EUDR for Kenyan coffee: a practical guide for cooperatives and exporters

What is the EUDR?

The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, aims to stop products linked to deforestation and forest degradation from entering or leaving the EU market. It covers seven commodities and products made from them: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Coffee beans, roasted coffee and many coffee products fall within its scope.

To be placed on the EU market or exported from it, a product must meet three conditions:

1. Deforestation-free: produced on land that has not been subject to deforestation after 31 December 2020.
2. Legal: produced in line with the relevant laws of the country of production.
3. Covered by a due diligence statement (DDS) submitted through the EU Information System.

When does it apply?

These dates come from Regulation (EU) 2025/2650, adopted in December 2025, which postponed the original start date for a second time and simplified some obligations. The Commission was asked to review the rules again in 2026, so always check the latest version on EUR-Lex before filing.

Who has to comply: cooperatives, exporters or importers?

The legal obligation to submit a due diligence statement sits with the operator: the company that first places the coffee on the EU market or exports it from the EU. For most Kenyan coffee, that is the EU importer or roaster, not the Kenyan cooperative.

In practice, though, the operator cannot file without information that only the origin can provide. That is why EU buyers are asking Kenyan exporters, who in turn ask cooperatives and estates, for plot-level data. The 2025 amendment also means only the first company to place a product on the market submits a DDS; companies further down the chain pass on reference numbers instead.

What information does a due diligence statement need?

Among other things, the DDS must contain:

• the product description and quantity
• the country of production
• the geolocation of all plots of land where the coffee was produced
• confirmation that due diligence was carried out and the risk is negligible (or, for low-risk countries, that simplified due diligence applies)

Geolocation: the part that falls on origin

Article 2(28) defines geolocation as latitude and longitude coordinates with at least six decimal digits. For plots of more than 4 hectares, the plot must be described by a polygon around its perimeter. For smaller plots a single point is enough. The EU Information System accepts this data as GeoJSON in the WGS84 coordinate system. Our explainer on points, polygons and GeoJSON covers the technical details.

For Kenya this is a large task. More than 800,000 smallholders grow coffee through cooperatives, which produce around 70 per cent of the country’s coffee, according to KIPPRA. In July 2025 the Agriculture and Food Authority announced mandatory national geo-mapping of coffee farms using satellite imagery, and reported that around 30 per cent of the national coffee area had been mapped at that point.

What does Kenya’s low-risk status change?

Under the EU’s country benchmarking, Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025, Kenya is classified as low risk. For operators sourcing from low-risk countries, the regulation allows simplified due diligence: they still collect the required information, including geolocation, but do not need to carry out the full risk assessment and mitigation steps, unless they become aware of a risk. Authorities also check a smaller share of operators sourcing from low-risk countries.

Low risk is not an exemption. Plot geolocation is still part of the information requirement, and the classification can be reviewed.

A practical checklist for Kenyan cooperatives

1. Agree with your exporter what data they need, in what format, and by when.
2. Register every member who delivers cherry, with consent to share plot data with buyers. See digital farmer registration.
3. Map every plot where coffee is grown: a point for 4 ha or less, a polygon above that. Our farm mapping guide explains how.
4. Check the data: no self-crossing boundaries, no unexplained overlaps or duplicates, and areas that make sense.
5. Keep it current when members join or leave, or plots change.
6. Export in the right format: GeoJSON in WGS84 at six decimal places.

How KahawaTrace helps

KahawaTrace covers steps 2 to 6: consent-first farmer registration, GPS point and boundary mapping on Android phones, automatic geometry checks, supervisor approval and GeoJSON export with the properties the EU Information System recognises. Learn more on our EUDR readiness page.

This guide explains the regulation in plain language and is not legal advice.