EUDR · COFFEE · UPDATED 2026
Prepare origin evidence for EUDR without turning the process into another spreadsheet
Nova Silva structures evidence from producers and plots through lots and shipments so the responsible organization can perform due diligence on a traceable basis. Nova Silva does not certify compliance, issue the legal risk conclusion by itself or replace the responsible operator.
Who carries the obligation
Operators and traders
Obligations depend on the actor's actual role and transaction. Evidence prepared at origin supports due diligence but does not automatically transfer legal responsibility to the producer, cooperative or origin exporter.
Limited simplified regime
Article 4a provides a specific pathway for certain micro or small primary operators. It must not be generalized to ordinary exporters or operators.
Current application dates
30 December 2026
Large and medium operators, plus micro/small operators already covered by the EUTR.
30 June 2027
Other micro and small operators within the scope of the regulation.
Evidence that must be reconstructable
Producer, supplier and plot
Stable identities, relationship to the organization, plot and data provenance.
Geolocation
Under the ordinary pathway, plot geolocation remains central. For commodities other than cattle, plots over 4 ha require a polygon. The Article 4a exception is not extrapolated.
Production and traceability
Production period and a reproducible connection from source through deliveries, lots and shipment.
Legality and deforestation
The record should show what was reviewed, for which plot or source, when and under which version or criterion.
Risk and mitigation
Assessment and any mitigation are distinct from merely having documents. Missing evidence may require a blocker or gap, not an invented conclusion.
Shipment and handoff
The package should preserve which sources and documents supported a specific review. DDS references are recorded only when supplied by the responsible operator or an authorized integration.
What Nova Silva does
Organizes evidence, preserves provenance and versions, connects origin entities to lots and shipments, identifies gaps and prepares information for review.
What it does not do: Nova Silva does not certify EUDR compliance, replace legal advice, submit a DDS without an expressly authorized role or integration, or treat a voluntary certification as automatically sufficient legal evidence.
Primary sources
- EUR-Lex · Regulation (EU) 2023/1115, consolidated text
- European Commission · EUDR implementation
- European Commission · EUDR Information System