EUDR Compliance for Coffee Traders: What It Means for Swiss Exporters Selling into the EU

Understanding your role: you are an upstream operator

If your business is based in Switzerland and you sell coffee into the EU, you are considered the first entity placing that product on the EU market. Under the EUDR, this makes you an upstream operator, regardless of being outside the EU.

This distinction is essential: upstream operators carry the full responsibility for compliance. You cannot delegate this obligation to your EU buyer, and you cannot assume that existing certifications or supplier assurances are sufficient on their own. The regulation places the burden of proof squarely on the entity that first introduces the product into the EU market.

Your core obligations under EUDR

Before any coffee is placed on the EU market, you must complete three key steps. Each one is mandatory, and failure to complete any of them can result in penalties of up to 4% of your annual EU-wide turnover.

1. Conduct due diligence

You must ensure that the coffee you sell is:

• Deforestation-free — not grown on land that was deforested after 31 December 2020
• Legally produced — in accordance with the relevant laws of the country of production (in this case, Brazilian environmental, land use, labour, and tax legislation)

This involves a structured process of risk assessment, supplier verification, and documentation. You must evaluate factors including the country risk level, the complexity of your supply chain, the presence of indigenous communities in production areas, and any concerns raised by civil society or media. Where risk is identified as non-negligible, you must implement mitigation measures before proceeding.

2. Ensure full traceability

The EUDR requires precise traceability of coffee back to its origin. This is one of the most operationally demanding aspects of the regulation, particularly for coffee supply chains that often involve thousands of smallholder farmers across multiple regions. Specifically, you must provide:

• Geolocation coordinates of the farms where the coffee was produced — a single GPS point for plots under 4 hectares, or full polygon boundaries for larger plots, in GeoJSON format with WGS84 coordinates at 6-decimal precision
• Information about producers and supply chain actors — names, addresses, and roles of all entities in the chain from farm to EU entry point
• Verification that no mixing with unknown or non-compliant sources has occurred — particularly critical at processing, milling, and blending stages where coffees from different origins are commonly combined

For Swiss traders sourcing Brazilian coffee, this means working closely with your Brazilian suppliers — exporters, cooperatives, and estates — to obtain plot-level geolocation data and maintain a documented chain of custody from farm to port.

3. Submit a Due Diligence Statement (DDS)

Before placing coffee on the EU market, you must:

• Submit a DDS through the EU Information System (built on the TRACES NT platform)
• Declare that due diligence has been carried out in accordance with Articles 8–11 of the regulation
• Confirm that the risk of non-compliance is negligible

Once submitted, you receive a DDS reference number. This number must accompany your product through the supply chain — your EU customer needs it to fulfil their own downstream obligations. Without a valid DDS reference, the product cannot legally be placed on the EU market.

Passing information downstream

Your EU customer — for example, a German importer, roaster, or distributor — becomes a downstream operator under the EUDR. The good news for them is that they are not required to repeat the full due diligence process. However, they must:

• Retain your DDS reference number and be able to present it to competent authorities on request
• Maintain traceability records linking the product to your DDS
• Act if there are substantiated concerns — if they become aware of information suggesting the product may not be compliant, they must take appropriate action, which may include suspending sales and notifying authorities

This system ensures that the heavy lifting of compliance is handled at the point of entry into the EU market, while information and accountability flow through the supply chain. It is designed to prevent the same product from being checked multiple times while maintaining a clear audit trail.

Who holds the responsibility?

One of the most important aspects of the EUDR is that responsibility is not shared — it is assigned. There is no concept of joint liability or proportional responsibility between supply chain actors. As the upstream operator:

• You are legally responsible for the accuracy and completeness of your due diligence
• You remain liable even if you relied on information provided by suppliers, cooperatives, or third-party certification bodies
• Errors or gaps in traceability, geolocation data, or risk assessment fall on your company — not on your Brazilian supplier and not on your German buyer

This is a significant shift from previous voluntary sustainability frameworks where responsibility was often diffused across the supply chain. Under the EUDR, there is one entity responsible for each product entering the EU market, and that entity must be able to demonstrate compliance with documentary evidence.

A critical business decision: who is the importer?

Your compliance obligations depend heavily on one operational detail that many traders overlook:

• If you import the coffee into the EU (i.e., you are the declarant or the entity on whose behalf the customs declaration is made) → you are the upstream operator with full compliance responsibility
• If your German buyer imports the coffee (i.e., they handle customs clearance and are the declarant) → they become the upstream operator and bear the compliance burden

This decision directly affects risk, cost, and compliance workload. Many Swiss traders are currently re-evaluating their Incoterms and contractual arrangements with EU buyers in light of the EUDR. The choice of who acts as importer of record is no longer just a logistics and tax question — it is a compliance strategy decision with significant legal and financial implications.

Key risks to manage

To operate successfully under the EUDR, coffee traders must actively manage several categories of risk:

• Incomplete or inaccurate geolocation data — Brazilian coffee supply chains can involve hundreds of farms across multiple states. Ensuring that every plot is accurately geolocated and validated against the EUDR v1.5 specification is a major data quality challenge.
• Lack of transparency in upstream suppliers — Many traders rely on intermediaries (exporters, cooperatives, local aggregators) who may not have direct relationships with individual farmers. Building visibility into the upstream chain takes time and investment.
• Mixing compliant and non-compliant coffee — At dry mills, warehouses, and blending facilities, coffees from different origins and farms are routinely combined. Without robust segregation and traceability systems, compliant coffee can be contaminated by non-compliant sources.
• Overreliance on certifications without verification — Certifications such as Rainforest Alliance, UTZ, or 4C are valuable indicators but are not sufficient for EUDR compliance on their own. The regulation requires independent verification of deforestation-free status through satellite data and geolocation evidence, regardless of certification status.

Final takeaway

The EUDR shifts the burden of proof to the first company placing goods on the EU market. For Swiss coffee traders exporting into the EU, this means taking a proactive approach to compliance, traceability, and risk management — starting now, not when enforcement begins on 30 December 2026.

Done correctly, EUDR compliance is not just a regulatory requirement — it is an opportunity to build a transparent, sustainable, and trusted supply chain that differentiates your business in an increasingly compliance-conscious market.

Source: This article draws on the European Commission's official EUDR guidance. See EU Publication Office — EUDR Guidance Document.