At Gepa, cooperative employees record the geodata of the plots using mobile devices. A comparison is then carried out using satellite images.
But the data does not always provide clear results. “An alarm does not mean that the forest has actually been cleared,” says Tchibo manager Schweighöfer. If, for example, coffee plants are renewed or shade trees are cut back, the system could interpret this as deforestation. Then additional tests are necessary.
But the satellite images do not show whether a farmer is using his land legally. Companies must also check whether production complies with the relevant regulations of the producing country. These include land use, environmental, labor law and human rights.
According to the UN Agriculture Organization FAO, around 420 million hectares of forest were cut down globally between 1990 and 2020, mostly for agriculture. This corresponds roughly to the area of the EU. The “EU Deforestation Regulation” (EUDR) is intended to prevent further forests from being destroyed for goods on the European market.
Goods covered by the regulation may not come from areas that were deforested after December 31, 2020. Their production must also comply with the laws of the producing country. A due diligence declaration confirms that the required tests have taken place.
The rules apply to cattle, cocoa, coffee, rubber, timber, soy and palm oil, as well as certain goods made from them, such as chocolate or furniture.
The requirements generally apply from December 30, 2026. Small and micro businesses have a little longer under certain conditions. From June 30, 2027, the regulation will apply to all companies.
Companies that bring goods covered by the regulation onto the EU market for the first time or export them from there must generally determine their origin, collect evidence, examine risks and, if necessary, reduce them. A due diligence declaration must be submitted before sale or export. Downstream companies and dealers do not have to carry out their own due diligence, but are obliged to document information on suppliers and commercial customers and store it for possible review.
Among other things, Gepa asks whether producers are owners or tenants or have shared usage rights. “The receipts must be available to the cooperatives and accessible for audits,” says Cruz García.
The company uses questionnaires to record further risks and agree on countermeasures. Tchibo examines risks based on country analyzes and information from its suppliers. For Schweighöfer, however, it remains unclear how comprehensively buyers have to check legal production and what standards apply. She says companies need “clear guidelines and uniform enforcement of the law by national authorities.”
If the requirements are met, the importer submits the due diligence declaration to the EU information system and receives a reference number. “The company remains solely responsible for the accuracy of the due diligence declarations submitted,” says GNF expert Kemper. This also applies when using external software or consultants. Violations may result in fines and affected products and revenue may be confiscated.
In addition to the required evidence, preventative forest protection is needed, says Schweighöfer. Tchibo is working with other coffee companies in the Coffee Canopy Partnership. Joint maps are intended to show where forests are threatened by coffee cultivation - and where protective measures can be taken.
