With the application date of 30 December 2026 now less than three months away, importers of green coffee have one practical question: did the April review move the goalposts? The short answer is no. The Commission's review left the legal text alone and confirmed the calendar. What did change is smaller, more operational, and worth separating from the noise. This article covers only what is new since our earlier piece, EUDR and Brazilian Green Coffee: What Importers Must Prepare Before 30 December 2026.
Regulation (EU) 2023/1115 applies to large and medium-sized operators and traders from 30 December 2026. Most micro and small operators follow on 30 June 2027. The Commission's report on the regulation, COM(2026) 191 final, was adopted on 4 May 2026 under the review clause of Article 34(1a). It did not reopen either date.
The report states that the Commission does not consider it appropriate to propose further amendments to the basic legal text, citing legal certainty. For an importer, this is the key finding: there is no new postponement to plan around, and no new substantive obligation in the regulation itself.
The report instead relies on simplification inside the existing framework. The Commission estimates that the combined measures reduce annual compliance costs by about 75%, from EUR 8.1 billion to EUR 2.0 billion. These are the Commission's own estimates, and actual costs will depend on each company's supply chain. The report also does not introduce a "zero-risk" benchmarking category, so the low, standard and high-risk tiers remain.
Practical points for the coming months:
Commission Delegated Regulation (EU) 2026/2102 amends Annex I of the EUDR. It was adopted on 13 July 2026 and entered into force on 18 September 2026. Among other changes, it adds extracts, essences and concentrates of coffee (soluble coffee, HS 2101 11 00) to the list of relevant products.
Two points matter for planning. First, the new products become subject to the regulation only from 30 December 2027, a full year after the main date. Second, green coffee was already in scope and is unaffected by this act. The change closes a gap that could have let processed coffee reach the EU market without deforestation checks.
If you trade or supply soluble coffee, or sell green coffee to soluble producers, treat 2027 as a mapping year. Review your product codes now, because the act also introduces exclusions for samples, packaging and marketing materials, waste and used products, and removes some unrelated items.
The review and updated guidance clarify who does what. The first operator placing a product on the EU market, or exporting it, submits the due diligence statement. Non-SME downstream operators generally must register in the Information System. For first downstream actors, the duty to collect and keep reference numbers or declaration identifiers is described as passive: they need not request them from suppliers, but must retain what they receive.
For a roaster or distributor buying green coffee already placed on the market by an importer, this means three things to verify before January:
One caution on sources: several trade summaries of the delegated act circulated before publication and give different entry-into-force dates. The EUR-Lex record shows 18 September 2026, so use the official text, not secondary summaries, when you brief your compliance team.
The obligations for large and mid-size importers are unchanged: traceability to plot level, no deforestation after 31 December 2020, compliance with the producing country's laws, and a due diligence statement before the goods enter the EU. The practical work in the final quarter is execution.
The April review gave importers certainty rather than relief: the text stays, the date stays, and the Information System and guidance are more usable. The only new scope item for coffee, soluble coffee, arrives a year later. Teams that spend October to December on testing and contracts, rather than waiting for another delay, will be best placed on 30 December.
This article is for general information and is not legal advice. Confirm obligations against the official texts.
