compliance
EUDR at Origin: What Your Supplier Should Already Have
The EUDR obligation is yours, but almost all the evidence sits at origin. This is the list to send an exporter before you contract, and how to read what comes back.
You carry the liability. Your supplier holds the evidence. That asymmetry is the whole difficulty of EUDR compliance in coffee, and the only way through it is to ask precisely.
Below is a checklist you can paste into an email to any exporter. For each item there is what to ask, what a good answer looks like, and what a poor one usually means.
1. Plot geolocation
Ask: "Can you supply geolocation for the specific plots this lot comes from — polygons for plots above 4 hectares, points below — and in what file format?"
A good answer names a format (GeoJSON, KML, shapefile, or a CSV of coordinates), states whether the plots are polygons or points, and distinguishes between the whole farm and the blocks that actually produced the lot.
A weak answer offers a single point for a large estate, or the address of the exporter's office. A single point for a 40-hectare estate does not satisfy the regulation, and it usually indicates nobody has done the mapping.
Ask for the blocks, not the entity. A lot that is blended across farms needs coordinates for every contributing farm.
2. Land tenure and legal right to produce
Ask: "What documents evidence legal right to produce coffee on these plots?"
In India this usually means land records, plus registration with the Coffee Board of India. The exact document names vary by state, so do not expect a single universal certificate — expect a set.
A weak answer substitutes a sustainability certificate. Organic, Fairtrade and Rainforest Alliance certificates are useful supporting evidence and do not discharge the legality limb.
3. Deforestation status since 31 December 2020
Ask: "Has any of this land been converted from forest since 31 December 2020, and what supports that?"
A good answer is specific about land-use history and offers something checkable — satellite imagery, historical records, the age of the shade canopy, planting dates.
Shade-grown origins have a structural advantage here that is worth understanding rather than taking on trust. A two-tier canopy of mature native trees is not something established in the last five years, and it is visible in imagery going back decades.
4. Traceability from block to container
Ask: "At what point does the lot lose block-level identity — and does it?"
This is the question that catches people out. Most Indian coffee passes through a curing works after the farm, where it is hulled, graded, colour-sorted and bagged. If the curing works processes several estates' coffee, the lot can lose its plot identity there unless it is kept segregated and documented.
A good answer describes how segregation is maintained through curing and bagging, and what records exist at each handover.
A weak answer describes traceability to the exporter's warehouse and stops.
5. Who files the DDS
Ask: "Do you understand that we file the Due Diligence Statement, and can you supply the underlying data in time for us to do it before shipment?"
Timing matters more than people expect. The DDS is filed before goods are placed on the EU market, and the reference number travels with the shipping documents. Evidence that arrives after the vessel does is worthless.
Agree a deadline in the contract: geolocation and legality pack delivered with the pre-shipment sample, not with the invoice.
6. What happens when the answer is no
Not every supplier will be ready, and some good coffee will come from farms that cannot produce polygons this season.
That is a commercial decision, not a moral one. Your options are to mitigate — independent verification, satellite checks, third-party mapping — or to not buy. What you cannot do is file a DDS on evidence you know to be incomplete.
The short version
If you only send one message, send this:
For each lot we contract, we will need: plot geolocation (polygons above 4 ha, points below) for the blocks the lot came from, in GeoJSON or KML; documents evidencing legal right to produce; a statement on land-use change since 31 December 2020 with supporting evidence; and a description of how block-level traceability is maintained through curing and bagging. We file the Due Diligence Statement, so we need this before shipment, not with the invoice.
Where Hoysala stands
Hoysala grows in Chikmagalur under continuous two-tier shade, holds the relevant Coffee Board of India documentation, and cures and grades its own coffee — which shortens the chain between block and container considerably compared with a lot passing through a shared curing works.
If you are assembling a file for the coming season, the overview of what EUDR requires covers the regulation itself.
A working checklist for buyers, not legal advice. Verify against the current regulation text and your own obligations.