The EU Deforestation Regulation (UE 2023/1115) is in force since 29 June 2023. Enforcement, however, is phased. For coffee specifically, three dates matter and they are not the same for every roaster. The point of this article is to help you file your calendar once, correctly, and then forget about it.
The three dates in your diary
First date: 30 December 2025. On this day, operators and large traders enter full enforcement. If you are an importer or a first-handler roaster, you file a Due Diligence Statement before you place the coffee on the EU market.
Second date: 30 June 2026. On this day, small and micro traders enter enforcement. Many specialty roasters fall into this category. Micro means fewer than ten employees and under two million euros annual turnover. If that is you, your clock starts here.
Third date: rolling, per harvest. The regulation requires that the data in your dossier reflects the current harvest. This means a re-screening every year, before the container closes. In Honduras, the harvest window is October to February. We screen in Q1 for the forward offers on the next harvest.
Primary DDS versus downstream DDS
A Due Diligence Statement filed by the first operator placing a lot on the EU market is a primary DDS. A roaster who buys green coffee that has already entered the EU files a downstream DDS, which is lighter. It references the primary DDS of the operator who imported the coffee.
Why this matters practically: ask your importer for their DDS reference. If they can give it to you at the time of purchase, you file a downstream statement from it. If they cannot, you may be in a situation where you need to file a primary DDS yourself, which requires the full plot-level dataset. That is more work.
The six documents your dossier should contain
- A geolocated plot map, GeoJSON format, polygons for every plot in the lot
- A deforestation screening report, each plot scored against the 31 December 2020 reference date
- A Due Diligence Statement reference number issued by the primary operator
- A chain of custody, producer to port, dates and operator identities
- A lab certificate on moisture, water activity, defect count, screen size
- The certifications of origin (ICO) and any voluntary labels (Organic, Rainforest Alliance)
What a non-compliant plot actually looks like
In our 2026 Finca Jerusalén screening, 1 plot out of 1 was cleared. In the 2026/2027 forward offer, the two cooperatives (APROCAJER and COMICAOL) have between them around 1,280 contributing plots. We expect a small number to flag on satellite review. The ones that flag are removed from the lot before dispatch. The volume adjusts. The dossier remains clean.
Removing a plot is not punitive. It is procedural. It allows the lot to ship on time with a defensible compliance posture. We publish the methodology on our compliance page so your due diligence team can retrace it.
“The regulation does not ask for perfection at origin. It asks for traceable risk management. The difference matters.”
What this looks like in practice at Maison Alti
Every lot ships with the six-document dossier. You get the DDS reference at contract signing, not at dispatch. You file your downstream statement from the dossier, and we stand ready to answer any field-level question from your compliance auditor. We priced the dossier into the catalog so there is no separate compliance line to argue over.
If you want to see the format before you commit, register and ask for a sample dossier. We send a full redacted version of one landed lot so your team can review the structure. The whole thing takes a week on your side, and then it is done.