EUDR What Ireland Needs to Know About Deforestation-Free Products

EUDR What Ireland Needs to Know About Deforestation-Free Products

Introduction

From December 2025, the European Union’s new Deforestation-Free Products Regulation (EUDR) will begin reshaping how coffee is imported, roasted, and sold across Europe. Coffee is one of seven commodities included in the regulation, which requires that every bag placed on the EU market is traceable to the farm plot and proven to be deforestation-free.

For Ireland, this means importers and roasters face new obligations, while buyers, from cafés to corporate offices, will need to understand what compliance looks like and why it matters. This guide provides a clear explanation of the EUDR, who must comply, how traceability works, and what non-compliance could mean for the coffee sector.

Table of Contents

What the EUDR Is
Who Must Comply (Operators vs Traders vs Buyers)
What Traceability to Farm Plots Means
The Due Diligence Process Explained
Timelines, Enforcement & Penalties in Ireland
What Happens if a Roaster Doesn’t Comply
Compliance in Practice: Who Does What
Choose Coffee That’s Good for You and the Planet
Frequently Asked Questions
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Quick Summary

  • Coffee is a regulated commodity under the EU’s new deforestation law (Regulation (EU) 2023/1115).

  • Operators (importers of green beans or roasters sourcing outside the EU) must prove coffee is deforestation-free, legal, and traceable.

  • Traders (businesses buying from compliant EU operators and reselling) must pass on compliance documentation.

  • End buyers (homes, hotels, cafés, offices) do not file paperwork but should only source from compliant suppliers.

  • Enforcement in Ireland will be led by the Department of Agriculture, Food and the Marine (DAFM), which can inspect, seize, and penalise non-compliant businesses.

What the EUDR Is

The EU Deforestation-Free Products Regulation (EUDR) was adopted in 2023 and targets seven commodities with high deforestation risks: coffee, cocoa, soy, palm oil, cattle, wood, and rubber.

The regulation requires that:

  1. Products must be deforestation-free (no land cleared after 31 December 2020).

  2. Products must be legal under the producing country’s laws.

  3. Products must be traceable to the farm plot where they were grown.

To achieve this, businesses placing coffee on the EU market must submit a due diligence statement through the EU Information System, including geolocation coordinates of the farms.

Who Must Comply (Operators vs Traders vs Buyers)

  • Operators are the first to place coffee on the EU market. In Ireland this typically means:

    • Importers bringing in green coffee.

    • Roasteries that import green beans and roast them locally.

  • Traders are businesses that sell coffee already placed on the EU market. Their role is to store and pass on documentation proving compliance.

  • End buyers such as hotels, cafés, restaurants, and offices are not operators under the law. They do not file due diligence statements. Their responsibility is to buy only from compliant suppliers and keep documentation if they wish to prove ESG standards.

What Traceability to Farm Plots Means

Perhaps the biggest shift under the EUDR is the requirement for geolocation coordinates of the farms where coffee is grown.

  • Larger farms require polygons showing plot boundaries.

  • Very small farms can use single point coordinates.

  • These data points are uploaded into the EU Information System and checked against satellite images to ensure no deforestation has occurred since 31 December 2020.

This is a major change for the coffee industry. Certifications like Rainforest Alliance or Organic remain helpful, but they are no longer sufficient on their own: the EU requires farm-level traceability for every shipment.

The Due Diligence Process Explained

Operators must complete three steps:

  1. Collect Information

    • Product description, CN code, quantity.

    • Supplier and producer details.

    • Geolocation data of the farm plot(s).

    • Proof of legality in country of origin.

  2. Assess Risk

    • Check country or regional risk classification.

    • Evaluate supply-chain complexity.

    • Review farm mapping and satellite data.

    • Consider certifications or audits as supporting evidence.

  3. Mitigate Risk

    • If risk is not negligible, obtain further documentation or conduct audits.

    • Switch suppliers if necessary.

    • Maintain full records and report annually.

Table: Due Diligence at a Glance

Step Requirement Tool / Proof
Information Geolocation, legality proof Supplier docs, EU Information System
Risk Assessment Country risk, supply chain, data quality EU benchmarks, satellite checks
Risk Mitigation Extra audits, supplier change Updated DDS, farm audit reports


Timelines, Enforcement & Penalties in Ireland

  • Application date: Current Commission guidance indicates a one-year deferral.

  • Enforcement: In Ireland, the Department of Agriculture, Food and the Marine (DAFM) is the competent authority. DAFM can:

    • Conduct checks, including unannounced inspections.

    • Request due diligence statements.

    • Detain or block non-compliant coffee.

    • Impose administrative fines or require product recalls.

What Happens if a Roaster Doesn’t Comply

If an Irish roastery imports green beans but fails to comply:

  • Customs and import records will flag the business as an operator.

  • DAFM can request its due diligence statement and supply-chain documentation.

  • If absent, products may be seized, withdrawn from the market, or fines imposed.

For micro-roasteries that only buy roasted beans already imported into the EU, the compliance burden falls on their supplier. In this case, they are traders, not operators, but they must still retain and pass on documentation.


Compliance in Practice: Who Does What

Operators (Importers / Roasteries with direct imports)

  • Collect farm geolocation data.

  • Submit due diligence statements.

  • Maintain audit trails.

Traders (EU roasteries/resellers buying compliant beans)

  • Keep documentation.

  • Pass on compliance information to customers.

End buyers (Hotels, cafés, offices)

  • Not required to file due diligence.

  • Should buy only from compliant suppliers.

  • Can keep supplier statements as part of ESG reporting.

Choose Coffee That’s Good for You and the Planet

At Fzin Coffee, we work only with suppliers who meet these requirements. Our partner Mokador in Italy acts as the operator, importing and roasting under strict sustainability standards including ISO 9001 (Quality Management) and ISO 14001 (Environmental Management). Mokador also contributes to Treedom tree-planting projects, adding traceable climate impact to each cup.

As a trader, Fzin ensures this compliance is passed on to you.

When you buy from Fzin, your coffee and cocoa is already compliant with the EU Deforestation Regulation. We work only with suppliers who provide farm-level traceability and EU due-diligence compliance.

Frequently Asked Questions

Do Irish hotels or cafés have to comply with EUDR?
No. End buyers are not operators under the law. Their responsibility is to buy from compliant suppliers.

Do Irish micro-roasteries need to comply?
Yes, if they import green beans. They are operators and must file due diligence. If they buy roasted beans already in the EU, their supplier is responsible.

What happens if a business doesn’t comply?
DAFM can seize products, block sales, and apply penalties. Non-compliant coffee cannot legally be marketed in the EU.

What evidence should buyers ask for?
Ask suppliers for their due diligence statement reference and supporting documentation (certifications, geolocation proof).

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